Minutes of the 226th meeting of Approval Committee

Minutes of the 226th Unit Approval Committee Meeting of Kandla SEZ held on 13.05.2026 at 11:00 hrs under the Chairmanship of Shri Dnyaneshwar Bhalchandra Patil, Development Commissioner, Kandla Special Economic Zone. Following were present:

1. Ms. Rajtanil Solanki : Joint Development Commissioner, KASEZ.

Shri. S. K. Chaudhary : Sub-Divisional Magistrate, Anjar Rep. of District Collector, Kutch (Video Conferencing mode). 3. Shri. Rakesh Jain : Additional Commissioner of Customs, Rep. of Commissioner of Customs, Kandla. (Video Conferencing mode). 4. Shri. Bharat Nakum : Manager R. M., DIC, Bhuj

(Video Conferencing mode). 5. Shri. Darshan Gattani : Deputy Development Commissioner, KASEZ (Special Invitee) 6. Shri. Bhanu Jain : Deputy Commissioner of Customs, KASEZ (Special Invitee) Absentees:-

1. Director (Banking)
2. I.T.
3. DGFT 226.I Review/Confirmation of the minutes of last meeting (225th UAC) of the Approval Committee:- 1 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

entees:-

1. Director (Banking)
2. I.T.
3. DGFT 226.I Review/Confirmation of the minutes of last meeting (225th UAC) of the Approval Committee:- 1 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

Minutes of the last meeting of Unit Approval Committee were confirmed. 226.1 REQUEST FOR BROADBANDING/ITEM ADDITION AGENDA ITEM NO. 226.1.1 Request for addition of Manufacturing Activity in their existing LoA– Request of M/s. Pon Pure Chemical India Private Limited, KASEZ M/s. Pon Pure Chemical India Private Limited, KASEZ is an approved unit with LoA No. 06/2005-06 dated 06.05.2005 issued from F. No. KASEZ/IA/06/2005-06 as amended for repacking of chemicals and solvents, falling in Chapter 27, 28 & 29, organic composite solvents and thinners, manufacturing and trading activity. Now the said unit
has requested for addition of items for manufacturing activity in their existing LoA. No representative from the unit appeared before the Committee to explain the proposal. Therefore, the Approval Committee decided to defer their proposal. AGENDA ITEM NO. 226.1.2 Request for addition of items in Manufacturing Activity in their existing LoA– Request of M/s Rusan Pharma Ltd. (Unit-II), KASEZ M/s Rusan Pharma Ltd. (Unit-II), KASEZ is an approved unit for Manufacturing of Transdermal Patches (Pharmaceutical Product) (HS Code 3004) vide Letter of Approval No.

(Unit-II), KASEZ M/s Rusan Pharma Ltd. (Unit-II), KASEZ is an approved unit for Manufacturing of Transdermal Patches (Pharmaceutical Product) (HS Code 3004) vide Letter of Approval No. KASEZ/IA/07/2015-16/4089 dated 01.07.2015, as amended/extended from time to time. Now the said unit
has requested for addition of items for manufacturing activity in their existing LoA. Shri Vivek Milak, Authorised Representative of the company appeared before the Committee to explain the proposal. Shri Milak stated that they are already into manufacturing and exports of pharmaceutical products and now they have requested for addition of one item for manufacturing activity and the same product line will be used for manufacturing the additional item. The Approval Committee after due deliberation decided to approve the proposal for additional item in manufacturing activity in their existing LoA, subject to standard terms and conditions: 2 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

decided to approve the proposal for additional item in manufacturing activity in their existing LoA, subject to standard terms and conditions: 2 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

i) Any restrictions on import/export of manufacturing items and its raw materials will apply. ii) Further, the items will be subjected to the Policy Conditions specified in DGFT’s ITC HS Code wherever applicable. iii) In case of any discrepancy/mismatch between the ‘Description of Goods’ as provided by the Unit & ‘Description of goods as per DGFT Import Policy’, the later will prevail. iv) Further, the unit will obtain registration/clearance/any other mandatory requirement prescribed under any Act/Rules from concerned agencies before undertaking of such activities. v) Further, the unit will ensure the compliance of all guidelines, policies issued by any Ministry from time to time pertaining to the items approved in LoA. vi) Further at the time of import/export/DTA procurement of any items, the HSN code has to be examined by the Customs officers at the time of clearance of the goods. vii) Further, the unit will give an undertaking that none of the items proposed and its raw materials are falling under negative list and if the items are found in negative list, penal action may be initiated against them. AGENDA ITEM NO. 226.1.3 Permission for addition of manufacturing service activity in their existing LoA – Request of M/s. International Warehousing & Trading (Unit-II), KASEZ. M/s.

st them. AGENDA ITEM NO. 226.1.3 Permission for addition of manufacturing service activity in their existing LoA – Request of M/s. International Warehousing & Trading (Unit-II), KASEZ. M/s. International Warehousing & Trading (Unit-II), KASEZ is an approved unit in KASEZ with LoA No. 28/2024-25 dated 12.12.2024 issued for Manufacturing Activities, as amended. Now the said unit has requested for permission for addition of manufacturing activity under Rule 18(6) of SEZ Rules 2006 and submitted list of items for manufacturing service. Shri Kiran Singh Kochhar, Partner of the firm appeared before the Committee to explain the proposal. Shri Kochhar stated that they are having a manufacturing LoA for tobacco products and now they want to include tobacco dust pellets in their manufacturing service activity under Rule 18(6) of the SEZ Rules, 2006 on behalf of their foreign clients. The Committee noted that their proposal was deferred in the last UAC with direction to the unit to submit their application for manufacturing service activity in NSDL as Unit-II after rectifying the discrepancies. 3 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

ith direction to the unit to submit their application for manufacturing service activity in NSDL as Unit-II after rectifying the discrepancies. 3 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

