Minutes of the 209th meeting of Approval Committee

Minutes of the 209th Unit Approval Committee Meeting of Kandla SEZ held on 23.12.2024 at 11:00 hrs under the Chairmanship of Shri Dinesh Singh, Development Commissioner, Kandla Special Economic Zone. Following were present: : Joint Development Commissioner, KASEZ.

1. Shri. Marut Tripathi : Deputy Commissioner of Customs, Rep. of Commissioner of Customs, Kandla.
2. Shri Rajesh Dahiya : Manager R. M., DIC, Bhuj (Video Conferencing mode).
3. Shri. Bharat Nakum : Income Tax Officer, Rep. of Joint Commissioner of Income Tax, Gandhidham.
4. Shri. Mohanram : Deputy Development Commissioner, KASEZ (Special Invitee)
5. Shri. Himanshu Gunawat : Deputy Commissioner of Customs, KASEZ (Special Invitee)
6. Shri. Bhanu Jain Absentees:-
7. Director (Banking)
8. SDM
9. DGFT of the minutes of last meeting (208thUAC) 209.1 Review/Confirmation of the Approval Committee:- Minutes of the last meeting of Unit Approval Committee were confirmed. 1

Minutes of the 209th Unit Approval Committee Meeting of Kandla SEZ held on 209.1 NEW UNIT APPLICATION AGENDA ITEM NO. 209.1.1 Application for setting up of a Manufacturing Unit in KASEZ namely M/s. Jindal Textile Industries Pvt. Ltd., E-l, Industrial Area, Near Old Court, Panipat, Haryana. A proposal has been submitted by M/s. Jindal Textile Industries Pvt Panipat, Haryana for setting up a unit in Kandla SEZ for Ltd., manufacturing activity. Shri Navnish Mittal, General Manager along with Shri Ashwani Goyal, Authorised Representative of the company explained the proposal. Shri Navnish stated that their proposal was deferred in the last UAC meeting with direction to submit BRC’s for the F.Y. 2022-23 and 2023-24, brief write up of M/s. Jindal Woollens Pvt. Ltd. with regard to sale/transfer of the said company along with audited balance sheets for the year 2022-23 and also drawing/layout plan of the proposed manufacturing activity which they have submitted & further stated that M/s. Jindal Textile Industries Pvt. Ltd. was established in Nov’22 and hence the sales figures for the F.Y. 2022-23 is for two months amounting to Rs. 29.75 crores and for F.Y. 2023-24 for the whole year sales figures was Rs. 222.02 crores & hence there is major difference in two years sales figures. He further stated that M/s. Jindal Woollen Industries Ltd. and M/s. Jindal Textile Industries Pvt. Ltd. both the said units are presently working and M/s. Jindal Woollen Industries Ltd. is in existence for clearing the stock and disposal of land & building Director is common in both the companies. Regarding trade receivable, he clarified that export proceeds are received by them in 60-90 days’ time and all the outstanding trade receivables are received by the which are already reflecting in the Balance Sheet submitted by them. He further requested to consider their application for setting up of manufacturing unit in KASEZ. now as one The Committee perused the Chartered Accountant certificate for purchase of plant & machinery submitted by the unit along with the Audited Balance Sheet for the financial year 2022-23 & 2023-24 and noticed that there is difference in the list of plant & machinery and its value and asked the unit representatives about the differences. In reply, Shri Navnish stated that the details submitted in Chartered Accountant certificate includes Invoice value-wise including GST of Plant & Machinery and the Balance Sheet figures shows Plant & Machinery without GST 8s hence the difference. He further stated that in the Chartered Accountant certificate the Plant & Machinery details includes only purchased from M/s. Jindal Woollen Industries Ltd. whereas the Balance Sheet details includes the plant & machinery purchase from other supplies also apart from M/s. Jindal Woollen Industries Ltd. The Committee directed the unit representatives to submit the details of plant & machinery in tabular form showing the co­ relation of plant & machinery between the companies. 2

