Remove as such

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DEEPAK ROHERA (Querist)

02 August 2016 We are registered in excise as manufacturer we had purchase a non excisable goods in manufacturing division now we want to sales as it is that goods shall we paid duty on that or not any notification please provide

Arun Kumar Singh

Arun Kumar Singh (Expert)

04 August 2016 If you have purchase the non excisable goods and sale as it is then no need to pay excise duty.

DEEPAK ROHERA

DEEPAK ROHERA (Querist)

05 August 2016 we remove that material through Rule 11 Invoice or other invoice and any other register maintain for that

Aashok Kumar Sharma

Aashok Kumar Sharma

(Expert)

21 July 2025 Great question — you're dealing with the removal of non-excisable goods "as such" by an excise-registered manufacturer, and you're unsure about:

Whether excise duty is payable,
Whether to use a Rule 11 invoice,
And what records/registers to maintain.
Let’s clarify:

✅ Situation:

You are a manufacturer registered under Central Excise.
You purchased non-excisable goods (e.g., exempt goods, or goods not listed in the Central Excise Tariff).
Now you want to sell/transfer those goods as-is, without using them in manufacturing.
🧾 Excise Duty Applicability

✅ No excise duty is payable on removal of non-excisable goods, because excise applies only to excisable goods under Section 3 of the Central Excise Act, 1944.
Since the goods are non-excisable, they are outside the scope of excise altogether — even if you are an excise-registered manufacturer.
🔹 Reference: Rule 3(5) of the CENVAT Credit Rules only applies to inputs on which CENVAT credit has been taken, and which are excisable.
🧾 Should You Use a Rule 11 Invoice?

❌ No, do not use a Rule 11 excise invoice.
Rule 11 invoices are only for the removal of excisable goods under Central Excise Rules, 2002.

Instead, you should use a commercial (tax) invoice — similar to how a trader would invoice — with:

Standard buyer/seller details,
Description of goods,
Sale price,
VAT/CST (as applicable pre-GST),
No excise duty column.
📒 Record-Keeping Requirements

Since the goods are not subject to excise, you:

Don’t need to maintain RG-1 or RG-23 records for them.
Can maintain a separate inward/outward register (even in Excel) for non-excisable goods to ensure clear audit trail.
If your ERP system mixes excisable and non-excisable items, consider using separate item codes or tags.

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