IN FORCE Policy Relaxation Committee Advance Authorisation 2024-08-30

DGFT Committee Minutes

Document text

Directorate General of Foreign Trade (PRC Section)

Minutes of the Policy Relaxation Committee Meeting Held on 07.08.2024 under the Chairmanship of Shri Santosh Kumar Sarangi, Director General of Foreign Trade

Meeting No.13AM25 held on 07.08.2024

The following members were present in the meeting:

Ms. Shubhra Sr.Dev.Commissioner 2. Shri Hardeep Singh Addl. DGFT 3. Shri Anil Aggarwal Addl. DGFT 4. Dr. S.K. Bansal Addl. DGFT 5. Shri S.C.Agarwal Addl. DGFT 6. Shri Rakesh Kumar Addl. DGFT 7. Shri K.V.Tirumala Joint DGFT 8. Shri K.M. Harilal Joint DGFT 9. Shri Randheep Thakur Joint DGFT 10. Shri Md. MoinAfaque Joint DGFT

Following cases were discussed. The decision taken on the individual cases are as under:-

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Case No.01 M/s. Mallak Specialties Private Limited, Mumbai

F.No.HQRPRCAPPLY00004214AM25

Meeting No.13AM25 held on 07.08.2024

Subject: Request for relaxation to grant FMS license which was not filed within due date.

Applicant’s statement: One of our colleague who handled refund related work skipped to claim refund on some shipping bills and it was bought to our notice only after his sudden resignation from the company. During audit our auditor pointed out missing of Page 2 of 37 go¥'\

some shipping bills where claim was not filed. Now we would like to apply for the refund which is our rightful and genuine dues.

Decision: The Committee reviewed and went through the justification furnished by the firm and discussed the case at length and found no merit in the request of the firm. Accordingly, it decided to maintain rejection of the earlier decision of PRC in its Meeting No.02AM25 held on 19.04.2024 (Case No.7).

(Action: Applicant)

Case No. 02 M/s. Mallak Specialties Private Limited, Mumbai

F.No.HQRPRCAPPLY00004215AM25

Subject: Request for relaxation to grant FPS license which was not filed within due date.

(Action: Applicant)

Case No.03 M/s. Sun Pharmaceutical Industries Limited, Mumbai

F.No.HQRPRCAPPLY00004463AM25

Subject: Request for extension of EOP against Advance Authorization No. 0511015886 dated 18.11.2022.

Applicant’s statement: Please note that due to slow demand of the resultant product in foreign market we were unable to fulfill export obligation within the initial and extended EO period. We have confirmed export order of export resultant product in hand for shipment to be made in coming months. We have got 1st EOP extension from CLA up to 18/11/2024 and fulfillment the export obligation within the period. Since remaining balance quantity of Export obligation (619.674 Kgs) yet to be exported towards fulfilled EO. Hence, we request you to consider our case for EOP extension for

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further SIX Months from the date of 1st EO extended period towards fulfillment of Export obligation. In this regard, we request you to kindly allow EOP extension for Further SIX month period from the Expiry of FIRST extended EO period enabling us to fulfil export obligation within the EOP extension and oblige.

Decision: The Committee went through the justification made by the applicant and discussed the matter at length. After detailed discussion it was decided to accede to the request and allowed EOP extension of Advance Authorization No. 0511015886 dated , 18.11.2022for a further of 6 months from the date of endorsement subject to payment of composition fee as per policy provisions. The firm shall approach RA concerned within 30 days from the date of uploading of the minutes of meeting.

(Action: Applicant/RA-CLA-New Delhi)

Case No.04 M/s. R R K Cotton's India Private Limited, Tamil Nadu

F.No.HQRPRCAPPLY00004447AM25

Meeting No.13AM25 held on 07.08.2024

Subject: Request for extension of EOP against Advance Authorization No. 3211002270 dated 05.01.2022.

Applicant’s statement:With reference to the Advance Authorization No. 3211002270/ 05.01.2022, we completed part of the Export obligation and not able to complete the balance part of the export obligation because of order cancellation from the buyer. Now we are searching for the new buyer for exporting the balance obligation qty, but still we are not able to find out the buyer. We already got the EOP extension two more times in the RA Coimbatore (Which we got extension up to 05.07.2024) and still we are not able to complete our balance export obligation. We request you to grand for another one year of EOP extension ie up to 05.07.2025 for fulfilling the balance export obligation.

Decision: The Committee went through the justification made by the applicant and discussed the matter at length. After detailed discussion it was decided to accede to the request and allowed EOP extension of Advance Authorization No. 3211002270 dated 05.01.2022 for a further of 6 months from the date of endorsement subject to payment of composition fee as per policy provisions. The firm shall approach RA concerned within 30 days from the date of uploading of the minutes of meeting.

(Action: Applicant/RA-Coimbatore)

Case No.05 M/s. SMS Pharmaceuticals Limited, Hyderabad F.No.HQRPRCAPPLY00004501AM25 Meeting No.13AM25 held on 07.08.2024

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Subject: Request for extension of EOP against Advance Authorization No. 0911000628 dated 29.03.2021.

Applicant’s statement: The company has obtained Advance Authorization for export of Levetiracetam vide Authorization No.0911000628 dated 29.03.2021. The company has sourced inputs materials and manufactured the product as well as exported 72% of licensed quantities. It is submitted that the period of export obligation was allowed upto 28.07.2024. We have sufficient export orders on hand for the balance quantity of 28 MT and our customer has slowdown the intake due to some modification in their production schedules and they have assured to take the material in next 3 to 4 months. Hence, we request your kind authority allow EOP extension to fulfill the balance export obligation at our end. The delay in export of the product due to slowdown of the product in the market and our customer M/s VKT Pharma Private Limited (VKT) is formulation maker and the company has tied up with M/s EywaPharma Inc., (Eywa) who are the distributors in US market. EywaPharma is sourcing Formulation from VKT and selling to US market. Eywa has holding/divert the sales proceeds without payment to VKT against purchases which resulted the product movement was getting slowdown and subsequently stopped by VKT. We came to understand that Eywa was financial troubled and settled with our customer VKT and subsequently cancelled the agreement by both the parties. As per the market news, Biocon has brought by Eywa as outright basis.

Decision:The Committee went through the justification made by the applicant and discussed the matter at length. After detailed discussion it was decided to accede to the request of the firm and allowed EOP extension of Advance Authorization No. 0911000628 dated 29.03.2021 for a further period of 6 months from the date of endorsement subject to payment of composition fee as per policy provisions. The firm shall approach RA concerned within 30 days from the date of uploading of the minutes of meeting.

(Action: Applicant/RA-Hyderabad)

Case No.06 M/s. Unique Autorubber Udyog Private Limited, Faridabad

F.No.HQRPRCAPPLY00004494AM25

Meeting No.13AM25 held on 07.08.2024

Subject: Request for revalidation of Scrip against MEIS Scrip No. 0519287888 dated 09.03.2022, 0519286612 dated 28.02.2022, 0519287605 dated 09.03.2022, 0519286613 dated 28.02.2022.

Applicant’s statement: | am writing to bring to your attention an issue regarding my Merchandise Exports from India Scheme (MEIS) license, which has unfortunately expired before | could fully utilize it. Details of the MEIS License: (IEC NO. 0509001076) M/s. Unique Auto Rubber Udyog (P) LTD. - MEIS License Number: 059287888 Date of Page 5 of 37 or

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Issue: 09.03.2022 Expiry Date: 08.03.2023 - MEIS License Number: 0519286612 Date of Issue: 28.02.2022 Expiry Date: 27.02.2023 - MEIS License Number: 0519287605 Date of Issue: 09.03.2022 Expiry Date: 08.03.2023 - MEIS License Number: 0519286613 Date of Issue: 28.02.2022 Expiry Date: 27.02.2023 Due to unforeseen circumstances, | was unable to utilize the benefits of the MEIS license within the given validity period. | am a committed exporter and have always complied with the regulations set forth by the DGFT. The benefits from this scheme are crucial for my business operations and significantly contribute to my competitive edge in the international market. Given the importance of this matter, | kindly request your office to consider an extension of the validity period for my MEIS license. An extension would allow me to make full use of the benefits and continue contributing to the growth of India's exports. | assure you that | will utilize the extended period effectively and adhere to all guidelines and requirements specified by the DGFT. Your understanding and support in this matter would be greatly appreciated. Decision: The Committee went through the statements made by the firm and noted that the applicant has not submitted any cogent reason/ justification in support of any genuine hardship faced by them. Accordingly, the Committee decided to reject the request.

(Action: Applicant)

Case No.07 M/s. Millenium Exim Private Limited, West Bengal

F.No.HQRPRCAPPLY00007305AM24

Meeting No.13AM25 held on 07.08.2024

Subject: Request to allow the export to Bhutan realized in Indian Currency against EPCG Authorization No. 0230008922 dated 01.07.2013.

This is review case of PRC Meeting No.23/AM24(Case No.53) held on 12.12.203 wherein Committee reject the case. Applicant’s statement: Review of PRC Committee decision vide Meeting No. 23/AM24 held on 12.12.2023, Case No. 53 of Millenium Exim. Please note that out export is not a normal Indian Rupee Export, it is export realized through Vostro Account Mechanism to Bhutan. We attached Vostro Account Certificate of State Bank India. This request was considered by EPCG Committee in the 1st Meeting on AM-24 held on 27.04.2023 and 04.05.2023 wherein Committee decided to refer the case to PRC Section for necessary action. The applicant stated that they have exported to Bhutan in Indian Rupee Currency value is Rs. 8,05,52,362.94 within export obligation period of the subject EPCG license under 0% concessional duty. They have already paid composition fees for Rs. 203921. Hence they are requesting to allow export to Bhutan realized in Indian Rupees towards fulfillment of EO against EPCG License no. 0230008922 dated 01.07.2013 yk

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Decision: The Committee examined the case on the basis of submission made by the firm and discussed the matter at length. After detailed discussion it was decided to refer to RA Kolkata to examine as per relevant Policy/HBP provisions for resolution. Applicant may approach the RA.

