Re registration under dealer importer catagory with central excise.

visit your Range Superintendent, with your import documents and corresponding period returns, 

if the import is reflected in your returns he may consider you to get registered from back date, on the strength of return filed, 

Central Excise Registration is unit wise or premises wise and PAN based, if you surrendered the registration, you should file a new registration. There is no mater you are manufacturer or Dealer or Importer etc.

Its only a change of constitution in your excise registration application and which is procedural lapse.

I think there should not be any denial of Cenvat credit to your customers. There are many caselaws where it held that, there should not be denial of cenvat credit which is substantial benefit under law for procedure laps.

If your customer can prove that, goods received has put in manufacturing process on which rightly duty paid, then credit should be allowed to him.

Your customer can submit endrosement letter with his range officer about receipt of goods under GRN and his Cenvat payment details to you and his consumption details.

Venkat

venkat @ hiregange.com

9620116162

Thank you very much Sir for your kind advise.