Shri Kochhar stated that they have submitted their new unit application as Unit-II in the NSDL online system. He further stated that they are having LoA No. 28/2024-25 for manufacturing of tobacco products as Unit-II and now they want to include tobacco dust pellets in their manufacturing service activity under Rule 18(6) of the SEZ Rules, 2006 on behalf of their foreign clients. The Approval Committee after due deliberation decided to approve the proposal for addition of manufacturing service activity under Rule 18(6) of SEZ Rules, 2006 in their existing LoA, subject to standard terms and conditions: i) Any restrictions on import/export of above items and its raw materials will apply. ii) The above manufacturing services activity is also subject to strict compliances of Rule 18(6) of SEZ Rules, 2006. iii) In case of any discrepancy/mismatch between the above ‘Description of Goods’ as provided by the Unit & ‘Description of goods as per DGFT Import Policy’, the later will prevail. iv) Further, the items will be subjected to the Policy Conditions specified in DGFT’s ITC HS Code wherever applicable.

t & ‘Description of goods as per DGFT Import Policy’, the later will prevail. iv) Further, the items will be subjected to the Policy Conditions specified in DGFT’s ITC HS Code wherever applicable. v) Further, the unit will obtain registration/clearance/any other mandatory requirement prescribed under any Act/Rules from concerned agencies before undertaking of such activities. vi) Further at the time of import/export/DTA procurement of any items, the HSN code has to be examined by the Customs officers at the time of clearance of the goods. vii) Further, the unit will give an undertaking that none of the items proposed and its raw materials are falling under negative list and if the items are found in negative list, penal action may be initiated against them. 226.2 MISCELLANEOUS ITEMS AGENDA ITEM NO. 226.2.1 Request for One-time Permission for addition of warehousing items in our LoA due to supply chain disruption caused by US-Iran War – Request of M/s. Garden Foods Corporation, KASEZ. The Committee noted that M/s. Garden Foods Corporation has requested for One-time Permission for addition of warehousing items in our LoA due to supply chain disruption caused by US-Iran War for Warehousing service activity of additional items. Shri Rahul Sihori, Partner of the firm appeared before the Committee to explain the proposal. Shri Sihori stated that they have requested for one 4 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

ri Rahul Sihori, Partner of the firm appeared before the Committee to explain the proposal. Shri Sihori stated that they have requested for one 4 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

time permission for warehousing of additional items as one of their client has requested to warehousing the goods due to US-Iran War disruption. The Committee asked the Partner as to whether they require one time permission to warehouse the goods. In reply, Shri Sihori stated that they require regular permission also for the said additional items. The Committee after due deliberation decided to permit the additional items to be warehoused by the above unit on behalf of DTA/Foreign clients as submitted by the unit (subject to unit submitting KYC of their clients alongwith ITR of last 3 years on whose behalf they will warehouse goods, to DC office before commencing first transaction by that client, in terms of Instruction No. 117), subject to the unit fulfilling NFE criterion and also subject to following conditions: i) None of the items which are restricted or prohibited will be allowed to be warehoused and any restrictions on import/export of any items will apply unless specifically permitted by the UAC.

ns: i) None of the items which are restricted or prohibited will be allowed to be warehoused and any restrictions on import/export of any items will apply unless specifically permitted by the UAC. This clause will have overriding effect for any approval granted in LoA now or before. ii) Further, the items will be subjected to the Policy Conditions specified in DGFT’s ITC HS Code wherever applicable. iii) Further, the items will be subjected to the MIP conditions wherever applicable. iv) Further, the unit must ensure that they should have a tamper- proof ERP/SAP/Tally system with provisions of CCTV with sufficient longer duration of storage & other equipments. v) Further, the transfer of goods from one FTWZ to another FTWZ shall not be allowed except in specific and exceptional cases after consideration by the UAC. vi) In case of any discrepancy/mismatch between the ‘Description of Goods’ as provided by the Unit & ‘Description of goods as per DGFT Import Policy’, the later will prevail. vii) Further, the unit will obtain registration/clearance/any other mandatory requirement prescribed under any Act/Rules from concerned agencies before undertaking of such activities. viii) Further, the unit will ensure the compliance of all guidelines, policies issued by any Ministry from time to time pertaining to the items approved in LoA. ix) Further at the time of import/export/DTA sales of any items, the HSN code has to be examined by the Customs officers at the time of clearance of the goods. x)

ing to the items approved in LoA. ix) Further at the time of import/export/DTA sales of any items, the HSN code has to be examined by the Customs officers at the time of clearance of the goods. x) Further, the unit will give an undertaking that none of the items proposed are falling under negative list and are not hazardous or require environmental clearance for storage/ transmission/ 5 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

handling and if the items are found in negative list or hazardous in nature, penal action will be initiated against them. AGENDA ITEM NO. 226.2.2 Request for one time permission to warehouse goods on behalf of Foreign Principals for further export – Request of M/s. International Warehousing & Trading, KASEZ. The Committee noted that M/s. International Warehousing & Trading has requested for One-time Permission to warehouse goods on behalf of foreign clients. Shri Kiran Singh Kochhar, Partner of the firm appeared before the Committee to explain the proposal. Shri Kochhar stated that due to US-Iran War they have been approached by US brands for warehousing goods as the goods destined for Jebel Ali Port has been diverted to Mundra Port and the principals has told them to warehouse the goods in their warehouse till the Jebel Ali Port which is closed due to war is re-opened. He further stated that the warehoused goods will be re-exported. The Committee noted that the item at Sr. No. 2 of the agenda is restricted and only State Trading Enterprise is authorised to import the same.

stated that the warehoused goods will be re-exported. The Committee noted that the item at Sr. No. 2 of the agenda is restricted and only State Trading Enterprise is authorised to import the same. In reply, Shri Kochhar stated that they have requested for one time permission as due to War their principals are not able to ship the goods to Jebel Ali Port. The Committee further noted that as a special case we may consider one time permission for item at Sr. No. 2 of the agenda and write to State Trading Enterprise mentioning that the item proposed to be warehoused is especially for re-export and DC office is permitting the same to be warehoused in KASEZ and if they have any objection they may visit the site for verification of the warehoused goods.
The Committee after due deliberation decided to grant one-time permission to the unit for warehousing of the proposed items as the Committee noted that the items proposed to be warehoused are for re-export purpose and directed the DC Office to write to State Trading Enterprise with regard to item at Sr. No. 2 that due to closure of Jebel Ali Port, the item proposed at Sr. No. 2 is allowed to be warehoused in KASEZ which is for re- export purpose only and if they have any issue of warehousing of proposed item at Sr. No. 2, they have write to DC office within 7 days time. AGENDA ITEM NO. 226.2.3 Permission to warehouse goods on behalf of Foreign/DTA client in their existing LoA – Request of M/s.