(Action: Applicant/ RA-Kolkata)

Case No.08 M/s. Ganges Jute Private Limited, Kolkata

F.No.HQRPRCAPPLY00007749AM24

Subject: Request for revalidation of Scrip against MEIS Scrip No. 0219096925 dated 10.11.2020.

Applicant’s statement:We have submitted MEIS licence for registration and verification at JNCH, NhavaSheva on dated 11.10.2020, due to Covid period we can't receive our original MEIS Licence from JNCH, NhavaSheva. Our MEIS Licence has been misplaced by Custom authority and expired at Custom custody. They have now obtained NUC and NOC in January 2024 from JNCH Custom Authority.

Decision: The Committee went through the statements made by the firm and noted that the applicant has not submitted any cogent reason/ justification in support of any genuine hardship faced by them. Accordingly, the Committee decided to reject the request.

(Action: Applicant)

Case No.09 M/s. Adani Wilmar Limited, Ahmedabad

F.No.HQRPRCAPPLY0000737AM25

Meeting No.13AM25 held on 07.08.2024

Subject: Request for extension of import validity period for 1 year against Advance Authorization No. 0810146819 dated 20.12.2019.

This is a review case of PRC Meeting No.31AM24 held on 01.03.2024 (Case No.07) wherein Committee decided to reject the case.

Applicant’s statement: Our application for extension was filed due to the hardships faced by our company in importing Crude Sunflower Oil and Crude Soyabean Oil, stemming from technical issues in the Standard input output Norms (SION) norms, particularly E-124 and E-121. The SION norms for Crude Sunflower Oil permitted

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imports within a specific Free Fatty Acid (FFA) range of 1.4% to 1.8%. Similarly, the SION norms for Crude Soyabean Oil permitted imports within a specific Free Fatty Acid range of 1.5% to 3%. Consequently, we applied for a amendment to the SION norms allowing to import crude edible oils of lower FFA grade. However, while awaiting the approval of the SION norms amendment, we were unable to import the necessary goods within the allotted time frame of the Advance Licenses. We were unable to complete import obligation of said license due to Pandemic situation globally and market recession as well as SION Modification (67/121) to Norms Committee to DGFT Delhi as per FSSAI Standard. In view of the above circumstances, we urge the authority to kindly grant us extension for import of said Advance License. We remain at your disposal for any further information required on the said matter.

(Action: Applicant)

Case No.10

M/s. Continental Hospitals Private Limited, Hyderabad

F.No.HQRPRCAPPLY0000820AM25

Meeting No.13AMZ25 held on 07.08.2024

Subject: Request for extension of Total EO Period against EPCG Authorization No. 0930008439 dated 31.07.2012

Applicant’s statement: We have obtained above EPCG Authorization for procurement of Capital Goods, accordingly Capital Goods were procured and the same has been installed in our premises. Our Endeavour was to complete our exp0I1 obligations under the license well within the 8 years. When we were under swing of growth in export business, we were affected by the covid period that hampered forex earnings. We have elaborated the circumstances and reasons in detailed below, seeking further extension of period as stipulated. Our performance: We successfully completed export obligation fulfillment for 13 EPCG licenses and obtained EODC from the ADGFT - Hyderabad office for total EO Value of Rs. 45 Crores. We would like to submit to the office that we have availed the Amnesty scheme and paid Rs.6,79,89,223 (6.79 Crores) to regularize 4 EPCG Licenses. Current Situation: As per HBP 5 Chapter FTP provisions, under the EPCG scheme we have to full fill the export obligation over the specified period in following proportions and Export obligation fulfillment details are mentioned below. We were unable to achieve 100% EO against this EPCG Authorization and opted for extension of EOP by 2 years. The two years expiry was during the covid period. Original Expire of Export obligation is 29.07.2020 Actual EOP Extension for 2 years is up to 29.07.2022. We request you to give us permission to complete EO for this license till 29.07.2026. ; Position regarding EO was seen from the application. Qo a\

Page 8 of 37

(Action: Applicant)

Case No.11 M/s. Cropnosys (India) Private Limited, Mumbai

F.No.HQRPRCAPPLY00004512AM25

Subject: Request for extension of EOP against Advance Authorization No. 0310786547 dated 08.07.2014

Applicant’s statement: Kindly note that due to recession of demand of our export product in the international market during years 2016-2017 upto March, 2017, we were not able to export the product as per the advance authorization and could not met the balance export obligation imposed against the above referred advance authorization. Hence require EO extension for six months from date of endorsement.

(Action: Applicant)

Case No.12 M/s. Damara Gold Private Limited, Mumbai

F.No.HQRPRCAPPLY0000997AM25

Subject: Request for considering free shipping bill for counting of specific EO against EPCG Authorization No. 0330044290 dated 06.05.2016.

Applicant’s statement:Free shipping bill to be granted for counting of EO 1. We purchased gold from Nominated Agency namely HDFC Bank. 2. Our purchase is against the LUT/Custom Bond wherein clearly mentioned the EPCG Authorization number and date, Items of export with ITC HS code matching with the Authorization. 3. Since the purchase made from Nominated Agency and no other beneficial scheme applicable to Export of Articles of Gold Jewelry ( ITC code 71131910, 71131920, 71131940 ) Sir, under the above evidential circumstances our Export may be considered in obligation under the EPCG authorization.

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Decision: The Committee reviewed the case on the basis of statement made by the firm and observed that there is no merit in firm’s contention. Hence, it decided to maintain the rejection of the earlier decision of PRC Meeting No.05/AM25 held on 10.05.2024 (Case No. 17).

(Action: Applicant)

Case No.13 M/s. Jain Recycling Private Limited, Chennai

F.No.HQRPRCAPPLY000034496AM25

Subject: Request for revalidation of Authorization/Certificate against Advance Authorization No. 3210079645 dated 18.08.2020, 3210079645 dated 18.08.2020, 3210079610 dated 16.07.2020.

Applicant’s statement:We have made an excess export of 436461 Kgs of Refined Copper Billets against the said authorization. Due to unavailability of our input item Copper Scrap Druid (CU 37.5% to 42.5%) in the market, we couldn't able to import the material within the time limit. Whereas we are required to import 1026389 Kgs of Copper Scrap Druid (CU 37.5% to 42.5%) against the excess export made. The License was issued on 13-08-2020 and the revalidation for the said license is expired on 13-082021. Hence, we request that please grant us 1 year extension of revalidation period for import of the said material. We have made an excess export of 285066 kg of Refined Copper Billets against the said authorization. Due to the unavailability of our input item Copper Scrap Druid in the market, we could not import the material within the time limit. Whereas we are required to import 683957 kgs of Copper Druid against excess export made. The License was issued on 16.07.2020 and import validity expired on 16.07.2021. Hence, we request to grant us 1 year extension of revalidation period for import of the said material.

(Action: Applicant)

Case No.14 M/s. AnuhPharma Limited, Mumbai

F.No.HQRPRCAPPLY00004502AM25

Subject:Request for extension of EOP against Advance Authorization No. 0310831862 dated 27.09.2019. ' Page 10 of 37 BK \

Applicant’s statement:This is with reference to the request mentioned above for relaxation of policy provision to extend the export obligation period of Advance Authorization No. 0310831862 DT. 27.09.2019. We have put in hard efforts to procure the export orders from our existing buyers, but because of corona pandemic the demand of export order was badly affected and we could not got the order. We had imported the raw material in the assumption of that we will export he material as it was regular shipment. Our marketing team visited personally to our customer in their country and in Pharma exhibition to get the export order. Condition telephonic call and emails were done to the customer. With lots of hardship & efforts. We finally got some orders from our customer and we are expecting more order from another customer in the coming month. Hence Policy Relaxation Committee is requested to kindly grant us EOP extension for 6 months in this license to fulfill export obligation. Decision: The Committee went through the statements made by the firm and noted that the applicant has not submitted any cogent reason/ justification in support of any genuine hardship faced by them. Accordingly, the Committee decided to reject the request.

(Action: Applicant)

Case No.15 M/s. Clean Science and Technology Limited, Pune

F.No.HQRPRCAPPLY00004508AM25

Subject: Request for amendment against Advance Authorization No. 3110067551 dated 04.10.2019.

Applicant’s statement: We had been issued Advance Authorization no.3110067551 dated.04.10.2019 under self-Ratification Scheme. Licenses issued as per para 4.07 A have to comply with pre-import condition. We were not able to comply/fulfill the preimport condition in the license because in the chemical industry it is quite difficult to comply the same. Hence, requesting to PRC to allow amend the License from Self Ratification to Self-Declared authorization as per para 4.07 of HBP. We have already fulfilled the Export obligation and if such amendment is accepted will enable us to regularize the license as pre-import condition will not be applicable to the License under self-declaration Scheme. We have very good track record of Export of Last 15 Years without any show cause Notice or Adjudication order We are 1) Four-star Export House (Copy Enclosed) 2) T2 AEO holder (copy Enclose) 3) ISO Certificate holder (copy Enclose) ISO 14001-2015, 45001-2018 &9001-2015 4) We are awarded for our export performance from the Maharashtra State Export Award for 2018-19, 2019-20, 2020-21, and 2021-22. Copies of the certificate are enclosed. Taking into consideration of above and the fulfillment of Export obligation in proportion to imports made amendment Please consider for us Self-declaration instead of Self-Ratification.

