Separate Registration as Importer in addition to registration as Dealer
WE received this mail from a harassed assessee -
The recent amendments vide notifications 08 to 11/2014-CE (NT) effective from 1 st April, 2014 have created myriad of complex issues at the field level.
Some of them are narrated below-
1. Many officers in the department now think that every importer must obtain Central Excise registration irrespective of whether he wants to pass on the CENVAT Credit or not.
2. A person acting as a trader of indigenously procured goods and also as an importer is required to obtain two separate registrations - one as a dealer & the other as an importer.
3. The website (aces.gov.in) does not permit selection of multiple categories in the same application. In the drop down Menu list, a person can select only one of the options.
4. A few officers also insist that the person must have separate premises for each registration.
5. Why 2 separate registrations by the same Company or Individual, having ONE PAN Number?
6. In fact, in case of a manufacturer's depot, the format requires three registrations:
- One as a ‘Manufacturer's Depot'
- Another as a ‘Dealer'; and
- The third one as an ‘Importer'
7. The rule obeying officer would insist the manufacturer to have three godowns. Keep three sets of invoices, RG23D and file three returns.
8. Moreover, the assessee is warned that action would be taken for recovery of CENVAT credits passed without having a separate registration
The Board should understand that framing of rules and regulations is one thing and implementing is another helluva job. It is as if the Board is disconnected with the ground reality!
Hope the Board takes cognizance of this unintended mess and does the needful so that what it sought to achieve by the amendments is not lost in the maze of additional paper work.