sed item at Sr. No. 2, they have write to DC office within 7 days time. AGENDA ITEM NO. 226.2.3 Permission to warehouse goods on behalf of Foreign/DTA client in their existing LoA – Request of M/s. International Warehousing & Trading, KASEZ. 6 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

The Committee noted that M/s. International Warehousing & Trading, KASEZ has requested for permission for warehousing activity of additional items. Shri Kiran Singh Kochhar, Partner of the firm appeared before the Committee to explain the proposal. Shri Kochhar stated that they have requested for warehousing of additional items. He further stated that out of the 9 items proposed for one time permission, they have requested for warehousing of 5 items on regular basis. The Committee noted that the item at Sr. No. 2 of the agenda is restricted and only State Trading Enterprise is authorised to import the same and directed the Partner that the same will not be allowed. The Committee after due deliberation decided to permit the additional items except item at Sr. No. 2 of the Agenda to be warehoused by the above unit on behalf of DTA/Foreign clients as submitted by the unit (subject to unit submitting KYC of their clients alongwith ITR of last 3 years on whose behalf they will warehouse goods, to DC office before commencing first transaction by that client, in terms of Instruction No.

submitting KYC of their clients alongwith ITR of last 3 years on whose behalf they will warehouse goods, to DC office before commencing first transaction by that client, in terms of Instruction No. 117), & subject to the unit fulfilling NFE criterion and also subject to following conditions: i) None of the items which are restricted or prohibited will be allowed to be warehoused and any restrictions on import/export of any items will apply unless specifically permitted by the UAC. This clause will have overriding effect for any approval granted in LoA now or before. ii) Further, the items will be subjected to the Policy Conditions specified in DGFT’s ITC HS Code wherever applicable. iii) Further, the items will be subjected to the MIP conditions wherever applicable. iv) Further, the unit must ensure that they should have a tamper- proof ERP/SAP/Tally system with provisions of CCTV with sufficient longer duration of storage & other equipments. v) Further, the transfer of goods from one FTWZ to another FTWZ shall not be allowed except in specific and exceptional cases after consideration by the UAC. vi) In case of any discrepancy/mismatch between the ‘Description of Goods’ as provided by the Unit & ‘Description of goods as per DGFT Import Policy’, the later will prevail. vii) Further, the unit will obtain registration/clearance/any other mandatory requirement prescribed under any Act/Rules from concerned agencies before undertaking of such activities. 7 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

tration/clearance/any other mandatory requirement prescribed under any Act/Rules from concerned agencies before undertaking of such activities. 7 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

viii) Further, the unit will ensure the compliance of all guidelines, policies issued by any Ministry from time to time pertaining to the items approved in LoA. ix) Further at the time of import/export/DTA sales of any items, the HSN code has to be examined by the Customs officers at the time of clearance of the goods. x) Further, the unit will give an undertaking that none of the items proposed are falling under negative list and are not hazardous or require environmental clearance for storage/ transmission/ handling and if the items are found in negative list or hazardous in nature, penal action will be initiated against them. AGENDA ITEM NO. 226.2.4 Request of M/s. S. R. Brothers, KASEZ, for addition of items in warehousing activity in their existing LOA NO. 25/2021-22 dated 21.02.2022 The Committee noted that M/s. S. R. Brothers, KASEZ has requested for permission for warehousing activity of additional items. Shri Sabbir Rayma and Shri Sarfaraz Bara, Authorised Representatives of the firm appeared before the Committee to explain the proposal.

rmission for warehousing activity of additional items. Shri Sabbir Rayma and Shri Sarfaraz Bara, Authorised Representatives of the firm appeared before the Committee to explain the proposal. Shri Rayma stated that they have requested for warehousing of additional items. The Committee noted that for some of the items the unit has not given correct ITC HS Code and directed the unit representatives to submit the correct ITC HS Code for the items proposed. The Committee after due deliberation decided to permit the additional items (with direction to submit correct ITC HS Code of items at Sr. No. 8, 9, 16, 19, 20, 30, 32, 33, 34, 48, 51, 52 of the Agenda) to be warehoused by the above unit on behalf of DTA/Foreign clients as submitted by the unit (subject to unit submitting KYC of their clients alongwith ITR of last 3 years on whose behalf they will warehouse goods, to DC office before commencing first transaction by that client, in terms of Instruction No. 117), subject to payment of outstanding rental dues & subject to the unit fulfilling NFE criterion and also subject to following conditions: i) None of the items which are restricted or prohibited will be allowed to be warehoused and any restrictions on import/export of any items will apply unless specifically permitted by the UAC. This clause will have overriding effect for any approval granted in LoA now or before. ii) Further, the items will be subjected to the Policy Conditions specified in DGFT’s ITC HS Code wherever applicable. 8 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

ed in LoA now or before. ii) Further, the items will be subjected to the Policy Conditions specified in DGFT’s ITC HS Code wherever applicable. 8 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

iii) Further, the unit must ensure that they should have a tamper- proof ERP/SAP/Tally system with provisions of CCTV with sufficient longer duration of storage & other equipments. iv) Further, the transfer of goods from one FTWZ to another FTWZ shall not be allowed except in specific and exceptional cases after consideration by the UAC. v) In case of any discrepancy/mismatch between the ‘Description of Goods’ as provided by the Unit & ‘Description of goods as per DGFT Import Policy’, the later will prevail. vi) Further, the unit will obtain registration/clearance/any other mandatory requirement prescribed under any Act/Rules from concerned agencies before undertaking of such activities. vii) Further, the unit will ensure the compliance of all guidelines, policies issued by any Ministry from time to time pertaining to the items approved in LoA. viii) Further at the time of import/export/DTA sales of any items, the HSN code has to be examined by the Customs officers at the time of clearance of the goods. ix) Further, the unit will give an undertaking that none of the items proposed are falling under negative list and are not hazardous or require environmental clearance for storage/ transmission/ handling and if the items are found in negative list or hazardous in nature, penal action will be initiated against them. AGENDA ITEM NO.