Further, with regard to GSTIN of both the companies in the same premises, the Committee directed the DC office to write to the GST Commissionerate for their perusal. The Approval Committee after due deliberation decided to approve the proposal for setting up a manufacturing unit and subject to applicant furnishing details of production value for 5 years and also subject to submission of details of plant & machinery showing co-relation of plant & machinery purchased from M/s. Jindal Woollen Industries Ltd. This approval is also subject to standard terms and conditions as under: Any restrictions on import/export of manufacturing items and its raw materials will apply. None of the items which are restricted or prohibited will be allowed to be manufactured/imported and any restrictions on import/export of any items will apply unless specifically permitted by the UAC. 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. Further, the items will be subjected to the Policy Conditions specified in DGFT’s ITC HS Code wherever applicable. Further, the applicant will obtain registration/clearance/any other mandatory requirement prescribed under any Act/Rules from concerned agencies before undertaking of such activities. Further, the applicant will ensure the compliance of all guidelines, policies issued by any Ministry from time to time pertaining to the items approved in LoA. Further, the applicant 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. i) ii) iii) iv) v) vi) vii) AGENDA ITEM NO. 209.1.2 Application for setting up of a Manufacturing unit in KASEZ namely M/s. VISOK ENTERPRISES PRIVATE LIMITED, 442, Basement (FP), Mathura Road, Bhogal, Jungpura, South Delhi, New Delhi - 110 014. A proposal has been submitted by M/s. Visok Enterprises Private Limited, New Delhi for setting up a unit in Kandla SEZ for manufacturing activity. Shri Ajay Aggarwal, Director of the company explained the proposal. Shri Ajay stated that they are in petro chemical business since last more than 50 years and now to further expand their business they want to start manufacturing activity of granulated fertilizers as there is huge demand of 3

23.12.2024 at 11:00 hrs under the Chairmanship of Shri Dinesh Singh on fertilizers in foreign countries and they are also supplying their petro­ chemical raw materials to the fertilizer industry. He further stated that their proposal was deferred in the 207th UAC meeting with direction to submit detailed project report showing brief of manufacturing process along with photographs of plant & machinery proposed which they have submitted now and requested to consider their proposal for manufacturing of granulated fertilizers of various combinations. The Committee asked the Director of the company about the investment proposed and the source of funds and employment proposed for the said project. In reply, Shri Aggarwal stated that the project cost for the proposed manufacturing activity will be around Rs. 10 crores out of which 50% i.e. Rs. 5 crores will be from Directors capital and reserves & surplus and balance will be bank loan. He further stated that they propose to give employment to around 150 people during gestation period which will be later on increased to about 200 people. The Committee further asked the Director of the company about the land requirement 86 greenbelt norms required for such industry and their annual production capacity for the proposed manufacturing activity. In reply, Shri Aggarwal stated that they will require about 5 acres land for the proposed project with provisions of greenbelt and their production capacity will be 6000-7000 MT per month. The Committee directed the Director to submit layout plan for the proposed manufacturing activity. The Committee noted from the ITR submitted by the applicant that the ITR of both the Directors are about Rs. 29 lakhs and then how they going to finance Rs. 5 crores in their proposed project. In reply, Shri Aggarwal stated that they are having joint family business 86 joint groups engaged in various business in the southern part, northern part 8& also central part of India and as a joint family business, they will source funds from their own capital and from their family businesses. Regarding finance from bank he further stated that they are having talks with the bankers and once the project in KASEZ is approved, they will approach their bankers for finance. are proposal for setting up a manufacturing unit except item at Sr. No. 16 of the raw materials list of the Agenda as the item at Sr. No. 2 & 16 one 8b the same and subject to furnishing drawing/layout plan of the proposed manufacturing activity. This approval is also subject to standard terms and conditions as under: are i) Any restrictions on import/export of manufacturing items and its rawr materials will apply. allowed to be manufactured/imported and any restrictions ii) on 4

