Vat on tooling cost

As we understand in this case there would be 2 order- 1) for tool 2) for product. Once tool ready you could raise a local invoice as goods are not moving at all. There is a constructive delivery of tool by you to customer outside India and you continue to hold the tool on his behalf. Tools would not be actually exported ever. Therefore on the day of the invoicing you are liable for VAT on the tool. 

On the components now there is no tooling amortisation as already tool cost VAT paid. 

Sir,

I am very much thankful to you for the reply and agree with your views.

I had gone through your various articles on excise and they are very useful for us. Last year I had even bought your book on excise "Central Excise Law and Procedure" and I use it as a reference book.

I would also like to know that whether excise duty on such tooling cost would attract or will be exempt as tools are used for manufacture of export goods.

Thanks and Regards,

S.S.Balande