EA - 2000 AUDIT QUARY

[Guest]

R/sir, Now a days EA-2000 Audit continue , Auditor ask all EPCG realate documents with istallation certificate from factory start to till date . He ask details about EPCG OBLIGATION complete or not with each machinery wise & also ask EODC Certificate and all export details from factory start to till date against EPCG . Our unit complet audit up to Sept 2009 & Audit report recd clear. Is auditor ask all past details for EPCG related ? Please give suggestion for above issue . Regards, SNEHAL SHAH

[Snehal Kulkarni]

In our view, the EPCG Lic are governed by the DGFT and Customs only. As far as Excise Role is concern it is upto Installation Certificate Only. They are not the competent authority to monitor the EO.

But since the period for EPCG Export Obligation is 8 / 12 Yrs ( as the case may be ) and further the after receipt of EODC the records to be maintained for another 5 Yr, to total span to hold the record is 13-17 Yrs.

If the Excise Department are demanding the documents for scrutiny, do not hesitate to provide. They can ask for the documents related to EPCG since from the begining. There is no time bar as the case of CENVAT/Sale Invoice/Books of accounts which are provided for audit only upto last 5 Yrs.

AI Summary

EPCG export obligation: Excise may request full EPCG documentation though enforcement of obligations rests with trade and customs. EPCG licences are administered by external trade and customs authorities while Excise is limited to verifying the Installation Certificate; however Excise may demand and scrutinise all EPCG-related documents, including export performance and EODC, and because export obligations plus post EODC recordkeeping create an extended retention horizon, EPCG records are not subject to the ordinary short audit time bar and should be produced when lawfully requested.