import/export of any items will apply unless specifically permitted by the UAC. 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. Further, the applicant will obtain registration/clearance/any other mandatory requirement prescribed under any Act/Rules from concerned agencies before undertaking of such activities. Further, the applicant will ensure the compliance of all guidelines, policies issued by any Ministry from time to time pertaining to the items approved in LoA. Further, the applicant 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. iii) iv) v) Vi) vii) AGENDA ITEM NO. 209.1.3 Application for setting up of a Manufacturing unit in KASEZ namely M/s. Navdurga Tradex (OPC) Pvt. Ltd, Office No.4, First Floor, Plot No.25, Sector No. 8, Gandhidham-Kutch. A proposal has been submitted by M/s. Navdurga Tradex (OPC) Pvt. Ltd., Gandhidham, Kutch for setting up a unit in Kandla SEZ for manufacturing service activity. Shri Hitesh Thakker, Director of the company explained the proposal. Shri Thakker stated that he is into the business of logistics since last 10 years and now he proposes to go into setting up a manufacturing unit in KASEZ for chemical and allied products and their main focus is into manufacturing of industrial oil & lubricants. The Committee noted that the applicant has not followed the statutory compliance required for setting up a unit in KASEZ and has not submitted Audited Balance Sheet of the Director/company so as to ascertain as to whether the applicant is capable of undertaking manufacturing unit in KASEZ. Further, the Committee asked the Director as to whether they have GST registration for their company. In reply, Shri Thakker stated that they have not taken GST registration of their company as the company is established in Jun’24 only. Further, Committee also noted that their proposal for setting up manufacturing, trading and warehousing unit was rejected by the UAC in its 206th meeting held on 30.09.2024 as the Committee noted that the manufacturing process was not explanatory in nature and unit representative was also not able to explain how the finished products are coming into the existence by using what kind of specific raw materials. Now also the applicant has submitted fresh proposal for 5

on manufacturing activity and there are no additional inputs been provided by the applicant in the present proposal and the Committee does not find any merits in the present proposal as the Director has no experience in the manufacturing field. Therefore, the Approval Committee after due deliberations decided to reject their proposal for setting up manufacturing unit in KASEZ. AGENDA ITEM NO. 209.1.4 Application for setting up of a Trading unit in KASEZ namely M/s. Oswal Polymers Unit-II (Division of Oswal Agricomm Pvt. Ltd), Office No.4 8c 11,12, Sector-2, Kandla Special Economic Zone, Gandhidham- Kutch. A proposal has been submitted by M/s. Oswal Polymers Unit-II (Division of Oswal Agricomm Pvt. Ltd), KASEZ, Gandhidham for setting up a unit in Kandla SEZ for Trading activity. No representative of M/s. Oswal Polymers Unit-II (Division of Oswal Agricomm Pvt. Ltd) appeared before the Committee to explain the proposal. The applicant vide letter dated 23.12.2024 has shown their inability to attend the UAC meeting due to an urgent travel plan and not to take up the proposal for setting up unit at KASEZ in the current UAC meeting. Therefore, the Approval Committee after due deliberation decided to defer their proposal. AGENDA ITEM NO. 209.1.5 Application for setting up of a Manufacturing, unit in KASEZ namely M/s. Tokyo Plast International Ltd (Unit-II), Plot No. 363/1, (1,2,3), Shree Ganesh Industrial Estate, Kachigaum Road, Daman (U.T). A proposal has been submitted by M/s. Tokyo Plast International Ltd (Unit-II), Daman (U.T) for setting up a unit in Kandla SEZ for Manufacturing activity. Shri Priyaj Haresh Shah, Director along with Shri Santosh Sarode, Authorised Representative of the company explained the proposal. Shri Shah stated that they have established their unit since last more than 20 years for insulated products such as casseroles & lunch boxes and the first plant was set up in Daman and then they have started a manufacturing unit in KASEZ in 2007 for Ice Boxes and other items. He further stated that they have generated NFE of about Rs. 350 crores from their Kandla plant and are exporting to about 65 countries. The Committee noted that the applicant has not submitted all the details required in the application form & project report such as Foreign Exchange balance sheet showing figures in US Dollar, annual production 6

capacity & production value for 5 years, layout plan of the proposed manufacturing unit, ITRs of its Directors and also there is mismatch in the figures submitted in the application form and project report with regard to proposed employment and directed the Director to submit the application form duly completed along with revised project report to enable the Committee to take a decision in their application for setting up a manufacturing unit in KASEZ. Therefore, the Approval Committee after due deliberation decided to defer their proposal with direction to the applicant to submit their application form duly completed in all aspects along with revised project report mentioning the finished goods, raw materials, brief manufacturing flow chart of each finished goods, source of finance along with working capital details. AGENDA ITEM NO. 209.1.6 Application for setting up of a Manufacturing Unit in KASEZ namely M/s. Triworld Fashions Ltd., D-148, Phase-IV-A, Focal Point, Ludhiana- Punjab. A proposal has been submitted by M/s. Triworld Fashions Ltd., Ludhiana-Punjab for setting up a unit in Kandla SEZ for Manufacturing activity. Shri Pawan Garg, Authorised Representative of the company explained the proposal. Shri Garg stated they are having a manufacturing unit in Ludhiana for knitted and readymade garments catering to domestic market having capacity of 10,000 pieces per day & 4 storey building consisting of 2500 sq. ft. area and now to expand their business they propose to set up a manufacturing unit in KASEZ for shirts, woven shirt/trousers 8& jackets. The Committee asked the unit representative about the source of funds for the proposed project in KASEZ. In reply, Shri Garg stated that the source of funds will be from share capital & internal accruals of the company and also from friends & relatives. The Committee directed the unit representative to furnish documents supporting source of funds/financial strength/net worth certificates of all the Directors/company along with Audit Balance Sheet of the company with all enclosures. proposal for setting up a manufacturing unit subject to furnishing documents related to net worth of all the Directors/company with all enclosures as well as working capital of the project. This approval is also subject to standard terms and conditions as under: 7

