Single registration -reg.

This query is : Resolved 

15 February 2017 Dear sir

Two units, one located opposite to each other. Unit 1 is a Partnership firm registered under central excise while unit 2 is a non excisable proprietary concern which is currently a job worker for unit 1 ,doing an intermediate process for unit 1. We wants a single registration for both of them in terms of excise notification 36/2001-C.E (N.T. ) dated 26-06-2001.

16 February 2017 If one unit is doing jobwork for another unit then no need to registered under central excise for jobwork unit.

18 February 2017 Dear Sir,

Two unit segregated by public road, one is partnership firm registered under central excise and second is job worker not registered central excise department. Two premises are located within a close are in the jurisdiction of central excise. Manufacturing process undertaken therein interlinked. We wants a single registration under new Notification 19/2016 CE (NT).

18 February 2017 If principal manufacturer are paying duty on final products then no need to registered under central excise to jobworker and paying any service tax on job work activity (intermediary services).

20 February 2017 Dear sir

thanks for your reply. But my question is that both units i.e. our manufacturing unit registered with central excise and unit doing job work falls under same central excise jurisdiction and we want to merge it with our manufacturing unit. Now problem is that the job-work unit is on lease and plant & machinery is already installed in it. Therefore, whether it is possible to register under single registration when the unit is on lease?

25 July 2025 Hereโ€™s a clear explanation regarding **Single Registration under Central Excise for two units (one manufacturing, one job work)**, especially when one unit is on lease:

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### Context:

* Unit 1: Partnership firm, registered under Central Excise.
* Unit 2: Proprietary concern doing job work for Unit 1 (intermediate process), not registered under Central Excise.
* Both units are in close proximity but separated by a public road.
* Query: Can they have **single Central Excise registration** under Notification 19/2016-CE (NT) or earlier Notification 36/2001-CE (NT)?

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### Key Points & Clarifications:

1. **Central Excise Single Registration Concept:**

* As per **Notification 19/2016-CE (NT)** (earlier 36/2001-CE (NT)), **units under the same management** located within the same premises or complex may be allowed to have **single Central Excise registration**.
* This helps simplify compliance and reduce paperwork.

2. **Job Work Unit and Registration:**

* If the job worker is **processing on behalf of the principal manufacturer** who pays the excise duty on final goods, **the job worker need not have separate Central Excise registration**.
* The job worker activity is treated as a service to the principal manufacturer.

3. **Effect of Separate Location & Lease:**

* If the job work unit is **on lease and located separately**, even if nearby but separated by a public road, **it may be treated as a separate premise**.
* Single registration typically requires units to be within the **same premises or contiguous premises**, not separated by a public road or different ownership.

4. **Can Single Registration Be Allowed When Job Work Unit Is on Lease?**

* Generally, **single registration is allowed only if the units are under the same ownership or management and located within the same premises or adjoining premises**.
* Leasehold premises for job work unit complicates this because ownership and control are separate.
* Customs and Excise authorities may **not allow single registration** in this case.

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### Recommendations:

* **Check with Jurisdictional Central Excise Office:** Because interpretations and permissions may vary.
* **If single registration is not possible, job worker can continue without registration** if principal manufacturer pays duty and accounts for job work as per law.
* **Service Tax** may be applicable on job work as an intermediary service.

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### Summary Table:

| Condition | Single Registration Possible? |
| --------------------------------------------------------------- | ----------------------------------------------------------------------- |
| Units under same management, same premises | Yes |
| Units under same management, adjoining premises | Possibly, subject to authority |
| Units separated by public road or different ownership/leasehold | Usually No |
| Job worker doing processing for principal manufacturer | Job worker may not require separate registration if principal pays duty |

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If you want, I can help draft a letter to your Central Excise jurisdiction seeking clarification or applying for single registration. Would you like me to help with that?


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