require environmental clearance for storage/ transmission/ handling and if the items are found in negative list or hazardous in nature, penal action will be initiated against them. AGENDA ITEM NO. 226.2.5 Request for addition of items in warehousing activity - Request of M/s. Shriji Overseas, KASEZ The Committee noted that M/s. Shriji Overseas, KASEZ has requested for permission for warehousing activity of additional items. Shri Shivam Kumar, Authorised Representative of the firm appeared before the Committee to explain the proposal. Shri Shivam stated that they have requested for warehousing of additional items. The Committee noted that some of the items proposed requires FSSAI and some of the items requires PESO licence and asked the unit representative as to whether they have got FSSAI and PESO licence for warehousing the proposed goods. In reply, Shri Shivam stated that they already have FSSAI approval and regarding PESO licence they will apply for the same. The Committee directed the unit representative to first apply for PESO licence and then come up for the items which require PESO. The Committee further noted that due to urgency by the unit one-time permission was granted to the unit for warehousing of the item at Sr. No. 99 of the Agenda and ratified the same. 9 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

urgency by the unit one-time permission was granted to the unit for warehousing of the item at Sr. No. 99 of the Agenda and ratified the same. 9 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

The Committee after due deliberation decided to permit the additional items except items at Sr. No. 41 to 49, 74 to 85 of the Agenda to be warehoused by the above unit on behalf of DTA/Foreign clients as submitted by the unit (subject to unit submitting KYC of their clients alongwith ITR of last 3 years on whose behalf they will warehouse goods, to DC office before commencing first transaction by that client, in terms of Instruction No. 117), & subject to the unit fulfilling NFE criterion and also subject to following conditions: i) None of the items which are restricted or prohibited will be allowed to be warehoused and any restrictions on import/export of any items will apply unless specifically permitted by the UAC. This clause will have overriding effect for any approval granted in LoA now or before. ii) Further, the items will be subjected to the Policy Conditions specified in DGFT’s ITC HS Code wherever applicable. iii) Further, the unit must ensure that they should have a tamper- proof ERP/SAP/Tally system with provisions of CCTV with sufficient longer duration of storage & other equipments. iv) Further, the transfer of goods from one FTWZ to another FTWZ shall not be allowed except in specific and exceptional cases after consideration by the UAC. v) In case of any discrepancy/mismatch between the ‘Description

of goods from one FTWZ to another FTWZ shall not be allowed except in specific and exceptional cases after consideration by the UAC. v) In case of any discrepancy/mismatch between the ‘Description of Goods’ as provided by the Unit & ‘Description of goods as per DGFT Import Policy’, the later will prevail. vi) Further, the unit will obtain registration/clearance/any other mandatory requirement prescribed under any Act/Rules from concerned agencies before undertaking of such activities. vii) Further, the unit will ensure the compliance of all guidelines, policies issued by any Ministry from time to time pertaining to the items approved in LoA. viii) Further at the time of import/export/DTA sales of any items, the HSN code has to be examined by the Customs officers at the time of clearance of the goods. ix) Further, the unit will give an undertaking that none of the items proposed are falling under negative list and are not hazardous or require environmental clearance for storage/ transmission/ handling and if the items are found in negative list or hazardous in nature, penal action will be initiated against them. AGENDA ITEM NO. 226.2.6

Subject: Reconsideration of withdrawal of approvals granted to M/s.

Royal Petro Oil Refinery LLP and M/s. Ananya Oil Pvt. Ltd. (erstwhile 10 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

M/s. Hindustan Oil Industries), KASEZ, for recycling/reclamation of used oil, in pursuance of the directions of the Board of Approval. The Committee noted that the said agenda was discussed in the last UAC meeting and the UAC directed the Committee constituted under chairmanship of DC Custom KASEZ to submit a detailed report and also directed the unit representatives to submit written submission in support of their claim to DC Custom committee that as per EPR guidelines re-refining of used oil is not a recycling process. Shri Hemant Shah, Partner & Shri Jigar Gohil, Authorised Representative of M/s. Royal Royal Petro Oil Refinery LLP, KASEZ and Shri Narendra Nimbawat, Director of M/s. Ananya Oil Pvt. Ltd. along with Shri Ashish Jhagarawat (through VC) appeared before the Committee to explain their proposal. Shri Ashish stated that as per minutes of the last UAC meeting they were required to give written submission in support of the discussions held in the last meeting and they have submitted their written submissions stating various facts and one of the important point is that the activities which they are describing is manufacturing activity.

st meeting and they have submitted their written submissions stating various facts and one of the important point is that the activities which they are describing is manufacturing activity. He further stated that they have also submitted in their written submissions the recent precedent of BoA also wherein used cooking oil import was permitted for manufacture of bio-fuels and used cooking oil is a prohibited item and under Rule 27(1) of the SEZ Rules, 2006 the power to approve the same lies with the BoA. However, import of used oil or waste oil is not prohibited for import and under Rule 27(1), the same is allowed to be imported for manufacturing of base oil, lubricants or new fuels with distinct HSN and new product will be coming out. Since the matter was also earlier referred to the BoA and the BoA has remanded back the matter with regard to EPR guidelines they have requested for re-consideration. The Committee noted that there is thin line in manufacturing and re- cycling and perused the Committee Report wherein they have cited various examples of Visakhapatnam SEZ wherein LoAs was issued for used cooking oil after approval of BoA wherein from the used cooking oil, bio-fuels are being manufactured and from used oil, base oil, lubricants & fuels are being manufactured. The Committee asked the Deputy Commissioner of Customs, KASEZ about the difference between used cooking oil and used oil.

