CENVAT Reversal for merchant export

[CA Hemanth Kumar]

Dear Experts,

Does reversal of CENVAT under rule 6(3) of CCR, 2004 will apply for merchant exports, treating as a trading activity or can we take shelter under Rule 6(6) (v) , i.e. export under bond in terms of the provisions of the Central Excise Rules, 2002.

Please provide your views and suportings.

Thanks in advance.

AI Summary

Cenvat credit reversal for merchant exports: exports under bond treated as duty-paid goods, reversal not required.
Merchant exporters who procure goods and export them without payment of duty under bond/LUT should not have Cenvat credit reversed under Rule 6(3), because such exports are not treated as exempted goods but as duty-paid goods for export benefits, permitting reliance on Rule 6(6)(v) for export under bond without reversal.