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Decision: The Committee went through the submission made by the applicant and discussed the matter at length. The Committee decided to accede to the request of the firm for considering the advance authorisationNo. 3110067551 dated 04.10.2019under the Para 4.07 of HBP instead of Para 4.07A HBP. No other relaxation was allowed. The firm shall approach RA concerned within 30 days from the date of uploading of the minutes of meeting.

(Action: Applicant/RA- Pune)

Case No.16 M/s. Clean Science and Technology Limited, Pune

F.No.HQRPRCAPPLY00004509AM25

Meeting No.13AM25 held on 07.08.2024

Subject:Request for amendment against Advance Authorization No. 3110067523 dated 04.09.2019, 3110067647 dated 02.01.2020, 3110067535 dated 19.09.2019.

Applicant’s statement:We had been issued Advance Authorization no.3110067535 dated.19.09.2019,3110067647 dated.02.01.2020 and 3110067523 dated.04.09.2019 under self-Ratification Scheme. Licenses issued as per para 4.07 A have to comply with pre-import condition. We were not able to comply/fulfill the pre-import condition in the license because in the chemical industry it is quite difficult to comply the same. Hence, requesting to PRC to allow amend the License from Self Ratification to Self-Declared authorization as per para 4.07 of HBP. We have already fulfilled the Export obligation and if such amendment is accepted will enable us to regularize the license as preimport condition will not be applicable to the License under self-declaration Scheme. We have very good track record of Export of Last 15 Years without any show cause Notice or Adjudication order We are 1) Four-star Export House (Copy Enclosed) 2) T2 AEO holder (copy Enclose) 3)ISO Certificate holder (copy Enclose) ISO 14001-2015 , 450012018 &9001-2015 4) We are awarded for our export performance from the Maharashtra State Export Award for 2018-19, 2019-20, 2020-21, and 2021-22. Copies of the certificate are enclosed. Taking into consideration of above and the fulfillment of Export obligation in proportion to imports made amendment Please consider for us Selfdeclaration instead of Self-Ratification.

Decision: The Committee went through the submission made by the applicant and discussed the matter at length. The Committee decided to accede to the request of the firm for considering the subject advance authorisation under the Para 4.07 of HBP instead of Para 4.07A HBP. No other relaxation was allowed.The firm shall approach RA concerned within 30 days from the date of uploading of the minutes of meeting. (Action: Applicant/RA- Pune)

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Case No. 17 M/s. Clean Science and Technology Limited, Pune

F.No.HQRPRCAPPLY000045071AM25

Meeting No.13AM25 held on 07.08.2024

Subject:Request for amendment against Advance Authorization No. 3110067606 dated 25.11.2019, 3110067618 dated 09.12.2019, 3110067636 dated 27.12.2019, 3110067493 dated 06.08.2019.

Applicant’s statement:We had been issued Advance Authorization no.3110067636 dated 27.12.2019,3110067618 dated.09.12.2019,3110067606 dated.25.11.2019, 3110067493 dated.06.08.2019 under self-Ratification Scheme. Licenses issued as per para 4.07 A have to comply with pre-import condition. We were not able to comply/fulfill the pre-import condition in the license because in the chemical industry it is quite difficult to comply the same. Hence, requesting to PRC to allow amend the License from Self Ratification to Self-Declared authorization as per para 4.07 of HBP. We have already fulfilled the Export obligation and if such amendment is accepted will enable us to regularize the license as pre-import condition will not be applicable to the License under self-declaration Scheme. We have very good track record of Export of Last 15 Years without any show cause Notice or Adjudication order We are 1) Four-star Export House (Copy Enclosed) 2) T2 AEO holder (copy Enclose) 3) ISO Certificate holder (copy Enclose) ISO 14001-2015, 45001-2018 &9001-2015 4) We are awarded for our export performance from the Maharashtra State Export Award for 2018-19, 2019-20, 2020-21, and 2021-22. Copies of the certificate are enclosed. Taking into consideration of above and the fulfillment of Export obligation in proportion to imports made amendment Please consider for us Self-declaration instead of Self-Ratification.

Decision: The Committee went through the submission made by the applicant and discussed the matter at length. The Committee decided to accede to the request of the firm for considering the subject advance authorisation under the Para 4.07 of HBP instead of Para 4.07A HBP. No other relaxation was allowed. The firm shall approach RA concerned within 30 days from the date of uploading of the minutes of meeting.

(Action: Applicant/RA- Pune)

Case No.18 M/s. Putzmeister Concrete Machines Private Limited, Goa

F.No.HQRPRCAPPLY00004515AM25

Subject:Request for RODTEP E-script.

Applicant’s statement:We M/s. Putzmeister Concrete Ltd having a factory at Verna, Goa Manufacturer and exporter of Concrete Pumps of different model of the developed and under develop countries. Against our exports, we are eligible for RODTEP under

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HS code 8434000 @ 1.00% of FOB value. We are regularly applying to RODTEP script against our exports and utilizing the same in payment of Custom Duty against our imports. But, we would like to inform you that for some shipping bills, we are unable to generate RODTEP script due to technical error in the Custom ICE gate site. We have therefore lodged complaint to rectify the error, so that we can get RODTEP script against our exports. Copy of the complaints are attached herewith for your reference. We also attaching herewith the statement showing the scroll number and date of RODTEP script not generated. We are therefore approaching your office to accept our request and to upload the shipping bills for the shipping bills shown in our export statement. We are making the exports, in spite of the stiff international competition and earning valuable Foreign Exchange and also creating employment We therefore request you to please allow us to claim the RODTEP benefit against our exports.

Decision: The Committee examined the case on the basis of submission made by the firm and discussed the matter at length. The Committee noted that it is not a PRC matter. The firm may approach Customs for resolution.

(Action: Applicant)

Case No.19

M/s. Spiceor Bionutralites Private Limited, Kerala

F.No.HQRPRCAPPLY00004514AM25

Subject: Request for export obligation extension against export against LOP.

Applicant’s statement:Spiceor Bionutralites Private Limited is an extraction facility established in the Biotechnology Incubation center, KINFRA Hi Tech Park, Kalamassery, Kerala, run by Rajiv Gandhi Center for Biotechnology, funded by DBT, Government of India After discussions with various Government agencies we were convinced that at that point in time the best option was to commence the Unit as an EOU and accordingly our firm, Spiceor Bionutralites Private Limited got registered as a EOU with the Development Commissioner, Cochin Special Economic Zone. The facility for duty free import of inputs required for our finished products and other facilities of EOU enchanted us in to the Scheme. After trial production, sample testing etc commercial production commenced in 2017 and as a safe measure, initially we had undertaken jobbing work from another EOU namely M/S Akayflavours , Cochin. Till 2020, this arrangement continued and thereafter we organized our own exports through a third party namely Spice Planters, Ernakulam. We have a very smooth sailing till recently and even now we have sufficient orders in hand. Unfortunately, during the year 2022-2023 our third party exporters M/s Spice Planters informed us that their clients cancelled their order for oils and oleoresins and accordingly the orders placed on us were cancelled for the time being. This was the first shock in our business career. Still we were able to manage with other small orders and now M/s Spice Planters have informed us that the clients are showing keen interest to restart their purchase activity and that in the next three to four months they will resume their earlier business in full

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Page 14 of 37

measure. The imported raw materials namely pepper were already processed by us to oil and oleoresins and we are holding this stock since 2022.It was our understanding that under the EOU Scheme the time frame to use the imported materials were co terminus with the LOP issued by the Development Commissioner and on that basis we thought we were safe to process the materials and keep as stock till the end of our LOP Period .It was abold from the blue when recently the EOU division of Cochin Customs informed us that we ought to have fulfilled the Export Obligation of oleoresin and oil processed out of the imported pepper with in the period of 120 days from the date of clearance of each consignment rom Customs. We had very badly overlooked the specific provision in the FTP and were led by the belief that we have the time till the end of LOP period. Admittedly it is a lapse from our side Under these circumstances, we are now approaching the Hon. Policy Relaxation Committee to kindly condone this lapse and extend the Export obligation for a further period of 6 months from the date of approval of condo nation. Sirs, we are confident to fulfill the obligation in full within the extended period as we are almost sure of bagging the orders in the next couple of months. We take this opportunity to humbly request the Hon. Committee to consider the matter sympathetically and take a lenient view on the two technocrats who commenced this venture with great pride and hope. It is true that an important aspect like Export obligation period was over looked but we would like to submit that it was not intentional nor with any malafide to defraud revenue. In fact we have attached along with thin fact we have attached along with this application copies of our quarterly return in form A which would reveal that the corresponding quantity of oleoresin and oil was always held as stock at the close of every quarter. A statement indicating the total stock available as on June 2024 is also attached for your kind perusal and satisfaction We once gain make our humble submission for bestowing on us a sympathetic and lenient view on the matter and be kind enough to extend the Export obligation for a further period of 6 months from the date of approval by the Committee.

Decision: The Committee went through the submission made by the firm and discussed the matter at length.After detailed discussion it was decided to seek comments from jurisdictional Development Commissioner.