red and from used oil, base oil, lubricants & fuels are being manufactured. The Committee asked the Deputy Commissioner of Customs, KASEZ about the difference between used cooking oil and used oil. Shri Bhanu Jain, DC (Customs), KASEZ stated that used oil is coming under Hazardous Waste Rules definitions whereas used cooking oil is non- hazardous. The Committee noted that as used oil is hazardous the definition of recycling is taken from Hazardous Waste Rules.But UAC observed that Committee not done deliberation on which definition of recycling is used in cooking oil case. The Committee deliberated on the issue and noted that in the Committee Report submitted by the DC (Customs), KASEZ they have 11 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

cited 3-4 examples of Indore SEZ unit, Visakhapatnam SEZ unit and the fact that the existing units have made significant investments in plant & machinery as per LoA issued and post-facto suspension of their authorised operations would be detrimental to their legitimate business interests.

ave made significant investments in plant & machinery as per LoA issued and post-facto suspension of their authorised operations would be detrimental to their legitimate business interests. Further, these units have submitted that they have clean track record, earned significant foreign exchange and undertook to comply with applicable environmental norms and for the existing units in Kandla SEZ, UAC may take into account the arguments as submitted by the units and may take a balanced decision, subject to compliance with applicable statutory requirements. The Unit Approval Committee (UAC) deliberated in detail upon the agenda note, the directions of the Board of Approval issued in its 127th and 128th meetings, the inspection committee reports dated 24.10.2024 and 06.05.2026, the submissions made by both units, and the applicable provisions of the SEZ Act and Rules along with the prevailing EPR framework issued by MoEF&CC.   During deliberations, the UAC observed that there exists a very thin line between “manufacturing” and “recycling/re-refining” processes in the present matter. The Committee noted that both units were granted approval by the UAC in the years 2014–2016 after due diligence and examination by the competent authorities. Based upon such approvals and issuance of LoAs, the units made substantial investments in plant and machinery and have been operating continuously for several years.   The UAC noted that in the case of M/s.

such approvals and issuance of LoAs, the units made substantial investments in plant and machinery and have been operating continuously for several years.   The UAC noted that in the case of M/s. Royal Petro Oil Refinery LLP, the Department of Commerce vide letter dated 27.01.2016 had specifically observed that if the Development Commissioner, KASEZ was satisfied that the process involved was not recycling, the matter could be decided at the level of KASEZ UAC. Accordingly, after examination of the process and project reports, approval was granted by the UAC.   The UAC also took note of the findings of the fresh committee report dated 06.05.2026, wherein it has been observed that the units import “used oil” as raw material and process the same into distinct finished products such as base oil, lubricants, grease and gas oil having different nomenclature, characteristics and classification. Prima facie, such activity appears to fall within the 12 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

se and gas oil having different nomenclature, characteristics and classification. Prima facie, such activity appears to fall within the 12 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

ambit of “manufacture” as defined under Section 2(r) of the SEZ Act, 2005. TheUAC also observed that “The statutory definition of ‘recycling of waste oil’ under the Hazardous Wastes (Management and Handling) Rules, 1989 is confined to reclamation and treatment processes aimed at removal of impurities and restoration of usability of waste oil. However, in the present case, the imported used oil is subjected to substantial industrial processing resulting in emergence of commercially distinct products such as base oil, lubricants, grease and gas oil having separate nomenclature, characteristics, tariff classification and end use. The activity, therefore, transcends mere recycling/reclamation and satisfies the test of ‘manufacture’ under Section 2(r) of the SEZ Act, 2005. Even the said Rules distinguish ‘re-refining’ from mere recycling and recognize production of base stock for further manufacture of petroleum products, thereby indicating that such processes are industrial manufacturing activities and not mere waste recovery operations.   The Committee further observed that neither the SEZ Act nor the SEZ Rules define the term “recycling.” The CRA Audit objection has relied upon the definitions contained in the Hazardous Waste Management Rules framed under the MoEFframework.

the SEZ Act nor the SEZ Rules define the term “recycling.” The CRA Audit objection has relied upon the definitions contained in the Hazardous Waste Management Rules framed under the MoEFframework. However, the Committee as well as UAC also took note that in the matter relating to M/s. Anjum Aromatics, Indore SEZ, the MoEF&CC itself clarified that matters relating to SEZ units are required to be examined under the SEZ framework and in consultation with the Board of Approval. Therefore, the UAC was of the view that definitions under the MoEFHazardous Waste Regulations cannot be applied mechanically for determination of “manufacturing” under the SEZ framework.   The UAC as well as Committee also observed that if such units were located in DTA, there would be no restriction upon their operations subject to applicable environmental laws. Merely because the units are located in an SEZ, denial of operations after years of functioning would be contrary to the objectives of the SEZ Act relating to export promotion, employment generation, investment promotion and Ease of Doing Business.   The UAC further considered that the units have made substantial investments, generated employment, earned foreign exchange 13 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

ng Business.   The UAC further considered that the units have made substantial investments, generated employment, earned foreign exchange 13 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

and have maintained compliance with applicable statutory provisions. Abrupt withdrawal of approvals granted after due diligence and long years of operation may adversely affect investor confidence and would not be in the larger national interest.   At the same time, the Committee noted that the issue relating to interpretation of Rule 18(4)(d) of the SEZ Rules, 2006 vis-à-vis re- refining/recycling activities is presently under audit scrutiny and policy clarification at the level of Department of Commerce/Board of Approval may still be required.   After detailed deliberations and taking a balanced and pragmatic view of the matter, the UAC decided as under:   (i) The decision taken in the 207th UAC Meeting held on 28.10.2024 for withdrawal of permissions granted to M/s. Royal Petro Oil Refinery LLP and M/s. Ananya Oil Pvt. Ltd.

