SSI supplies to 100% EOU

Hi,

I own a Small Scale Unit engaged in manufacture of Corrugated Boxes. I supply primarily to 100% EOUs. My turnover is as follows (approx):

1.4.2008 - 31.3.2009

Supply to DTA/Domestic Sales - 75 lakhs

Total - 75 lakhs

1.4.2009 - 1.2.2010

Supply to 100% EOUs - 130 lakhs

Supply to DTA/Local Clearances - 15 lakhs

Total : 145 lakhs.

I have not taken Excise Registration and hence do not avail cenvat credit. I am supplying boxes under SSI Exemption (150 lakhs).

1. In computing the exemption limit of 150 lakhs, are my sales to 100% EOU's (Rs.130 lakhs) includable ? Could you please point me to the relevent notification and amendments ?

2. A delivery challan (DC) is raised and the goods are sent to my clients' factory - door delivery. I get one copy of the DC back from the client with an acknowledgement stating goods were recieved. This is followed by a Tax Invoice on which VAT is not chargeable if they provide me with quarterly Form H. Are there any procedural lapses here ? Do I need to get any other documents from my customer e.g. A.R.E 1 or A.R.E 3 proving that the goods are in fact exported ? Or is the mere fact that I am supplying to a 100% EOU proof in itself ?

My excise consultant and range inspector disagree and I am not sure who is right.

Please advise.

Thanks & Regards,

GM