(Action: Applicant/DC Cochin SEZ)

Case No.20 M/s. Scorodite Stainless India Private Limited, Mumbai

F.No.HQRPRCAPPLY00004521AM25

Meeting No.13AM25 held on 07.08.2024

Subject: Request for extension of EOP against Advance Authorization No. 0310742969 dated 26.07.2013, 0310765128 dated 08.01.2014, 0310789656 dated 25.09.2014, 0310751690 dated 30.09.2013, 0310744577 dated 08.08.2013, 0310740118 dated 03.07.2013, 0310715215 dated 20.11.2012, 0310723863 dated 13.02.2013.

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Applicant’s statement: With reference to the above subject matter, we have informed by web-site on 3RD April 2024 that our case has been rejected on 22nd March 2024 meeting no 33AM24 due to non-submission of cogent reason /justification in support of any genuine hardship. In this regards, we want to inform you that due to financial problem our company went to NCLT and NCLT approved our application on 16.07.2019. Immediately we went to Policy Relaxation Committee and Covid started all over world. And we got one year EO extension by Policy Relaxation Committee on 28/06/2021 vide file number 01/60/162/337/AM21/PRC. Due to Covid, our company financial go totally down and we could not recover. Again we approached to Policy relaxation committee on 28th December 2022. Our case comes in committee on ‘st March 2023 and committee advise for call the report from RA. Finally our case come on 22nd March 2024 and case is rejected without proper discussion. Now our company slowly recovering in financially and exporting the goods. For pending above said advance licenses, we have to invest huge amount on production and also due to Ukraine and Russia War, international Market is not stable on price. Investor are coming and they are investing the money in our company. But still we need another one year time. We have completed 60% export obligation within extended EO period and still exporting. Also we are writing to request an extension of the manufacturing timeline for the production of seamless pipes .we would like to bring to your attention the complexities involved in the manufacturing process, which require additional time to fulfill the client's requirements. Each size of seamless pipes & tubes undergoes 3-4 meticulous processes to meet the final size as per the client's specifications. Due to the intricate nature of these processes, the manufacturing timeline is significantly extended. As a result, we are only able to produce a maximum of 27-30 tons per month. Considering the total quantity required to be manufactured, it is evident that the job will necessitate a minimum of 9-11 months to complete of balance qty of export . Furthermore, due to the time-consuming nature of the manufacturing processes, we anticipate needing an additional 12 months to complete the balance quantity for export. In light of the aforementioned circumstances, we kindly request an extension of 12 months from the date of endorsement to complete the remaining manufacturing and export activities. This extension will enable us to meet the client's requirements while maintaining the high quality standards that our company is committed to delivering. Therefore, we humbly request your goodself to consider the submissions and grant us EO extension without composition fees for our above Advance Authorizations for one Year and without composition fees. Kindly consider our request Decision:The committee went through the statement made by the firm in its application and noted that the facts of the case have not been clearly specified by the firm and hence decided to call the firm for Personal Hearing. (Action: Applicant/PRC) Case No.21 M/s. Sanathan Textiles Limited, Mumbai , F.No.HQRPRCAPPLY00004519AM25 wh \

Page 16 of 37

Meeting No.13AM25 held on 07.08.2024

Subject: Request for revalidation of Authorization/Certificate against Advance Authorization No. 0311016374 dated 15.07.2022. Applicant’s statement:As per custom notification dated 03.06.2024, the Hon?ble high court of Gujarat has passed order on 02.05.2024 for collection of Anti-Dumping duty on Import of PTA as prescribed under notification no 28/2019-Cust (ADD) until 19.07.2024. Please find below Bill of Entry of PTA Import made between 02.05.2024 to 19.07.2024:BILL OF ENTRY NO - 3983546 DATED - 13.06.2024 , BILL OF ENTRY NO - 3983656 DATED - 13.06.202 & BILL OF ENTRY NO - 4163198 DATED - 24.06.2024 We request you to revalidate the Licence for 6 months, since Licence should be valid as there is a possibility that Customs can levy Anti-Dumping Duty on PTA. Kindly note we have completed Import and Export Obligation. Attached herewith High Court order, Licencecopy with Revalidation and EO Extension Letter, Export and Import Statement for your reference. Decision: The Committee went through the statements made by the firm and noted that the applicant has not submitted any cogent reason/ justification in support of any genuine hardship faced by them. Accordingly, the Committee decided to reject the request.

(Action: Applicant)

Case No.22 M/s. ARCL Organics Limited, Kolkata

F.No.HQRPRCAPPLY00004520AM25

Meeting No.13AM25 held on 07.08.2024

Subject:Request for revalidation of Authorization/Certificate against Advance Authorization No. 0210210206 dated 10.11.2020, 0211001126 dated 25.08.2021, 0211001130 dated 25.08.2021, 0211001543 dated 24.11.2021, 0211001817 dated 17.01.2022, 0211002400 dated 13.05.2022, 0211002616 dated 27.06.2022. Applicant’s statement:VVe could not complete the import on basis of Actual Exports within the initial import period and revalidated period allowed by Regional Authority. We have always prioritized completing our export obligations prior to importing, in line with our commitment to contribute positively to our nation's foreign reserves and trade balance. This approach, while beneficial for our national economy, often requires extended timeframes for our import operations. During the challenging period of the COVID-19 pandemic and its prolonged impact, we encountered significant disruptions. Our international supplier prioritized orders with higher prices over the lower price contracts already they had with us, leading to indefinite delays in our consignments. Additionally, unpredictable transit times have frequently disrupted our planned deliveries at Kolkata Port. In light of these challenges, we respectfully request a revalidation of the import period for an additional six months from the date of sanction. We also request an enhancement of the CIF Value on the eligible quantities, as we have maintained

Page 17 of 37

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significantly more than the 15% value addition required by the Foreign Trade Policy. This support will enable us to navigate the current market dynamics more effectively and continue contributing significantly to India's export growth and foreign exchange reserves. We understand the importance of adhering to the guidelines set by your esteemed office and appreciate your consideration of our request. In addition to that kindly allow us to appear for personal hearing before you to clarify/ explain our request in details. Thank you for your time and attention to this matter. We appreciate your consideration of our request and look forward to a positive response and are hopeful for a continued fruitful association with the DGFT.

(Action: Applicant)

Case No.23

M/s. ARCL Organics Limited, Kolkata

F.No.HQRPRCAPPLY00004530AM25

Subject:Request for revalidation of Authorization/Certificate against Advance Authorization No. 0210209411 dated 02.09.2019.

Applicant’s statement:We are hereby applying for the review for PRC Revalidation of Import Period. We request for personal hearing. Reference to the above, we would like to draw your kind attention to the fact that Revalidation was granted by regional office of Add| DGFT against all the above noted Advance Authorisations, but we could not complete the import on basis of Actual Exports within this revalidated period allowed by Regional Office. We have always prioritized completing our export obligations prior to importing, in line with our commitment to contribute positively to our nation's foreign reserves and trade balance. This approach, while beneficial for our national economy, often requires extended timeframes for our import operations. During the challenging period of the COVID-19 pandemic and its prolonged impact, we encountered significant disruptions. Our international supplier prioritized orders with higher prices over the lower price contracts already they had with us, leading to indefinite delays in our consignments. Additionally, unpredictable transit times have frequently disrupted our planned deliveries at Kolkata Port. In light of these challenges, we respectfully request a revalidation of the import period for an additional six months from the date of sanction. We also request an enhancement of the CIF Value on the eligible quantities, as we have maintained significantly more than the 15% value addition required by the Foreign Trade Policy. This support will enable us to navigate the current market dynamics more effectively and continue contributing significantly to India's export growth and foreign exchange reserves. We understand the importance of adhering to the guidelines set by your esteemed office and appreciate your consideration of our request. In addition to Page 18 of 37 wK\

that if required kind allow us to appear personal hearing before you to clarify/ explain our request in details. Thank you for your time and attention to this matter. We appreciate your consideration of our request and look forward to a positive response and are hopeful for a continued fruitful association with the DGFT. Thanking you in anticipation of your kind support.

(Action: Applicant)

Case No.24 M/s. ARCL Organics Limited, Kolkata

F.No.HQRPRCAPPLY00004528AM25

Subject: Request for revalidation of Authorization/Certificate against Advance Authorization No. 0211002331 dated 29.04.2022.

Applicant’s statement: We would like to draw your kind attention to the fact that we could not complete the import on basis of Actual Exports within the initial import period and revalidated period allowed by Regional Authority. We have always prioritized completing our export obligations prior to importing, in line with our commitment to contribute positively to our nation's foreign reserves and trade balance. This approach, while beneficial for our national economy, often requires extended timeframes for our import operations. During the challenging period of the COVID-19 pandemic and its prolonged impact, we encountered significant disruptions. Our international supplier prioritized orders with higher prices over the lower price contracts already they had with us, leading to indefinite delays in our consignments. Additionally, unpredictable transit times have frequently disrupted our planned deliveries at Kolkata Port. In light of these challenges, we respectfully request a revalidation of the import period for an additional six months from the date of sanction. We also request an enhancement of the CIF Value on the eligible quantities, as we have maintained significantly more than the 15% value addition required by the Foreign Trade Policy. This support will enable us to navigate the current market dynamics more effectively and continue contributing significantly to India's export growth and foreign exchange reserves. We understand the importance of adhering to the guidelines set by your esteemed office and appreciate your consideration of our request. In addition to that kindly allow us to appear for personal hearing before you to clarify/ explain our request in details. Decision: The Committee went through the statements made by the firm and noted that the applicant has not submitted any cogent reason/ justification in support of any

Page 19 of 37

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genuine hardship faced by them. Accordingly, the Committee decided to reject the request.