ded as under:   (i) The decision taken in the 207th UAC Meeting held on 28.10.2024 for withdrawal of permissions granted to M/s. Royal Petro Oil Refinery LLP and M/s. Ananya Oil Pvt. Ltd. is hereby withdrawn with immediate effect.   (ii) The position and permissions prevailing prior to the decision of the 207th UAC Meeting shall stand restored.   (iii) Reply shall be submitted to CRA Audit stating that the determination of “manufacturing” under the SEZ framework cannot be based solely upon the definitions contained in the Hazardous Waste Management Rules and that the approvals granted during 2014–2016 were issued after due examination by the competent authorities and guidance received from the Department of Commerce.   (iv) However, till closure of the audit para or issuance of a final clarification/policy

decision

by

the

Department

of Commerce/Board of Approval regarding permissibility and classification of such activities under Rule 18(4)(d) of the SEZ Rules, 2006, no fresh LoA for similar activities shall be granted by KASEZ UAC.   The agenda item was accordingly approved. AGENDA ITEM NO. 226.3 14 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

les, 2006, no fresh LoA for similar activities shall be granted by KASEZ UAC.   The agenda item was accordingly approved. AGENDA ITEM NO. 226.3 14 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

Monitoring of ANNUAL PERFORMANCE REPORT (APR) of the 10 units whose LoA is due for renewal. As per Rule 54 of the SEZ Rules, 2006, the performance of the units shall be monitored by the Approval Committee as per the guidelines given under Annexure appended to these rules. The Committee noted that the performance of the 10 units as per the APRs received from the units is submitted for monitoring as per the provisions of SEZ Rules, 2006.

1. AB Warehousing M/s. AB Warehousing has been issued with LoA No. KASEZ/IA/44/2020-21 dated 24.03.2021 for Warehousing and trading activity and the unit has commenced their authorised operation w.e.f. 02.06.2021 and their LoA is valid upto 01.06.2026. The Committee perused the performance of the unit for the last 5 year block period and noted that the achievement of NFE is very less as compared to the projected NFE and the unit has not submitted APRs on time. Shri Sabbir Rayma, Partner of the firm appeared before the Committee. The Committee asked the Partner about very meagre activity during their current 5 year block period and no activity during 2021-22, 2022-23 & 2024-25.

the firm appeared before the Committee. The Committee asked the Partner about very meagre activity during their current 5 year block period and no activity during 2021-22, 2022-23 & 2024-25. In reply, Shri Rayma stated that due to delay in PGVCL connection they could not undertake any activity as there were pending dues of PGVCL against the earlier allottee of the plot allotted to them and the PGVCL connection was granted to them only in January’2024. He further stated that they have started their construction and the construction of building was completed by them in Mar’2024. He further stated that after the PGVCL connection in Jan’24, they have undertaken trading activity and in the APR for 2023-24 they have mentioned the figures. The Committee further asked the Partner as to whether they have not undertaken any warehousing activity. In reply, Shri Rayma stated that they are undertaking warehousing activity on behalf of their DTA client wherein they are receiving the payment of warehousing charges in INR. The Committee directed the Partner that receiving payment in INR is violation of SEZ Act and Rules and notice will be issued for violation of receiving payment in INR for warehousing services. 15 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

payment in INR is violation of SEZ Act and Rules and notice will be issued for violation of receiving payment in INR for warehousing services. 15 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

The Committee after due deliberation directed the DC office to initiate action for issuance of Show Cause notice to the unit for receiving payment in INR for the warehousing service provided by them and also for delay in submission of APR for the period 2021-22, 2022-23, 2023-24 & 2024-25. 2. Galentic Pharma (India) Pvt. Ltd.

M/s. Galentic Pharma (India) Pvt. Ltd. has been issued with LoA No. KASEZ/IA/010/2010-11 dated 05.08.2010 for manufacturing and trading activity and the unit has commenced their authorised operation w.e.f. 25.07.2011 and their LoA is valid upto 23.07.2026. block period and noted that the achievement of NFE is less as compared to the projected NFE and the unit has submitted APRs on time. Shri Hitesh Thakar, Authorised Representative of the firm appeared before the Committee. The Committee after due deliberation directed the DC office to renew their LoA for further 5 year block upto 23.07.2031 for manufacturing activity subject to submission of revised projections and also directed to issue separate LoA for trading activity with validity of 5 years period upto 23.07.2031, once the unit submits application in Form F along with application fee along with layout plan with separate entry & exit gates for both activities. 3. Godavari Chemicals M/s. Godavari Chemicals has been issued with LoA No.

in Form F along with application fee along with layout plan with separate entry & exit gates for both activities. 3. Godavari Chemicals M/s. Godavari Chemicals has been issued with LoA No. KASEZ/IA/GC/03/2020-21 dated 16.07.2020 for manufacturing and trading activity and the unit has commenced their authorised operation w.e.f. 10.07.2021 and their LoA is valid upto 09.07.2026. block period and noted that the achievement of NFE is less as compared to the projected NFE and the unit has submitted APRs on time. No unit representative of the firm appeared before the Committee. The Committee after due deliberation directed the DC office to renew their LoA for further 5 year block upto 09.07.2031 for manufacturing activity subject to submission of revised projections and also directed 16 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

to issue separate LoA for trading activity with validity of 5 years period upto 09.07.2031, once the unit submits application in Form F along with application fee along with layout plan with separate entry & exit gates for both activities. The Committee also directed to ask the unit about less export performance and NFE compared to projected exports and NFE and also their future plan for achievement of project exports and NFE in next 5 year block period. 4. HRJ Warehousing & Trading Co. M/s. HRJ Warehousing & Trading Co. has been issued with LoA No. KASEZ/IA/047/2010-11 dated 04.03.2011 for warehousing service and trading activity and the unit has commenced their authorised operation w.e.f.

