Registration as importer

[Vinay Sharma]

Dear Sir,

A company with multiple units is engaged in manufacture of auto parts. All units of the company are registered as manufacturing units in excise.It purchases raw materials in domestic market as well as thru direct imports. The imports are made in one of the units and it is consumed partially in the same unit and partially in other units. Imported material is transferred to other units on invoice and proportionate duty equal to CENVAT credit is paid. The transferee units take CENVAT credit on the basis of invoice so issued.

Please advise on the following points

1- Is the procedure adopted as above is correct.

2- whether the transferor unit is required to obtain a seperate excise registration as importer.

3- If yes, can an endorsement be made of the same registration for imports as well instead of taking a seperate registration in same manner as done for adding services in case of service tax.

With best regards

[MUKUND THAKKAR]

Sir,

1- Is the procedure adopted as above is correct.

if you are cleared goods as such your procedure is correct to subject to proportionate duty equal to CENVAT credit is paid.

2- whether the transferor unit is required to obtain a seperate excise registration as importer.

No any seprate registration is required.because rules is not restricted inter transfer activity.

3- is not applicable.

AI Summary

Company's CENVAT Credit Procedure Valid; No Separate Excise Registration Needed for Inter-Unit Transfers Under Current Rules. A company involved in manufacturing auto parts across multiple units seeks advice on its import and excise registration procedures. The company imports raw materials into one unit, partially consuming them there and transferring the rest to other units. It pays proportionate duty equal to CENVAT credit, and the transferee units claim CENVAT credit based on invoices. The query addresses whether this procedure is correct and if a separate excise registration as an importer is needed. The response confirms the procedure is correct, no separate registration is required, and the rules do not restrict inter-unit transfers.