(Action: Applicant)

Case No.25 M/s. ARCL Organics Limited, Kolkata

F.No.HQRPRCAPPLY0004532AM25

Subject:Request for revalidation of Authorization/Certificate against Advance Authorization No. 0210209712 dated 24.01.2020.

Applicant’s statement:We are hereby applying for the review for PRC Revalidation of Import Period. We request for personal hearing. Reference to the above, we would like to draw your kind attention to the fact that Revalidation was granted by regional office of Addl DGFT against all the above noted Advance Authorisations, but we could not complete the import on basis of Actual Exports within this revalidated period allowed by Regional Office. We have always prioritized completing our export obligations prior to importing, in line with our commitment to contribute positively to our nation's foreign reserves and trade balance. This approach, while beneficial for our national economy, often requires extended timeframes for our import operations. During the challenging period of the COVID-19 pandemic and its prolonged impact, we encountered significant disruptions. Our international supplier prioritized orders with higher prices over the lower price contracts already they had with us, leading to indefinite delays in our consignments. Additionally, unpredictable transit times have frequently disrupted our planned deliveries at Kolkata Port. In light of these challenges, we respectfully request a revalidation of the import period for an additional six months from the date of sanction. We also request an enhancement of the CIF Value on the eligible quantities, as we have maintained significantly more than the 15% value addition required by the Foreign Trade Policy. This support will enable us to navigate the current market dynamics more effectively and continue contributing significantly to India's export growth and foreign exchange reserves. We understand the importance of adhering to the guidelines set by your esteemed office and appreciate your consideration of our request. In addition to that if required kind allow us to appear personal hearing before you to clarify/ explain our request in details.

(Action: Applicant)

Case No.26 M/s. ARCL Organics Limited, Kolkata

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Page 20 of 37

F.No.HQRPRCAPPLY00004531AM25

Meeting No.13AM25 held on 07.08.2024

Subject: Request for revalidation of Authorization/Certificate against Advance Authorization No. 0210209415 dated 03.09.2019.

Applicant’s statement: We would like to draw your kind attention to the fact that File No: HQRPRCAPPLY00182505AM22 dated 15.09.2021 applied to PRC for Revalidation in the past was issued a deficiency letter which was missed by us to respond on time. The deficiency letter asked whether any revalidation was taken from RA. Now, since that deficiency file is not showing in submitted applications due to long delay in responding, we are hereby applying afresh the Request for Revalidation. Revalidation for 6 Months was granted by regional office of Addl DGFT against the captioned Advance Authorization, but we could not complete the import on basis of Actual Exports within this revalidated period allowed by Regional Office. We have always prioritized completing our export obligations prior to importing, in line with our commitment to contribute positively to our nation's foreign reserves and trade balance. This approach, while beneficial for our national economy, often requires extended timeframes for our import operations. During the challenging period of the COVID-19 pandemic and its prolonged impact, we encountered significant disruptions. Our supplier prioritized orders with higher prices over the lower price contracts already they had with us, leading to indefinite delays in our consignments. These situations compelled us to source melamine from the domestic market at substantially higher costs, escalating from Rs 55 /kgs to even Rs 280/-kgs. This unforeseen expense not only strained our financials but also impacted our planned export commitments. Furthermore, the removal of the $331 per MT anti-dumping duty on our imports has greatly affected our cost structure. Previously, this duty provided a competitive edge over local suppliers, but its elimination has reduced our sales price advantage to a mere 5%-6% (Import Duty). The higher purchase prices from the local market during this period resulted in reduced profitability for our company, thereby impacting our contributions to the nation's revenue through lower tax payments. Additionally, unpredictable transit times have frequently disrupted our planned deliveries at Kolkata Port. In light of these challenges, we respectfully request a revalidation of the import period for an additional six months from the date of sanction. We also request an enhancement of the CIF Value on the eligible quantities, as we have maintained significantly more than the 15% value addition required by the Foreign Trade Policy. This support will enable us to navigate the current market dynamics more effectively and continue contributing significantly to India's export growth and foreign exchange reserves. We understand the importance of adhering to the guidelines set by your esteemed office and appreciate your consideration of our request. We are willing to provide any additional information or discuss this matter further, should it be required. We request for personal Hearing.

(Action: Applicant)

Case No.27

M/s. ARCL Organics Limited, Kolkata

F.No.HQRPRCAPPLY00004535AM25

Subject:Request for revalidation of Authorization/Certificate against Advance Authorization No. 0210209879 dated 19.05.2020, 0210209965 dated 08.07.2020, 0210210062 dated 28.08.2020, 0210210108 dated 16.09.2020, 0210210205 dated 10.11.2020, 0210210212 dated 11.11.2020. Applicant’s statement: We would like to draw your kind attention to the fact that Revalidation was granted by regional office of Addl DGFT against all the above noted Advance Authorisations, but we could not complete the import on basis of Actual Exports within this revalidated period allowed by Regional Office. We have always prioritized completing our export obligations prior to importing, in line with our commitment to contribute positively to our nation's foreign reserves and trade balance. This approach, while beneficial for our national economy, often requires extended timeframes for our import operations. During the challenging period of the COVID-19 pandemic and its prolonged impact, we encountered significant disruptions. Our international supplier prioritized orders with higher prices over the lower price contracts already they had with us, leading to indefinite delays in our consignments. Additionally, unpredictable transit times have frequently disrupted our planned deliveries at Kolkata Port. In light of these challenges, we respectfully request a revalidation of the import period for an additional six months from the date of sanction. We also request an enhancement of the CIF Value on the eligible quantities, as we have maintained significantly more than the 15% value addition required by the Foreign Trade Policy. This support will enable us to navigate the current market dynamics more effectively and continue contributing significantly to India's export growth and foreign exchange reserves. We understand the importance of adhering to the guidelines set by your esteemed office and appreciate your consideration of our request. In addition to that if required kind allow us to appear personal hearing before you to clarify/ explain our request in details.

(Action: Applicant)

Case No.28 M/s. Hartex Rubber Private Limited, Hyderabad Page 22 of 37

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F.No.HQRPRCAPPLY00004536AM25

Meeting No.13AM25 held on 07.08.2024

Subject: Request for extension of EOP against Advance Authorization No. 0911002341 dated 19.01.2022.

Applicant’s statement:We could complete 63% of the Export obligation within the extended period. However, due to sluggish market conditions in Europe, USA, South American Markets balance obligation could not be completed. Now with lot of marketing efforts we could get orders for fulfilling the balance obligations and are confident of completing the balance obligation if EOP is extended. Requested to extend the obligation period by another 6 months from the date of expiry of second extended obligation period.

Decision: The Committee went through the justification made by the applicant and discussed the matter at length. After detailed discussion it was decided to accede to the request of the firm and allowed EOP extension of Advance Authorization No. 0911002341 dated 19.01.2022for a further period of 6 months from the date of endorsement subject to payment of composition fee as per policy provisions. The firm shall approach RA concerned within 30 days from the date of uploading of the minutes of meeting.

(Action: Applicant)

Case No.29 Mis. Jaytick Intermediates Pvt. Ltd, Baroda

F.No.01/60/162/200AM-19/PRC

Meeting No.13AM25 held on 07.08.2024

Subject: Request for review of case for EOP extension of Advance Authorization No. 0310057245 dated 16.10.2000 upto 31.12.2003.

This is a review case of PRC Meeting No.14AM19 (Case No.21) held on 04.09.2018 wherein Committee reject the case.

Applicant’s statement:We do not get to hear anything either from PRC Section of DGFT or from RLA, Mumbai despite making our regular submissions almost numbering to 12 all copies enclosed, for extension of EO period based on our completion of export exclusively for redemption purpose vide our letter dated 3.2.2023. We do not get to understand the rationale behind not allowing the approval of our request of extension of EOP when the export stands effected long back.

The firm was requested to furnish the proforma i.e. ANF 2E for review of case vide this Directorate letter dated 8.5.2020. It was seen that firm did not send reply communication on proper address. Page 23 of 37 x 3

Decision: The Committee went through the justification made by the applicant and discussed the matter at length. After detailed discussion it was decided to accede to the request of the firm and allowed EOP extension of Advance Authorization No.0310057245 dated 16.10.2000 upto 31.12.2003 subject to payment of composition fee as per policy provisions. No other relaxation was allowed. The firm shall approach RA concerned within 30 days from the date of uploading of the minutes of meeting.

