Single Registration - an ambiguous Circular
VIDE Board Circular 1016/4/2016-CX, Dated: February 29, 2016 it is informed that Notification No. , dated 26.06.2001 has been amended vide Notification No. , dated 01.03.2016 to provide that -
- if two or more premises of the same factory are located in a close area,
- these premises are within the jurisdiction of a Central Excise Range, and
- the process undertaken there are interlinked, and
- the units are not operating under any of the area based exemption notifications,
then the Commissioner of Central Excise, may, subject to proper accountal of the movement of goods from one premise to other and such other conditions and limitations, as may be prescribed, allow single registration.
A Netizen writes -
It seems that the four circumstances narrated above are to be simultaneously satisfied inasmuch as they are not mutually exclusive to each other.
Further, section 2(e) of the CEA, 1944 defines factory thus -
(e) "factory" means any premises, including the precincts thereof, wherein or in any part of which excisable goods other than salt are manufactured, or wherein or in any part of which any manufacturing process connected with the production of these goods is being carried on or is ordinarily carried on;
In this view of the matter, it is apparent that the premises for which a single registration is envisaged is other than the premises located in the precincts but located in a ‘close area'. What is ‘close' cannot be fathomed by a layman - is it the ‘closeness' as shown in the toothpaste advertisement?
Suffice to say that if the ‘premises' are falling within the jurisdiction of the same Central Excise range, which jurisdiction can cover a few hundred square kilometres, they are to be considered as close to each other!
It is felt that such a weird yardstick for granting a single registration has the propensity to aggravate and smother the mantra of ease of doing business, not to mention the increase in litigation!