Minutes of the 209* Unit Approval Committee Meeting of Kandla SEZ held on i) Any restrictions on import/export of manufacturing items and its raw materials will apply. allowed to be manufactured/imported and any restrictions on import/export of any items will apply unless specifically permitted by the UAC. 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. Further, the applicant will obtain registration/clearance/any other mandatory requirement prescribed under any Act/Rules from concerned agencies before undertaking of such activities. Further, the applicant will ensure the compliance of all guidelines, policies issued by any Ministry from time to time pertaining to the items approved in LoA. Further, the applicant 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. ii) iii) iv) v) vi) vii) 209.2 REQUEST FOR BROADBANDING/ITEM ADDITION AGENDA ITEM NO. 209.2.1 Permission to add items under the Trading Activity - Request of M/s. Apex Lubricant, KASEZ. M/s. Apex Lubricant., KASEZ is an approved unit with LoA No. KASEZ/IA/08/2009-10/2820 dated 10.06.2009 warehousing & trading activity subject to certain terms and conditions enumerated in the aforesaid Letter of Approval. as amended, for Now the said unit has requested for permission to add new items in their Trading activity. Shri Ashish Jani, Partner of the firm of the firm explained their proposal. Shri Jani informed that they are in KASEZ since 2009 for trading and warehousing of petroleum products & dealer of HPCL supplying petro products to foreign going vessels at Port & also to custom bonded warehouse & also into the business of transportation bunkering of IOCL with annual turnover of about Rs. 8 to 10 crores and now they wish to include one item fuel oil in their trading activity. proposal for addition of items in trading activity in their existing LoA and also subject to the following standard terms and conditions: 8

allowed to be traded 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. 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. Further, no DTA sale is allowed for the approved traded item. The above permission is also subject to further condition that the unit shall maintain separate accounts for trading and warehousing and earmark separate space for both the activities. Further, the unit will submit separate APRs for their trading and warehousing activity. Further, the unit will obtain registration/clearance/any other mandatory requirement prescribed under any Act/Rules from concerned agencies before undertaking of such activities. 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. 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. i) ii) iii) iv) V) Vi) vii) viii) ix) AGENDA ITEM NO. 209.2.2 Request for broad banding of manufacturing activity -Request of M/s Hindustan Oils Industries, KASEZ. M/s. Hindustan Oils Industries, KASEZ is an approved unit with LoA dated 08.08.2013 issued from F. No. KASEZ/IA/006/2013-14 for manufacturing activity of light solvents, fuel oil, light fuel oil, light viscosity base oil, high viscosity base oil, rubber process oil/residue only for crude oil processing, vaccum distillation for reclamation of used oil, lightol and lubricants automotive and industrial and for trading activity of lubricants, fuel oil, bitumen, transformer oil, other petroleum products, castor oil and base mineral oil SN-500, 350, 150 etc., as amended. Now the said unit has requested for broad banding of their manufacturing activity and has expressed their intention for manufacturing of new finished products and submitted list of finished goods and raw materials along with their ITC HS Code. 9

