Need advice on EPCG SEO and AEO Fulfilment

[Pralhad Jadhav]

Dear Experts, please guide me through the following query:

The EPCG license period is complete.

1. There are certain shipping bills on which duty drawback benefit has been availed however, EPCG license reference is not present. At the time of redemption, can I request the RA to consider such shipping bills towards the EPCG license which was inadvertently not mentioned therein.

2. I have completed my Specific Export Obligation (SEO) in the first year itself, however throughout six years except one year I have not satisfied my Average Export Obligation (AEO). In such a situation, will it mean that I will have to pay 100% percent of the actual duty saved amount or only proportionate of sum of balance SEO+AEO that is not fulfilled.

3. The shipping bills on which drawback benefit has been claimed but no license number is mentioned, can it be used to fulfill the AEO of two EPCG Licenses.

Thanks in Advance. 

AI Summary

EPCG compliance: ensure licence numbers on shipping bills or amend them, reconcile exports and regularize any AEO shortfall.
EPCG redemption requires shipping bills to show the licence number or an amendment/RA justification; drawback does not bar using exports for EPCG but may require adjustment; SEO and AEO are separate obligations-AEO shortfalls attract proportionate duty plus interest; the same shipping bill cannot be used for multiple licences or to satisfy both SEO and AEO for different licences. Prepare licence-wise reconciliations, CA certification, compute shortfalls, and submit a detailed request to the RA.