Kindly send your expert opinion on my below query. We are registered under Central Excise as dealers and we are engaged in Trading business. We are importing products from various countries and make the sales to domestic market under the cover of excise invoice under rule 57G/GG and pass the incurred duty to Customers. Now we are getting enquiry from overseas market. We are having IEC already. Now kindly clarify the following points.
1. Is it allowed to export the goods which is imported as such for trading purpose? 2. What is the mechanism to pass the duty incurred at the time of import? 3. What would be the format of the Invoice. 4. Our product will come under the MRP category. 5. Please tell me the exact procedures to be followed in such cases.
02 August 2025
Great set of questions! Let me clarify your situation step-by-step based on the current Indian customs, excise, and export rules for trading/import-export businesses:
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## Your Situation Summary:
* You are **registered under Central Excise as dealers** (first-stage dealers). * You **import goods** and sell domestically under excise invoices using **Rule 57G/GG** to pass excise duty to customers. * Now, you want to **export those imported goods without further processing**. * You already have an **Import Export Code (IEC)**.
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## 1. **Is it allowed to export goods imported as such for trading purposes?**
* **Yes**, you can export goods imported as such, but:
* The goods should not be restricted or prohibited items. * Export should be made in compliance with **Customs Export Procedures**. * Since goods are imported and not manufactured, your export is considered as **re-export** or trading export. * You must follow customs clearance and file an **export declaration (Shipping Bill)**.
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## 2. **Mechanism to pass duty incurred at import**
* When you import, you pay **Customs Duty** (basic customs duty, IGST, CVD, etc.). * If you sell domestically under Rule 57G/GG, you pass excise duty to customers by issuing an excise invoice. * For exports:
* You **cannot charge excise duty** on exported goods (exports are zero-rated under GST). * You can **claim refund of the duty paid at import** (under certain conditions) through **Duty Drawback** or **IGST refund** mechanisms. * Proper documentation and compliance are required to avail these benefits.
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## 3. **What would be the format of the Invoice?**
* For exports, the invoice must comply with **Customs and Export requirements**:
* Invoice should mention **“SUPPLY TO EXPORT”**. * It should contain:
* Seller & buyer details. * Description of goods, quantity, value. * Shipping details. * IEC Number. * Export Invoice number and date. * It should **not charge excise duty** (since exports are duty free). * Under GST, invoice should follow **export invoice format** with GSTIN and shipping bill details.
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## 4. **Your product will come under MRP category**
* If the product is governed by **MRP (Maximum Retail Price)** rules:
* The MRP should be printed on the invoice. * Export invoices do not usually require MRP, but ensure compliance with **Legal Metrology Rules** for domestic sales. * Ensure pricing and labelling comply with export destination country regulations.
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## 5. **Exact Procedures to follow**
### Import to Domestic Sale (Rule 57G/GG)
* Import goods, pay duty. * Sell domestically with excise invoice under Rule 57G/GG. * Pass duty to customers.
### Export Procedure (Re-export)
* Obtain IEC (already done). * File Shipping Bill with Customs. * Generate export invoice (no excise duty). * Get Customs clearance and shipping. * Claim applicable **Duty Drawback or IGST refund**.
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### Summary Table
| Activity | Key Point | | ------------------------------- | ------------------------------------------------------- | | Export of imported goods | Allowed, subject to Customs procedure | | Passing duty on export invoices | Not allowed; exports zero-rated | | Invoice format | Export invoice without excise duty | | MRP applicability | Relevant for domestic sales; check export country rules | | Refund of duty paid at import | Claim via Duty Drawback or GST refund |
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If you want, I can help you draft sample export invoices, explain filing export declarations, or guide you on how to claim Duty Drawback or IGST refund.