(Action: Applicant/RA-Mumbai)

Case No.30 M/s. Highpoint Tradelink Private Limited, Kolkata

F.No.HQRPRCAPPLY00004556AM25

Subject: Request for revalidation of Authorization/Certificate against Advance Authorization No. 0210207966 dated 09.11.2017. Applicant’s statement:We would like to draw your kind attention to the fact that we could not complete the import on basis of Actual Exports within the initial import period. We have always prioritized completing our export obligations prior to importing, in line with our commitment to contribute positively to our nation's foreign reserves and trade balance. This approach, while beneficial for our national economy, often requires extended timeframes for our import operations. We are very thankful to Norms Committee -7 DGFT that it reviewed and enhanced the Input Output Norms for our subject Advance Authorizations in the Meeting No 06/AM 20, held on 17th July 2019. , Case NO A 53. Since Input Output Norms were revised/enhanced after the period of two years from the issue of Advance Authorization, we could not have approached DGFT RA KOLKATA for Enhancement in Bond Waiver and extension in time for completing the imports. After enhancement of Norms, shortly due to COVID-19 pandemic everything was impacted and in its prolonged impact, we encountered significant disruptions. Our international supplier prioritized orders with higher prices over the lower price contracts, leading to indefinite delays in our consignments. Sir, now in order to honor this enhancement in norms, we need to complete the imports based on this enhanced input output norms, so we need the bond waiver of the Revised Input quantity and Enhancement in CIF Value to be allowed to us as per the enhanced norms to maintain the minimum value addition of 15% and extension of time for completing the eligible imports. Exports and global chemical market slowed down from Year 2020 beginning due to COVID -19 and gradually its impact got very severe which led to scarce supply of Raw Material/Input and the unaffordable high Import prices. Logistics Issues erupted due to various international developments which had impacted the business since last around Four years and presently too the situation is very tough. Somehow now we are expecting some input supply from overseas. We believe that we can now complete the balance imports and thus we request you to kindly allow us sufficient time of at least Six months from the date of your approval as the logistics situation is still tight on account of vessel space availability and transit time assurance. The input prices had also gone up steeply. This support will enable us to navigate the Page 24 of 37 ok

current market dynamics more effectively and continue contributing significantly to India's export growth and foreign exchange reserves. We understand the importance of adhering to the guidelines set by your esteemed office and appreciate your consideration of our request. In addition to that kindly allow us to appear for personal hearing before you to clarify/ explain our request in details. Decision: The Committee went through the statements made by the firm and noted that the applicant has not submitted any cogent reason/ justification in support of any genuine hardship faced by them. Accordingly, the Committee decided to reject the request.

(Action: Applicant)

Case No.31 M/s. Highpoint Tradelink Private Limited, Kolkata

F.No.HQRPRCAPPLY00004546AM25

Subject: Request for revalidation of Authorization/Certificate against Advance Authorization No. 0210206974 dated 08.09.2016.

Applicant’s statement: We would like to draw your kind attention to the fact that we could not complete the import on basis of Actual Exports within the initial import period. We have always prioritized completing our export obligations prior to importing, in line with our commitment to contribute positively to our nation's foreign reserves and trade balance. This approach, while beneficial for our national economy, often requires extended timeframes for our import operations. We are very thankful to Norms Committee -7 DGFT that it reviewed and enhanced the Input Output Norms for our subject Advance Authorizations in the Meeting No 06/AM 20, held on 17th July 2019. , Case NO A 53. Since Input Output Norms were revised/enhanced after the period of two years from the issue of Advance Authorization, we could not have approached DGFT RA KOLKATA for Enhancement in Bond Waiver and extension in time for completing the imports. After enhancement of Norms, shortly due to COVID-19 pandemic everything was impacted and in its prolonged impact, we encountered significant disruptions. Our international supplier prioritized orders with higher prices over the lower price contracts, leading to indefinite delays in our consignments. Sir, now in order to honor this enhancement in norms, we need to complete the imports based on this enhanced input output norms, so we need the bond waiver of the Revised Input quantity and Enhancement in CIF Value to be allowed to us as per the enhanced norms to maintain the minimum value addition of 15% and extension of time for completing the eligible imports. Exports and global chemical market slowed down from Year 2020 beginning due to COVID -19 and gradually its impact got very severe which led to scarce supply of Raw Material/Input and the unaffordable high Import prices. Logistics Issues erupted due to various international developments which had impacted the

Page 25 of 37

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business since last around Four years and presently too the situation is very tough. Somehow now we are expecting some input supply from overseas. We believe that we can now complete the balance imports and thus we request you to kindly allow us sufficient time of at least Six months from the date of your approval as the logistics situation is still tight on account of vessel space availability and transit time assurance. The input prices had also gone up steeply. This support will enable us to navigate the current market dynamics more effectively and continue contributing significantly to India's export growth and foreign exchange reserves. We understand the importance of adhering to the guidelines set by your esteemed office and appreciate your consideration of our request. In addition to that kindly allow us to appear for personal hearing before you to clarify/ explain our request in details. Decision: The Committee went through the statements made by the firm and noted that the applicant has not submitted any cogent reason/ justification in support of any genuine hardship faced by them. Accordingly, the Committee decided to reject the request.

(Action: Applicant)

Case No.32

M/s. Highpoint Tradelink Private Limited, Kolkata

F.No.HQRPRCAPPLY00004547AM25

Subject: Request for revalidation of Authorization/Certificate against Advance Authorization No. 0210207705 dated 22.06.2017, Advance Authorization No. 0210207758 dated 21.07.2017.

Applicant’s statement:We would like to draw your kind attention to the fact that we could not complete the import on basis of Actual Exports within the initial import period. We have always prioritized completing our export obligations prior to importing, in line with our commitment to contribute positively to our nation's foreign reserves and trade balance. This approach, while beneficial for our national economy, often requires extended timeframes for our import operations. We are very thankful to Norms Committee -7 DGFT that it reviewed and enhanced the Input Output Norms for our subject Advance Authorizations in the Meeting No 06/AM 20, held on 17th July 2019. , Case NO A 53. Since Input Output Norms were revised/enhanced after the period of two years from the issue of Advance Authorization, we could not have approached DGFT RA KOLKATA for Enhancement in Bond Waiver and extension in time for completing the imports. After enhancement of Norms, shortly due to COVID-19 pandemic everything was impacted and in its prolonged impact, we encountered significant disruptions. Our international supplier prioritized orders with higher prices over the lower price contracts, leading to indefinite delays in our consignments. Sir, now in order to honor this enhancement in norms, we need to complete the imports based on this enhanced input output norms, so we need the bond waiver of the Revised Input Page 26 of 37 ot

quantity and Enhancement in CIF Value to be allowed to us as per the enhanced norms to maintain the minimum value addition of 15% and extension of time for completing the eligible imports. Exports and global chemical market slowed down from Year 2020 beginning due to COVID -19 and gradually its impact got very severe which led to scarce supply of Raw Material/Input and the unaffordable high Import prices. Logistics Issues erupted due to various international developments which had impacted the business since last around Four years and presently too the situation is very tough. Somehow now we are expecting some input supply from overseas. We believe that we can now complete the balance imports and thus we request you to kindly allow us sufficient time of at least Six months from the date of your approval as the logistics situation is still tight on account of vessel space availability and transit time assurance. The input prices had also gone up steeply. This support will enable us to navigate the current market dynamics more effectively and continue contributing significantly to India's export growth and foreign exchange reserves. We understand the importance of adhering to the guidelines set by your esteemed office and appreciate your consideration of our request. In addition to that kindly allow us to appear for personal hearing before you to clarify/ explain our request in details.

(Action: Applicant)

Case No.33 M/s. Hindustan Adhesives Limited, Delhi

F.No.HQRPRCAPPLY00004539AM25

Meeting No.13AM25 held on 07.08.2024

Subject: Request for grant of relaxation in terms of Para 2.59 of FTP-2023, in export obligation period (EOP) for fulfillment of export obligation against the access import done as per the Ad-hoc norms fixed by the norms committee under the Authorization no. 0510413100 Dated 26.12.2019 against Advance Authorization No. 0510413100 dated 26.12.2019.

Applicant’s statement : We refer to NC Minutes of Meeting No 3/22-23 dated 31.05.2022 in which the Norms Committee has approved the norms with a wastage of 10% instead of 15.6% as applied in the subject authorization with a deduction of 5.6%. We give below a chart wherein you will find the differences of applied norms and norms fixed by NC Committee in each import items AND ALSO STATING THAT DUE TO LESS WASTAGES GIVEN IN THE IMPORT ITMES A HUGE QUANTITIES OF OBLIGATION IMPOSED ON THE COMPANY. As the period was full of drastic situations due to covid-19 from 2020 to 2023 the process of fixation of norms and committee meeting was irregular and time taking the import of inputs and export of

Page 27 of 37

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product also done before the committee decision and we has no option to manage the import according the nc decision that time. We have also approached the norms committee for review or re-fixation the norms against the subject authorization in September 2022 to April 2023 but they have rejected the case. We would like to inform you that due to this less fixation of Ad Hoc Norms by Norms Committee in the subject authorization against each and every import items, we are liable to pay the customs duty plus interest which is a very huge amount and company is not in a position to bear such type of any burden as company already facing the problems due to COVID-19. Further we have to convey you that we have submit the duty + Interest against the excess import done of input serial no 3 by reassessment of one bill of entry no. and requesting you to please allow us the enhancement of total export obligation of the authorization by 110000 Kg to balance the excess import done by us of input serial no. 1 & 2 to regularization of duty tinterest as it is a very huge amount and company is not in a position to bear such type of any burden as company already facing the problems due to COVID-19. Decision: The Committee went through the justification made by the applicant and discussed the matter at length. After detailed discussion it was decided to accede to the request and allowed EOP extension of Advance Authorization No. 0510413100 dated 26.12.2019 for a further period of 6 months from the date of endorsement subject to payment of composition fee as per policy provisions, to make exports to balance the excess import done by them in terms of lower Norms fixed by the NC in Meeting No 3/2223 dated 31.05.2022.The firm shall approach RA concerned within 30 days from the date of uploading of the minutes of meeting.

(Action: Applicant/RA-CLA, New Delhi)

Case No.34 M/s. Medreich Limited, Bengaluru

F.No.HQRPRCAPPLY00004537AM25

Meeting No.13AM25 held on 07.08.2024

Subject: Request for extension of EOP against Advance Authorization No. 0711000923 dated 21.04.2021.

