PVC film sheets

[ASHOK AMIN]

Dear Experts,

We are in manufacturing of electroplating chemicals and equipment (engineering goods) We are having four plots in the same compound and it is registered under excise. From the four plot one of the plot is for manufacturing of engineering goods. Secondly, one of the plot from the four plots have an adjoined plot which is having entrance from the other side where we undertake trading activities and it is not registered under excise since more than a decade. Informed excise department as well. We import goods like electrophoretic chemicals, pvc film sheets and sell it to customers as it is. Now, we want to shift our trading activities at the engineering manufacturing unit due to shortage of space.

Our querry is ;

1) can we conduct trading activities from the engineering plot,

2) further our customer requires cenvat credit on pvc films, so, we decided not to shift the pvc films activities to the new place but, instead take dealers registration at the current trading plot and follow the excise procedures can we do that, and,

3) will the customer come to know of our import price of pvc films if we raise dealers invoice, if yes than what are measures we should follow in order to safeguard our import price.

We are very much in need of a solution for the above query. Request to all the experts to guide us in this matter as soon as possible.

AI Summary

Separate dealer registration required to issue cenvat-enabled invoices; trading from manufacturer premises is restricted and import price disclosure unavoidable.
A manufacturer must obtain separate dealer registration to issue cenvatable invoices for trading in duty-paid goods; trading from premises registered solely for manufacture is ordinarily restricted and special permission is needed when traded goods are identical to manufactured goods. Issuing cenvat-enabling invoices will disclose procurement and duty details, so import price cannot be concealed. If manufacturing and trading occur near each other, maintain strict demarcation and separate records and, where uncertain, seek permission from the jurisdictional authority to avoid regulatory complications.