Company Name changes-regarding

[Mathi]

Dear All.

We have changed the company name from XXXXXXXX to XXXXXXX Associates. We already obtained 2 advance Licenses from existing company. IEC also updated with new entity name. Now any step should we take for Name changes in the License or shall we apply for closure directle ?

No changes in the PAN and IEC No

[YAGAY and SUN]

Subject to verification of the specific Advance Authorisation(s), if there is only a change in the entity name and no change in PAN or IEC number, there is generally no requirement to close the licences merely because of the name change. Since the IEC has already been amended with the new name, the underlying importer-exporter identity remains the same. As per Para 2.14 of HBP 2023, modifications in IEC details are to be updated online, and transfer/linkage issues primarily arise where there is a change in PAN or a new IEC.

Accordingly, you may first examine whether the existing Advance Authorisations require a formal amendment to reflect the revised company name. DGFT permits amendments to authorisations, and applications for amendment of an authorisation can be filed with the concerned RA.

If the authorisations are no longer required and there is no import/export obligation pending, closure/redemption may be pursued as per the applicable provisions. However, where any obligation under the licences remains outstanding, it is advisable to have the records/licences aligned with the updated entity name before seeking redemption/closure.

Therefore, based on the facts shared:

1. No fresh licence or transfer is required, as PAN and IEC remain unchanged.

2. Consider filing an amendment request with the concerned DGFT RA to update the company name on the Advance Authorisations, if not already reflected.

3. Closure/redemption may be filed directly only after ensuring compliance with all obligations under the licences, wherever applicable.

For a definitive view, the licence conditions and current EO/closure status of the two Advance Authorisations should be reviewed.

AI Summary

Advance Authorisations and company name change: amendment may suffice where PAN and IEC remain unchanged, with closure only after obligations end.
A change in company name, without any change in PAN or IEC number, does not ordinarily require closure of existing Advance Authorisations merely because of the name change. The existing authorisations may be examined to determine whether a formal amendment should be filed with the concerned Regional Authority to update the revised company name. If any obligation under the licences remains outstanding, the records and authorisations should first be aligned with the updated entity name before seeking redemption or closure.