Applicant’s statement: We have applied and obtained AA No.0711000923/21.04.2021 towards the import of Prochlorperazine Maleate and the export of Prochlorperazine Maleate 5mg and 3mg Tablets. Due to the Covid-19 Period, the import and the relevant exports delayed by 6 months. Our 1st import was made on 08.06.2021 and the ‘st export was on 25.09.2021. Due the delays and changes during that period, we have completed our EO on 09.07.2023. 69% of the export obligation has been completed within validity of 12 months from the date of 1st import. 17% of the EO completed between 12-18months period from 1st import. Remaining 14% of EO has been completed beyond 18 months. Hence, We hereby request you to consider the extension of EO period upto 09.07.2023.

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Decision: The Committee went through the justification made by the applicant and discussed the matter at length. After detailed discussion it was decided to accede to the request and allowed EOP extension of Advance Authorization No. 0711000923 dated 21.04.2021 for a further period of 6 months from the date of endorsement subject to payment of composition fee as per policy provisions. The firm shall approach RA concerned within 30 days from the date of uploading of the minutes of meeting.

(Action: Applicant/RA-CLA, New Delhi)

Case No.35 M/s. Shineshilpi Jewellers Private Limited, Mumbai

F.No.HQRPRCAPPLY00004540AM25

Subject: Request for condonation of procedure lapse of 3 day delay for fulfillment of Export Obligation against TRQ licence Authorization No. 0111016283 dated 03.05.2024.

This is a review case of PRC Meeting No.09AM25 (Case No.25) held on 26.06.2024 wherein Committee decided to accede to the request and allow condonation of delay of 3 days beyond days permissible period.

Applicant’s statement: In this review application firm has stated as under :-

Thank you very much PRC Committee for considering our condonation request but sir we request your good offices please consider our three (3) exports and shipping bill as details given below :-

We have procured 11000 gms of gold under loan purchase scheme in advance (HBP Para 4.82) from Nominated agency/Bank i.e. Kotak Mahindra Bank Ltd. Vide their Invoice No.|IX23GKGMUM184Bdate drawn on 29.01.2024 and expire on 27.04.2024 IX23GKGMUM190A date drawn on 31.01.2024 and expire on 29.04.2024 IX23GKGMUM190C date drawn on 31.10.2024 and expire on 29.04.2024 for a gold jewellery export order to our overseas buyer. We accept the export orders on the basis of market reference and ship the goods against receipt of payment in 7 days. We manufacturing customized jewellery product was ready but in selection they took two more days after their conformation we (ship) export the jewellery. Post export we have realized that our due date to export gold availed from nominated agency was April 27the 2024 as such there is a delay of 3 days. We are export business and working closely with our bankers also to work out credit options to promote more exports smoothly.

Hence we are requesting to PRC for correction in minutes for condonation of 3 days delay beyond 90 days permissible period for export of gold jewellery from the date of procurement of gold from nominated agency, for the 3 invoices.

Page 29 of 37

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Decision: The Committee went through the statement made by the applicant and discussed the matter at length. After detailed discussion it was decided to accede to the request and allow condonation of delay of 3 daysbeyond 90 days permissible period for export of gold jewellery from the date of procurement of gold from Nominated Agency vide Invoice No. IX23GKGMUM184B dated 29.01.2024, IX23GKGMUM190A dt. 31.01.2024 and IX23GKGMUM190C dt. 31.01.2024 and & Shipping Bill No.9490813 dated 29.04.2024.

(Action: Applicant/ Customs-Mumbai/ Concerned Nominated Agency / GJEPC)

Case No.36

M/s. Varroc Engineering Limited, Maharashtra

F.No.HQRPRCAPPLY00004548AM25

Subject: Request for revalidation of Scrip against various MEIS Scrips.

Applicant’s statement: We, Varroc Engineering Limited, [previously known as Varroc Engineering Pvt. Ltd. IEC Number 0390019402] are registered Manufacturer Exporters and manufacture and supply our products to various clients in India and abroad. During our business, we have imported various Liquid Crystal Displays required to manufacture the finished products. 1. We had imported these under 90 Bills of Entries on payment of full duties to the Customs. 2. These duties were paid by debiting the Duty Credit Scrips granted to us against our exports in addition to making the payment in Cash terms. 3. The application for the grant of the refund against these imports were initially rejected by the Customs. 4. We filed the Appeal against the same to the Office of the Commissioner of Customs (Appeals) and the Order in Appeal setting aside the previous order was passed. 5. Customs has issued the Order-in-Original No. 26/20-21/AM(1)/NSIll dated 31.03.2021 and has granted for the scripts to be re-credited in the said MEIS scrip. [copies of the Customs orders are enclosed] 6. Being aggrieved with the said Appeal, we filed an Appeal against the said Order and we have been issued the Orderin-Appeal No. 708(CRC-1)/2024(JNCH)/Appeals dated 09.05.2024 wherein the grant of Refund of an amount of Rs. 143,84,854/- by way of re-credit to the respective Scrips was upheld. To sum up, the Customs has issued the Orders, which involve a total of 42 Duty Credit Scrips for 90 Bills of Entries in which the duties paid upon debit to the Duty Credit Scrips needs to be re-credited. However, the original validity of these scrips has already expired and thus the RLA is unable to make the needful re-credit. We are, therefore, making this application for the grant of the re-credit of the duty credit scrips. A chart providing details of the Order-in-Appeal along-with the respective Bill of Entries against which these Duty Credits are utilized enclosed in the attachment. Page 30 of 37 cad

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Decision: The Committee discussed the case on the basis of justification provided by the applicant and concluded that genuine hardship is there in this case and therefore decided to accede to the request of the firm and allowedrevalidation for a period of six months from the date of endorsement and re-credit of duty credit, provided the scrips are held by original exporter to whom the same were issued . It was also decided to refer to PC-3 for resolution. The firm shall approach PC-3 within 30 days from the date of uploading of the minutes of meeting.

(Action: Applicant/PC-3/RA)

Case No.37 M/s. Yazaki India Private Limited, Pune

F.No.HQRPRCAPPLY0000697AM25

Meeting No.13AM25 held on 07.08.2024

Subject: Request for rejection of SEIS application on the ground that our unit is registered as STPI unit against SEIS Scrip No. 07/21/098/50021/AM21. Applicant’s statement: We Yazaki India Private Limited having registered office at GATE N0.93 SURVEY NO-166 HIGH CLIF INDL.ESTATE, WAGHOLI-RAHU ROAD, KESNAND, PUNE, MAHARASHTRA PIN 412207 (Regd. Office), submitted SEIS application to Office of Jt. Director General of foreign Trade, Bangalore on 15.06.2020 under File No.07/21/098/50021/AM21 and Key number 70111508, for grant of License under SEIS Scrip Value of Rs. 66,53,086.48/-, for export of services amounting to Rs. 13,30,61,746.59/- (US$ 19,46,770.25) in respect of our Bangalore unit Located at Quadrant.3 at Umiya Business Bay Tower II 5th Floor, Cessna Business Park, Marathahalli - Sarjapura Outer Ring Road, Bangaluru -560037 Bangaluru-562105, Karnataka. It has been informed vide a Letter / Order dated 23.07.2020 under file reference No. 07/21/098/50021/AM21 issued by the Assistant Director General of Foreign Trade, that our claim has been rejected on the ground that the said Unit is registered under STPI scheme and as such we are not eligible/entitled to avail benefit of SEIS. The said letter also suggests to file an Appeal against the rejected letter in case we are aggrieved by the said communication, and accordingly we filed the detailed explanation and justification letter for re-consideration of application on 30.07.2020 to Bangalore RA. There is no response till date. It may please be noted that although we have been granted registration under STPI scheme, the said registration is as "NonSTPI" unit category. We are not availing/ entitled to any of benefits arising out of STPI scheme and accordingly not availed any benefits under the said scheme. It may please further be noted that the said registration as "non-STP Unit" has been obtained in compliance with RBI Circular mandating us to file SOFTEX form. For filing of SOFTEX form with STPI authorities, a registration is mandatory under the category of "Non-STPI" unit, which accordingly has been obtained by us. In view of the facts stated above and also that no benefit under STPI scheme has been obtained / entitled to us, the impugned order may kindly be set aside and our claim to obtain SEIS script be allowed. We are enclosing following documents for your perusal and kind consideration: 1. Copy

Page 31 of 37

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of rejection letter; 2. Copy of registration certificate mentioning our Units registered as "NON STPI Unit" 3. Copy of application submitted with STPI for registration of our unit as "NON STPI Unit" 4. Previous request letter dated 30.07.2020 to DGFT RA Bangalore against rejection letter along with acknowledgement copy 5. FAQ issued by STPI confirming the need of non-STPI registration against the RBI Master circular. Please refer SI. No 2 of FAQ 6. Corresponding RBI Circular No 80 dated 15.02.2012 on nonSTPI registration. 7. Extract of RBI Master Direction export of goods and services Para B.35 In view of the above it is Prayed that: Under the Circumstances, the Appellants pray that Hon'bleAdd!. DGFT may be pleased to set aside the impugned Rejection letter and direct to process our claim; Our application to grant SEIS script may please be allowed; Any other just and fair order in the interest of justice be passed; The Appellants also pray that the Appellants may kindly be granted personal hearing before the final decision/ direction.

Comments of RA was also seen.