on Shri Narendra Nimbawat, Partner of the firm explained the proposal. Shri Nimbawat stated that they are holding LoA since 2013 for manufacturing activity of lubricant oils and other products & also trading activity and now they want include additional items which are all OGL items for exports in their manufacturing activity. The Committee noted that finished goods items proposed at Sr. No. 1 i.e. Thinner the ITC HS of the same is already there in their LoA and then why they want to include the item proposed at Sr. No. 1. In reply, Shri Nimbawat stated that they are having approval of light oil in their LoA and now they want to add Thinner also in the manufactured items and hence the request. The Committee further asked the partner of the firm that they have not submitted specific raw materials list in respect of each finished goods. In reply, Shri Nimabawat submitted the specific list of raw materials required for each finished products in the UAC meeting. He further stated that the existing plant & machinery will suffice and some modification will be done to undertake distillation work ranging from 160-250 degree of the proposed manufactured items. He further stated that the additional manufacturing activity will generate employment of about 10-12 persons and also generate additional turnover of about Rs. 4-5 crores. The Committee noted that though the unit has given raw material list and manufacturing process along with their proposal but the partner has submitted specific list of raw materials for each finished goods proposed during the UAC meeting and therefore the UAC decided to constitute a Committee to ascertain the details of specific raw materials submitted vis-a- vis the finished goods proposed. proposal for addition of items in manufacturing activity except item at Sr. No. 4 of the manufactured item list of the Agenda along with its raw materials except item at Sr. No. 5 of the raw materials list of the Agenda in their existing LoA subject to confirmation/report by the Committee that no discrepancy in the manufacturing process, raw materials used is observed and subject to payment of outstanding rental dues and also subject to standard terms and conditions: - i) Any restrictions on import/export of manufacturing items and its raw materials will apply. 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. ii) iii)

The above permission is also subject to further condition that the unit shall maintain separate accounts for manufacturing and trading and earmark separate space for both the activities with provisions of CCTV with sufficient longer duration of storage & other equipments. Further, the unit will submit separate APRs for their manufacturing and trading activity. Further, the unit will maintain separate stock register for manufacturing and trading which will be subject to regular checking by the KASEZ customs authorities. Further, the unit will ensure the compliance of all guidelines, Further, the unit will give an undertaking that they will comply with all the prescribed norms such as PESO, Fire NOC, etc. under any Act/Rules. proposed and its raw materials are falling under negative list and if the items are found in negative list, penal action will be initiated against them. iv) v) vi) vii) viii) ix) x) AGENDA ITEM NO. 209.2.3 Request for broad banding of additional items in manufacturing activity in their existing Letter of Approval No. KASEZ/IA/12/2019-20 dated 02.12.2019 for Manufacturing activity and Trading activity, as amended issued to M/s. K P Woven Private Limited, KASEZ. M/s. K P Woven Private Limited, KASEZ is an approved unit for manufacturing activity of FIBC PP Woven Bags Sacks/Jumbo Bags, PP Woven Sacks Small Bags, LLDPE Liner and Filler Cord and trading activity in KASEZ issued with Letter of Approval No. 12/2019-20 dated 02.12.2019 from File No. KASEZ/IA/12/2019-20/10595, as amended. Now the said unit has requested for broad-banding of additional items in manufacturing activity in their existing LoA and submitted of items to be manufactured along with their ITC HS Code. Shri Kishor Athanikar, Authorised Representative of the company appeared before the Committee to explain the proposal. Shri Athanikar stated that during the manufacturing of FIBC bags some reprocessed granules is generated from the side cutter which they again reuse it in the manufacturing and at sometimes due to some errors in manual process the said reprocessed granules cannot be used in their manufacturing and the same is required to be sold in the DTA on payment of applicable duty and 11

Minutes of the 209* Unit Approval Committee Meeting of Kandla SEZ held on requested to grant them permission for manufacturing of all types of plastic reprocessed granules. The Committee noted that the unit has not submitted specific ITC HS Code list for the proposed manufacturing activity and directed the unit representative to submit the specific list of items required for manufacturing activity along with specific ITC HS Code for each items. Therefore, the Approval Committee after due deliberation decided to defer their proposal with direction to the unit to submit specific list of items required for additional manufacturing activity alongwith specific ITC HS Code of each items proposed for manufacturing activity. AGENDA ITEM NO. 209.2.4 Addition of new items in their LoA for Trading and Warehousing Service Activity - Request of M/s. Krishna Enterprise, KASEZ. M/s. Krishna Enterprise, KASEZ is an approved unit with LoA No. 04/2020-21 dated 16.07.2020 for trading activity and warehousing activity subject to certain terms and conditions enumerated in the aforesaid Letter of Approval, as amended. service Now the said unit has requested for addition of new items in their LoA for Trading and Warehousing service activity and submitted list of items required for trading and warehousing activity. Shri Mahesh Matang, Proprietor of the firm appeared before the Committee to explain the proposal. Shri Matang stated that they wish to include 4 items in their trading and warehousing activity and requested to permit them trading and warehousing of additional items. proposal for addition of items in trading activity and warehousing service activity (subject to unit submitting KYC of their clients alongwith ITR of last 3 years on whose behalf they will warehouse goods) except item at Sr. No. 1 of the Agenda in their existing LoA subject to payment of outstanding rental dues and also subject to the following standard terms and conditions: i) allowed to be traded/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. In case of any discrepancy/mismatch between the above ‘Description of Goods’ as provided by the Unit 86 ‘Description of goods as per DGFT Import Policy’, the later will prevail. Further, no DTA sale is allowed for the approved traded items. ii) iii) 12