sing & Trading Co. has been issued with LoA No. KASEZ/IA/047/2010-11 dated 04.03.2011 for warehousing service and trading activity and the unit has commenced their authorised operation w.e.f. 26.04.2011 and their LoA is valid upto 25.04.2026. block period and noted that there is no activity in their last 5 year block period and the unit has not submitted APRs on time. Shri Manit Kumar, Authorised Representative of the firm appeared before the Committee. The Committee asked the Authorised Representative about Nil performance during their last 5 year block period. In reply, Shri Manit stated that as their LoA was renewed only during last year, they could not undertake any activity. The Committee after due deliberation directed the DC office to examine and review the earlier UAC decision and also directed the Deputy Commissioner of Customs, KASEZ to undertake physical verification of the unit’s premises to ascertain the activity and submit its report within 10 days. The Committee further directed that the LoA of the unit may extended for 1 month’s period for warehousing activity and further directed that if the unit wishes to undertake trading activity they have to apply separate for trading activity in NSDL online system. The Committee also directed:- i. To initiate action for issuance of Show Cause notice to the unit for non-submission of APR for the period 2022-23, 2023-24, 2024-25 & 2025-26. 5. J.M. Baxi & Co. M/s. J.M. Baxi & Co. has been issued with LoA No.

ssuance of Show Cause notice to the unit for non-submission of APR for the period 2022-23, 2023-24, 2024-25 & 2025-26. 5. J.M. Baxi & Co. M/s. J.M. Baxi & Co. has been issued with LoA No. KASEZ/IA/041/2010-11 dated 29.11.2010 for warehousing service activity and the unit has commenced their authorised operation w.e.f. 29.11.2010 and their LoA is valid upto 28.11.2020. 17 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

block period and noted that there is no activity in their last 5 year block period and the unit has not submitted APRs on time. No unit representative of the firm appeared before the Committee. The Committee further noted that the validity of the LoA expired on 28.11.2020 and no extension has been granted thereafter. Since, the lease deed is co-terminus with the validity of the LoA, the lease has also automatically expired upon expiry of the LoA. The Committee after due deliberation decided not to renew their LoA for any further period as the unit has not undertaken any activity since 2015 and even prior thereto. The Committee further directed the Estate Officer to initiate action under the Public Premises (Eviction of Unauthorised Occupants) Act, 1971, as their LoA has already expired in the year 2020. 6. Kandla Polyplast (India) Pvt. Ltd. Unit-III M/s. Kandla Polyplast (India) Pvt. Ltd. Unit-III has been issued with LoA No. KASEZ/IA/32/2020-21 dated 08.01.2021 for manufacturing and warehousing activity and the unit has commenced their authorised operation w.e.f.

Pvt. Ltd. Unit-III has been issued with LoA No. KASEZ/IA/32/2020-21 dated 08.01.2021 for manufacturing and warehousing activity and the unit has commenced their authorised operation w.e.f. 23.06.2021 and their LoA is valid upto 22.06.2026. block period and noted that the unit has not achieved positive NFE in their current 5 year block period and the unit has submitted APRs on time. Shri Ankesh Gupta, Authorised Representative of the firm appeared before the Committee. The Committee asked the Authorised Representative about the reasons for non-achievement of positive NFE. In reply, Shri Gupta stated that they have got LoA during Covid Pandemic and market was shut down for 2 years and due to which they have make DTA sales of their finished goods. He further stated that in 2025-26 they have made exports of about Rs. 3 crores and during the current year 2 months period (Apr & May) they have undertaken exports of Rs. 1 crores. The Committee directed the representative to submit their future plan of exports as to how they will achieve positive NFE in the next 5 year 18 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

. The Committee directed the representative to submit their future plan of exports as to how they will achieve positive NFE in the next 5 year 18 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

block period as it has been noticed that in the current 5 year block period most of their finished goods are being sold in the DTA. The Committee after due deliberation directed the DC office to renew their LoA for further 3 months period upto 22.09.2026 for manufacturing activity subject to submission of revised projections and also directed to issue separate LoA for warehousing activity with validity of 3 months period upto 22.09.2026, once the unit submits application in Form F along with application fee along with layout plan with separate entry & exit gates for both activities. The Committee also directed:- i. To initiate action for issuance of Show Cause notice to the unit for negative NFE. The Committee directed the unit representative to submit their futuristic plan of exports and how they will achieve positive NFE in next 5 year block period. The Committee also directed the Deputy Commissioner of Customs, KASEZ to examine the issue of DTA Sale and produce the report. 7. S.R. Warehousing & Trading Co. Unit-II M/s. S.R. Warehousing & Trading Co. Unit-II has been issued with LoA No. KASEZ/IA/012/2011-12/3181 dated 17.06.2011 for warehousing activity and the unit has commenced their authorised operation w.e.f.

Warehousing & Trading Co. Unit-II has been issued with LoA No. KASEZ/IA/012/2011-12/3181 dated 17.06.2011 for warehousing activity and the unit has commenced their authorised operation w.e.f. 20.06.2011 and their LoA is valid upto 19.06.2026. block period and noted that the unit has achieved NFE to the higher side as compared to the projected NFE and the unit has submitted APRs on time except there was 1 month 23 days delay in filing of APR for 2021-22. The Committee condoned the delay in filing of APR for 2021-22. Shri Ramesh D. Shah, Partner of the firm appeared before the Committee. The Committee after due deliberation directed the DC office to renew their LoA for further 5 year block period upto 19.06.2031 for warehousing activity. 8. Saffire Fashions M/s. Saffire Fashions has been issued with LoA No. KASEZ/IA/003/2010-11 dated 09.06.2010 for manufacturing activity and the unit has commenced their authorised operation w.e.f. 13.06.2011 and their LoA is valid upto 12.06.2026. 19 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

manufacturing activity and the unit has commenced their authorised operation w.e.f. 13.06.2011 and their LoA is valid upto 12.06.2026. 19 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

block period and noted that there is no activity in their last 5 year block period and the unit has also not achieved positive NFE and the unit has not submitted APRs on time for 2021-22. No unit representative of the firm appeared before the Committee. The Committee after due deliberation directed:- i. To initiate action for issuance of Show Cause notice to the unit for negative NFE, reasons for non-achievement of projected NFE, for delay in submission of APR for the period 2021-22 and for non-performance as to why LoA of the unit should not be cancelled. The Committee further directed the Estate Officer to initiate action under the Public Premises (Eviction of Unauthorised Occupants) Act, 1971. 9. Shri Khatushyam Tradelinks M/s. Shri Khatushyam Tradelinks has been issued with LoA No. KASEZ/IA/31/2020-21 dated 28.12.2020 for warehousing and trading activity and the unit has commenced their authorised operation w.e.f. 25.06.2021 and their LoA is valid upto 24.06.2026. block period and noted that the achievement of NFE is very less as compared to the projected NFE and the unit has submitted APRs on time. Shri Rajesh Vashisth, Proprietor of the firm appeared before the Committee.

