Current filing requirements for STPI units under NN 52/2003 regarding imports? Do we need to file FORM A, ICGR-3, or both

[Sudhir M]

As per Customs Circular 7/2021 Clarification regarding payment of Agriculture Infrastructure and Development Cess (AIDC) by EOU under various situations and amendment to Circular no. 35/2016-Customs dated 29.07.2020 - Customs read with Circular No.35/2016 Removal of mandatory warehousing requirements for EOUs, STPIs, EHTPs etc. - Amendment to Notification 52/2003- Customs dated 31.03.2003. - Customs

The STPI unit is required to maintain records and file FORM A with the authorities for the import and export of goods as per Notification 52/2003. However, Notification 52/2003 mentions the ICGR Rules, which have their own form for maintaining records of import and export, known as IGCR-3. Therefore, we seek clarification on whether, as of today, if we are importing under Notification 52, we need to file FORM A, IGCR-3, or both.

AI Summary

Import documentation for STPI units: submit FORM A; IGCR 3 applies only when importing under IGCR Rules.
STPI units importing under Notification 52/2003-Customs must maintain prescribed import and consumption records and submit FORM A as the primary periodic compliance filing; IGCR-3 applies only where imports are made under the separate IGCR Rules. If an entity uses both Notification 52 and the IGCR route, it must maintain dual compliance by filing FORM A for Notification 52 operations and IGCR-3 for IGCR operations, together with required registers, reconciliations and supporting export documentation.