specified in DGFTs ITC HS Code wherever applicable. The above permission is also subject to further condition that the unit shall maintain separate accounts for trading and warehousing service activity and earmark separate space for all the activities with provisions of CCTV with sufficient longer duration of storage & other equipments. Further, the unit must ensure that they should have a tamper­ proof ERP/SAP/Tally system for their trading activity and warehousing activity. 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. Further, the unit will submit separate APRs for their trading and warehousing service. Further, the unit will maintain separate stock register for trading and warehousing service which will be subject to regular checking by the KASEZ customs authorities. Further, the unit will ensure the compliance of all guidelines, 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. iv) v) Vi) vii) viii) ix) X) xi) xii) AGENDA ITEM NO. 209.2.5 Enlargement of Manufacturing Activity (Addition of new products in unit’s LoA) - Request of M/s. R R Vibrant Polymers Ltd., KASEZ. M/s R R Vibrant Polymers Ltd., KASEZ is an approved unit for manufacturing of Recycled Polymer Pellets of LDPE/HDPE/PP/PVC/ABB and Agglomerates in Kandla Special Economic Zone vide Letter of Approval No. KFTZ/IA/ 1655(A)/96 dated 27.11.1996, as amended. The Committee noted that the request of M/s. R R Vibrant Polymers Ltd., KASEZ for enlargement of manufacturing activity (addition of new products in unit’s LoA) was deferred in the last UAC with direction to the unit to submit complete proposal with regard to additional items & export potential and as to whether they have achieved the required minimum quantum of export obligations required to be achieved by such units and also subject to payment of outstanding rental dues. 13

on Now the unit has submitted that as on 31st Oct, 24 they have a surplus residual DTA sales entitlement of far exceeding over 3000 Tons i.e. yet to be consumed and has excessive achievement of Physical export far exceeding the target and enlargement for manufacturing value added products will only pave way for achievement of future export and NFE targets as per their LOA. Shri Apar Agarwal, Director alongwith Shri Deepak Patel, Authorised Representative of the company appeared before the Committee to explain the proposal. Shri Agarwal stated that they have cleared pending rental dues and submitted copy of the same to the Committee and further requested to permit them addition of value added products in their manufacturing LoA. The Committee noted that the SEZ Section, Department of Commerce, New Delhi vide their letter dated 23.09.2024 had issued clarification that requests for broad-banding may be allowed for plastic or used clothing recycling units, subject to the conditions that such units shall not set up any sub-units, and all transactions of the unit shall be regulated through a single bank account, along with adherence to other conditions as stipulated under Rule 18(4A) and DoC’s extant policy in this regard. proposal for enlargement of manufacturing activity (addition of new products) subject to unit submitting correct item description & ITC HS code for the item proposed at Sr. No. 2 of the Agenda in their existing LoA subject to payment of outstanding rental dues and also subject to standard terms and conditions: - i) Any restrictions on import/export of manufacturing items and its raw materials will apply. 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. Further, the unit will ensure the compliance of all guidelines, Further, the unit will ensure that they shall not set up any sub-units and all the transactions of the unit shall be regulated through a single bank account along with adherence to other conditions as stipulated under Rule 18(4A) and DoC’s extant policy in this regard. ii) ml iv) v) Vi) 14