t the achievement of NFE is very less as compared to the projected NFE and the unit has submitted APRs on time. Shri Rajesh Vashisth, Proprietor of the firm appeared before the Committee. The Committee asked the Proprietor about very meagre activity during their current 5 year block period and they have not submitted APR for the year 2023-24, 2024-25 & 2025-26. In reply, Shri Vashisth stated that he has taken over the business during last year and after that he has re-constructed the building which is now complete and they will start their business in KASEZ shortly. The Committee after due deliberation directed the DC office to renew their LoA for further 1-year period upto 24.06.2027 for warehousing activity subject to submission of revised projections and also directed to issue separate LoA for trading activity with validity of 1 years period upto 24.06.2027, once the unit submits application in Form F along with application fee along with layout plan with separate entry & exit gates for both activities. If the performance of the unit is not satisfactory during the 1 year extended period, then action for cancellation of LoA may be initiated. The Committee also directed:- i. 20 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

atisfactory during the 1 year extended period, then action for cancellation of LoA may be initiated. The Committee also directed:- i. 20 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

To initiate action for issuance of Show Cause notice to the unit for delay in submission of APR/non-submission of APR for the period 2021-22, 2022-23, 2024-25 & 2024-25 and reasons for non- achievement of projected NFE and for non-performance. 10. Varsur Impex Pvt. Ltd. M/s. Varsur Impex Pvt. Ltd. has been issued with LoA No. KASEZ/IA/01/2021-22 dated 30.04.2021 for warehousing activity and the unit has commenced their authorised operation w.e.f. 18.06.2021 and their LoA is valid upto 17.06.2026. block period and noted that the achievement of NFE is less as compared to the projected NFE and the unit has not submitted APRs on time. Shri Narbir Singh, Director of the company appeared before the Committee. The Committee asked the Director about non-payment of outstanding rental dues as for renewal of LoA payment of pending rental dues is a pre-requisite condition. In reply, Shri Singh stated that they will clear pending rental dues in instalments as and when they will receive client for warehousing the goods. He further stated that they have requested for additional items in the last UAC however they have not been granted permission for additional items.

y will receive client for warehousing the goods. He further stated that they have requested for additional items in the last UAC however they have not been granted permission for additional items. The Committee directed the Director that renewal of LoA would be granted for 3 months period and the unit has to undertake warehousing of existing items only. The Committee further asked the Deputy Commissioner of Customs, KASEZ about the status of SCN issued to the unit. Shri Bhanu Jain, DC (Customs), KASEZ informed that SCN has been issued by Kandla Customs and the O-I-O is pending for adjudication. The Committee further asked the Additional Commissioner of Customs, Kandla that DC office has requested Kandla Customs for current status of investigation & status of adjudication proceedings. Shri Rakesh Jain, Additional Commissioner, Kandla Customs intimated that Kandla Customs has requested for documents from the unit and reply will be submitted to DC office shortly. The Committee after due deliberation directed the DC office to renew their LoA for further 3 months period upto 17.09.2026 for warehousing activity subject to payment of pending rental dues and the unit will be allowed to undertake warehousing activity of approved 21 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

for warehousing activity subject to payment of pending rental dues and the unit will be allowed to undertake warehousing activity of approved 21 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

items in their LoA and no additional items in warehousing is allowed till payment of all outstanding rental dues and the investigation is concluded by the adjudicating authority. SUPPLEMENTARY AGENDA ITEM NO. 226.4 Request for addition of items in Manufacturing Activity in their existing LoA – Request of M/s Siva Inotec Limited, KASEZ M/s Siva Inotec Limited, KASEZ is an approved unit for manufacturing activity and trading activity vide Letter of Approval No. KASEZ/IA/13/2009-10/5130 dated 13.07.2009, as amended. Now the said unit
has requested for addition of items for manufacturing activity in their existing LoA. Shri Vivek Milak, Authorised Representative of the company appeared before the Committee to explain the proposal. Shri Milak stated that they are already into manufacturing and exports of bingo tickets for 100% exports and now they have requested for addition of markers in their existing LoA for manufacturing activity which is a new product line. The Approval Committee after due deliberation decided to approve the proposal for additional item in manufacturing activity in their existing LoA, subject to standard terms and conditions: i) Any restrictions on import/export of manufacturing items and its raw materials will apply.

itional item in manufacturing activity in their existing LoA, subject to standard terms and conditions: i) Any restrictions on import/export of manufacturing items and its raw materials will apply. ii) Further, the items will be subjected to the Policy Conditions specified in DGFT’s ITC HS Code wherever applicable. iii) In case of any discrepancy/mismatch between the ‘Description of Goods’ as provided by the Unit & ‘Description of goods as per DGFT Import Policy’, the later will prevail. iv) Further, the unit will obtain registration/clearance/any other mandatory requirement prescribed under any Act/Rules from concerned agencies before undertaking of such activities. v) Further, the unit will ensure the compliance of all guidelines, policies issued by any Ministry from time to time pertaining to the items approved in LoA. vi) Further at the time of import/export/DTA procurement of any items, the HSN code has to be examined by the Customs officers at the time of clearance of the goods. vii) Further, the unit will give an undertaking that none of the items proposed and its raw materials are falling under negative list and if the items are found in negative list, penal action may be initiated against them. 22 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026

The meeting ended with a vote of thanks to the Chair. (Dnyaneshwar Bhalchandra Patil) Development Commissioner Kandla Special Economic Zone

23 KASEZ-IA1/15/2025-SEZ-KANDLA-Part(1) I/128386/2026