Replenishment against Advance Authorisation

[Ganesh]

Dear Members,

An advance authorisation was obtained during March 2026 to import goods without duty. During April 2026 a notification 12/2026-Customs dated 01.04.2026 was issued exempting BCD for certain goods (temporary benefit due to middle east conflict). Goods for which AA which was already obtained are covered in this notification. Using the exempted goods bought under notification 12/2026-Customs, goods were manufactured and exported mentioning the AA number. Now that the temporary exemption is withdrawn, can I carryout import replenishment against AA and redeem the AA against exports already made?

I didn't find any condition in notification 12/2026-Customs nor in FTP/HBP of any restrictions on such replenishment.

Wanted to get the views of experts of any specific aspect which i may have to consider or any issue that could come up by following this approach.

Thanks.

[Shilpi Jain]

In my view, yes, unless the input carries a pre-import condition under Appendix 4J or the SION https://www.taxtmi.com/acts?id=41741.

Otherwise, imports after export can be made as replenishment. The IGST pre-import condition was removed by Notfn 1/2019-Cus https://www.taxtmi.com/notifications?id=127809.

AI Summary

Advance authorisation replenishment permits post-export imports unless input-specific pre-import conditions restrict the relevant imported inputs.
Post-export replenishment under an Advance Authorisation may be available where duty-exempt inputs were used for manufacture and export, subject to any applicable input-specific pre-import requirement. No restriction is identified in the temporary basic customs duty exemption, the Foreign Trade Policy, or the Handbook of Procedures. Removal of the earlier IGST pre-import condition supports replenishment imports after export where no surviving pre-import condition applies.