proposed are falling under negative list and if the items are found in negative list, penal action will be initiated against them. vii) AGENDA ITEM NO. 209.2.6 Request of M/s. Royal Petro Specialities Pvt. Ltd., KASEZ for Addition of new items in their LoA for Trading Activity. M/s Royal Petro Specialities Pvt. Ltd., KASEZ is an approved unit for Manufacturing Activity of Automotive and Industrial lubricants, brake fluid, petroleum jelly, etc. and also trading activity vide LoA No. KASEZ/IA/026/2006-07 dated 12.12.2006, as amended from time to time. Now the said unit has requested for addition of new items in their LoA for Trading activity and submitted that the list of items for trading activity. Shri Vishal Ved, Director along with Shri Jigar Gohel, Internal Auditor of the company appeared before the Committee to explain the proposal. Shri Ved stated they are into manufacturing of automotive & lubricating oils and also trading items and now they want to include some items in their trading activity and requested to permit additional items for trading activity. proposal for addition of 04 items in trading activity in their existing LoA subject to payment of outstanding rental dues and also subject to the following standard terms and conditions: F. No. allowed to be traded 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. 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. Further, no DTA sale is allowed for the approved traded item. The above permission is also subject to further condition that the unit shall maintain separate accounts for manufacturing and trading and earmark separate space for both the activities. Further, the unit will submit separate APRs for their manufacturing and trading activity. i) ii) iii) iv) V) Vi) vii) 15

on viii) Further, the unit will ensure the compliance of all guidelines, 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. ix) AGENDA ITEM NO. 209.2.7 Request of M/s. Skylink Petrochemicals Pvt. Ltd., KASEZ for Addition of new items in their LoA for Warehousing service activity and addition of Trading Activity. M/s. Skylink Petrochemicals Pvt. Ltd, KASEZ is an approved unit for manufacturing activity and warehousing service activity vide Letter of Approval F.No. KASEZ/IA/15/2022-23/7422-25 dated ' 15.11.2022, as amended. Now the said unit has requested for addition of items for warehousing service activity and addition of trading activity in their existing LoA. Shri Naval Kishor Aggarwal, Authorised Representative of the company appeared before the Committee to explain the proposal. Shri Aggarwal stated that they propose to include 3 items in their warehousing activity and also addition of trading activity of 18 items. The Committee noted that the unit has been granted manufacturing and warehousing activity permission and the unit has started its warehousing activity and not started the manufacturing activity and asked the unit representative to submit the reasons for not starting manufacturing activity as almost two years have elapsed after granted of LoA dated 15.11.2022. In reply, Shri Aggarwal stated that delay has occurred as 6 months time has lapsed for taking possession of the plot and another 6 months’ time has lapsed in getting permission from Pollution Control Board/Explosive licence permission and now almost 90% construction work have been completed and they have installed 22 underground tanks and 4 over ground tanks and 90% distillation work has been done and work of cooling tower is under progress and they are expecting to commence their manufacturing activity by February’25. The Committee further asked the unit representative as to whether they have demarcated the area for manufacturing, warehousing and trading activity. In reply, Shri Aggarwal stated that they have separately demarcated the area for manufacturing and warehousing activity as taken two separate PESO licence for manufacturing and warehousing activity separately. Regarding, trading activity he stated that the trading activity is not approved

in their LoA and now only they have requested for inclusion of trading activity and they will demarcate separate area for trading activity once approval is granted. proposal for addition of items warehousing service activity except item at Sr. No. 2 of the warehoused goods of the Agenda(subject to unit submitting KYC of their clients alongwith ITR of last 3 years on whose behalf they will warehouse goods) and addition of trading activity except items at Sr. No. 5, 7, 14, 16 fit 17 of the traded goods of the Agenda in their existing LoA and subject to physical verification regarding the compliance with regard to physical demarcation of manufacturing, trading and warehousing service activities with separate entry & exit gates for each activity and also subject to the following standard terms and conditions: allowed to be traded/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. 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. Further, no DTA sale is allowed for the approved traded items. The above permission is also subject to further condition that the unit shall maintain separate accounts for manufacturing, trading and warehousing service activity and earmark separate space for all the activities with provisions of CCTV with sufficient longer duration of storage & other equipments. Further, the unit must ensure that they should have a tamper­ proof ERP/SAP/Tally system for their trading activity and warehousing activity. 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. Further, the unit will submit separate APRs for their manufacturing, trading and warehousing service activity. Further, the unit will maintain separate stock register for manufacturing, trading and warehousing service which will be subject to regular checking by the KASEZ customs authorities. i) ii) iii) iv) v) vi) vii) viii) ix) X) 17