(Action: Applicant)

Case No.38 M/s. Sun Pharmaceutical Industries Limited, Mumbai

F.No.HQRPRCAPPLYOO00886AM25

Meeting No.13AM25 held on 07.08.2024

Subject: Request for Extension of EOP against Advance Authorization No. 0511016144 dated 02.12.2022. Applicant’s statement:Please note that due to slow demand of the resultant product in foreign market we were unable to fulfill export obligation within the initial and extended EO period. We have confirmed export order of export resultant product in hand for shipment to be made in coming months. Hence, consider our case for 2nd EOP extension up to 19.12.2024 towards fulfillment of Export obligation. In this regard, we request you to kindly allow EOP extension up to 19.12.2024 enabling us to fulfill export obligation within the 2nd EOP extension.

Je

Page 32 of 37

payment of composition fee as per policy provisions. The firm shall approach RA concerned within 30 days from the date of uploading of the minutes of meeting.

(Action: Applicant/RA-CLA, New Delhi)

Case No.39 M/s. HPL Additives Limited, Faridabad

F.No.HQRPRCAPPLY00009214AM24

Subject: Request for re Export Shipping Bill counted for EO Fulfillment against Advance Authorization No. 0510401502 dated 03.02.2017.

Applicant’s statement:Dear sir, would like to inform you that the buyer has rejected total qty 6920 kg quantity of materials and we had imported back the rejected material as per below statement date under re export bond as per para 2.50 of FTP HBP. Thereafter exported the same quantity under the white shipping bill as per custom notification No. 158/95-Cus dated 14.11.1995. So, we request you kindly allow the Free shipping bill counted for EO Fulfillment.

(Action: Applicant)

Case No.40 M/s. ITCO Industries Limited, Bengaluru

F.No.HQRPRCAPPLY00009234AM24

Subject: Request for acceptance for delay in submission of DFIA transferability application against DFIA Authorization No. 072107600010AM18 dated 11.02.2016. Applicant’s statement: After completing our exports, we were initially under mistaken impression that DFIA transferability can be applied only online. Hence, we waited long for the online systems and missed out on manual filing of the same. 2 Subsequently, we have been trying to submit manually since covid time in 2020 but it was not possible to do so. Later, we were informed at JOGFT Bangalore office that manual filing shall not be accepted, and we need to follow mandatorily online filing. 3 Unfortunately, due to some technical error in your software since the end of 2021, it was not possible to upload our application and documents. Finally, when this technical error was resolved and a new software was launched by you, we could file our transferability application

Page 33 of 37

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online at JOGFT Bangalore office on 23.11.2022 (vide file ref.No. O7ASO7600037AM23 Dated 23.11.2022

(Action: Applicant)

Case No.41 M/s. ITCO Industries Limited, Bengaluru

F.No.HQRPRCAPPLY00009235AM24

Meeting No.13AM25 held on 07.08.2024

Subject: Request for acceptance for delay in submission of DFIA transferability application against DFIA Authorization No. 07210760076AM16 dated 11.02.2016.

Applicant’s statement: After completing our exports, we were initially under mistaken impression that DFIA transferability can be applied only online. Hence, we waited long for the online systems and missed out on manual filing of the same. 2 Subsequently, we have been trying to submit manually since covid time in 2020 but it was not possible to do so. Later, we were informed at JOGFT Bangalore office that manual filing shall not be accepted, and we need to follow mandatorily online filing. 3 Unfortunately, due to some technical error in your software since the end of 2021, it was not possible to upload our application and documents. Finally, when this technical error was resolved and a new software was launched by you, we could file our transferability application online at JDGFT Bangalore office on 27.10.2022 (vide file ref.No. O7ASO7600033AM23 Dated 27.10.2022.

(Action: Applicant)

Case No.42 M/s. ITCO Industries Limited, Bengaluru

F.No.HQRPRCAPPLY00009237AM24

Meeting No.13AM25 held on 07.08.2024

Subject: Request for acceptance for delay in submission of DFIA transferability application against DFIA Authorization No. 072107600065AM16 dated 16.12.2015. , Page 34 of 37 ook \

Applicant’s statement: After completing our exports, we were initially under mistaken impression that DFIA transferability can be applied only online. Hence, we waited long for the online systems and missed out on manual filing of the same. 2. Subsequently, we have been trying to submit manually since covid time in 2020 but it was not possible to do so. Later, we were informed at JOGFT Bangalore office that manual filing shall not be accepted, and we need to follow mandatorily online filing. 3. Unfortunately, due to some technical error in your software since the end of 2021, it was not possible to upload our application and documents. Finally, when this technical error was resolved and a new software was launched by you, we could file our transferability application online at JDGFT Bangalore office on 27.10.2022 (vide file ref.No.07AS07600031AM23 Dated 27.10.2022.

(Action: Applicant)

Case No.43 M/s. Alloys & Metals India, Kolkata

F.No.HQRPRCAPPLY00006020AM24

Meeting No.13AM25 held on 07.08.2024

Subject: Request for reactivation of Shipping Bill No. 4004428 dated:27.12.2019 pertaining to MEIS Scrip No. 0219095681 dated 28.01.2020 for duty credit amount of Rs. 3,04,955.00. Applicant’s statement: In this context, we would like to invite your attention to our initial prayer dated 04.12.2023, addressed to PC-3 wherein it was _ specifically requested for re-activation of the S/Bill No.4004428 dated 27.12.2019, since the MEIS scrip No.0219005681 dated 28.09.2020 has already been cancelled by RA Kolkata. It is apropos to allude to that unless the said S/Bill is detached from the cancelled MEIS scrip and re-activated we cannot apply for a issuance of a fresh MEIS scrip. The system is so designed that for applying for any fresh MEIS scrip, We need to upload the decision of the PRC/PC-3 approving issuance/re-issuance of the MEIS scrip. Based on the export performance in connection with the shipping Bill No.4004428 dated 27.12.2019, MEIS Scrip No.0219095681 dated 28.09.2020 for duty credit amount of Rs,3,04,955.00 has been generated in the online Portal. While the fact remains that the said MEIS Scrip never appeared online, the physical copy of the same could not be printed for actual utilization of the Scrip.

Decision: The Committee examined the case on the basis of submission made by the firm and discussed the matter at length. After detailed discussion it was noted that the firm has faced difficulty beyond their control and Committee decided to refer to PC3 for Page 35 of 37

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reactivation of shipping billNo. 4004428 dated27.12.2019 pertaining to MEIS Scrip No. 0219095681 dated 28.01.2020, to enable applicant to reapply for MEIS.The firm shall approach PC-3 within 30 days from the date of uploading of the minutes of meeting.

(Action: Applicant/PC-3 division)

Case No.44

M/s. Hyundai Motor India Limited, Tamil Nadu

F.No.HQRPRCAPPLY00004613AM23

Meeting No.13AM25 held on 07.08.2024

Subject: Request for revalidation of Scrip against Focus Product Scheme Authorization No. 0410165566 dated 06.05.2019.

This is review case of PRC Meeting No.03AM23 (Case No.68) held on 22.04.2022 & 05.05.2022 wherein Committee reject the case.

Applicant’s statement:GREETINGS FROM HYUNDAI MOTOR INDIA Sub Short Receipt of Export Incentive: Focus Product Scheme FPS We have received License amount Rs: 95.35Lacs out of 99.36 Lacs, Short receipt of Rs: 4.01Lacs Mistake has crept in due to calculation error We have regularly followed-up with RA(Chennai) for the Short receipt of FPS scrip value thro Mail Dt: 10-Sep-2019 , 19-Mar-2020 , 08-May2020.

(Action: Applicant)

Case No.45

M/s. Agrow Allied Ventures Private Limited, Gurugram

F.No.HQRPRCAPPLY00004200AM23

Meeting No.13AM25 held on 07.08.2024

Subject: Request for waiver of Export Obligation in authorization against Advance Authorization No. 0510405163 dated 29.12.2017, Advance Authorization No. 0510405597 dated 09.02.2018.

This is a defer case of PRC Meeting No.33AM23 (Case No.17) dated 01.03.2023 wherein Committee defer the case and ask CLA-New Delhi to submit a report in reference to PRC application within 21 days. ook \

Page 36 of 37

Applicant’s statement:The matter was taken up. The entire submission made by the applicant was gone through. The applicant stated that they are manufacturer and exporter of Agro-Chemicals and exporting these products since 2017. Initially they are exporting on payment of customs duty on inputs being used in the export product as there was little export but thereafter they started availing facility of Advance License to safe guard the capital of the organization on imported inputs use in the export product. They had applied for Advance License and being a new comer, they are not aware of procedure or familiar with exim policy therefore they applied for two different AA for each import items specified in SION i.e. Phenol and Mono Chloro Acetic Acid which led to double liability of exports as both the import items were being used to fulfill EO of one of the above AA. They noticed the problem and approach RA for amendment by incorporating other import items i.e. Phenol in AA No. 0510405163 dated 29.12.2017 and Mono Chloro Acetic Acid in another license that would enable them to fulfill the E.O. of both the licenses. RA has been rejected their request hence it was not possible to full double EO against import made in both authorizations as inputs imported under both authorization had been used to manufacture of export product that could be exported in any one of the authorizations. Hence they are requesting to allow waiver of fulfillment of EO in one of the authorizations.

Comments of RA-CLA was also seen.

Decision:The Committee examined the case on the basis of submission made by the applicant and discussed the matter at length. The Committee noted that import items from both the authorisations put together contribute to one set of each export product. Accordingly, it decided to allow consideration of clubbing of Advance Authorizations no. 0510405163 dated 29.12.2017, Advance Authorization No. 0510405597 dated 09.02.2018for EODC/redemption purpose only, subject to fulfilment of all other conditions. The firm shall approach RA within 30 days from the date of uploading of the minutes of meeting. (Action: Applicant/RA-CLA, New Delhi) =<

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