Registration: dealer

This query is : Resolved

Querist : Anonymous

Querist : Anonymous (Querist)

07 November 2012 I am the coal dealer. Purchasing from ESSAR Co.. Essar is importing from australia. I had applied for registration for excise as a dealer. But Asst. commissioner refused the application, because coal is exempt from excise duty. Hence no Registration required.

Please suggest me whether i withdraw my application or move forward.

Thanks in advance.

U S Sharma

U S Sharma (Expert)
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08 November 2012 mention your tariff sub head, all coal are not exempted,

however if your sub head is exempted, then registration is not necessary.

Querist : Anonymous

Querist : Anonymous (Querist)

22 November 2012 27011200

Aashok Kumar Sharma

Aashok Kumar Sharma (Expert)
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20 July 2025 Thanks for sharing the tariff sub-head: 27011200, which corresponds to bituminous coal under the Central Excise Tariff.

Here's the clarification:
As of your query date (November 2012), coal under Tariff Item 27011200 (bituminous coal) was subject to various notifications and changes around excise applicability. However, at that point in time:

✔️ Key Points:
Bituminous coal (27011200) was subject to excise duty, but exempt under certain notifications depending on the usage or buyer.
If Essar is importing the coal and you're only trading (not manufacturing), and if the product is exempted at the point of your sale, then:
Central Excise registration is generally not required for a dealer trading in fully exempted goods.
If there is no excise duty charged at any point in the supply chain, and no CENVAT credit is passed on, then you don't need dealer registration.
🔍 Recommendation:
Since the Assistant Commissioner has already confirmed that registration is not required due to exemption, and unless you intend to issue CENVATable invoices (i.e. pass on credit), you can withdraw your application.
Keep a written clarification/order from the Excise department for your records in case of future audit or inquiry.

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