on xi) Further, the unit will ensure the compliance of all guidelines, 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. 209.2.8 Addition of new items in their LoA for Trading and Warehousing Activity - Request of M/s. Star World, KASEZ. M/s. Star World, KASEZ is an approved unit for Trading and Warehousing service activity for the items viz. Paper, threading bar, stationery item, Hardware item, RMG, Paints & Varnish etc. in KASEZ vide Letter of Approval No. KASEZ/IA/17/2022-23/7852-55 dated 28.11.2022, as amended. xii) Now the said unit has requested for addition of new items in their LoA for Trading activity and warehousing activity and submitted the list of items for trading and warehousing activity. Shri Syed Salim, Authorised Representative of the firm explained the proposal. Shri Salim stated that they have requested for additional items in trading and warehousing activity and requested to permit additional items in their LoA. The Committee noted that the unit has been granted trading of 49 items and warehousing of 24 items in their LoA and asked the unit representative as to whether they have undertaken the activity for all the items approved in their LoA for trading and warehousing activity and also as to whether they have demarcated the area separately for trading and warehousing activity, in reply, Shri Salim stated that they have done authorised activity for some items only and regarding demarcation he stated that for trading and warehousing they have made two partition i.e. physical barrier for trading and warehousing activity. The Committee further noted that the unit has not submitted the KYC and ITR of their clients on whose behalf they are going to undertake warehousing activity and directed the unit representative to submit the same. Therefore, the Approval Committee after due deliberation decided to defer their proposal with direction to the unit to submit KYC and ITR of their clients on whose behalf they will warehouse the goods and also submit the list of items for trading and warehousingi activity for which they have not 18

undertaken any activity till date to exonerate the said items approved in their LoA for trading & warehousing activity and also detailed layout plan showing the area demarcated for trading and warehousing activity for which physical verification of the premises will be undertaken by DC office. 209.3 MISCELLANEOUS ITEMS AGENDA ITEM NO. 209.3.1 Visit Report dated 21.11.2024 of the Committee with regard to the Intimation of change in Partnership deed of M/s Vimal Trading, KASEZ. M/s Vimal Trading, Shed No. 398, AS-IV, Sector-1, KASEZ, is an approved unit for trading /warehousing service activity. The unit has been granted Letter of Approval dated 31.01.2017, issued vide F. No. KASEZ/IA/21/2016-17, as amended. The Committee noted that the request of M/s. Vimal Trading, KASEZ for change in partnership of the firm was deferred in the 207th UAC meeting held on 28.10.2024 with direction to the DC office to depute a team for physical verification with regard to physical demarcation of trading and warehousing activities with separate entry & exit gates for each activity. Accordingly, DC office vide Office Order dated 19.11.2024 has constituted a team of 3 officers to visit the unit’s premises for physical verification with regard to physical demarcation of trading & warehousing activities with separate entry & exit gates for each activity with provisions of CCTV and other equipments. Accordingly, the team so constituted has visited the unit premises on 21.11.2024 and submitted its Visit Report dated 21.11.2024 with regard to physical demarcation of trading & warehousing activities with separate entry & exit gates for each activity with provisions of CCTV and other equipments wherein as per layout plan submitted by the unit it was found that trading area was filled with wooden pallets. However, they stored liquors in warehousing area and on enquiry by team members about the same, the unit representative stated that they have been storing liquors in warehousing area and at present they have been dealing with trading of liquor items only and no warehousing activity has been undertaken since long time. Further, there was separate demarcation of both the trading and warehousing activity however the main entry and exit is common for both the activities. It was found the premises was under CCTV camera installed at various points. Shri Kishor Chavda, Authorised Representative of the firm along with Shri Ajay Sinh Zala and Shri Vijaysinh Zala, Partners being inducted in the firm and appeared before the Committee to explain the proposal. 19

on The Committee asked the unit representative about the activities being undertaken by them and as to why they are not maintaining the trading and warehousing activity area as per the approved layout plan. In reply, Shri Chavda stated that at the time of approval of their layout plan they have demarcated the trading and warehousing area separately with partition however later on they have included trading of liquor in their LoA which requires a facility to be created for storage of liquor and allied items with regard to hygiene, temperature control and security arrangements, etc. and as such they have utilized the warehousing area earmarked for trading of liquor and allied items. He further stated that they have already earmarked the area for warehousing activity in their premises. The Committee directed the unit representatives to submit revised layout plan of their premises and thereafter their unit premises will be re-visited for verification. The Committee noted that Department of Commerce vide Instruction No. 109 dated 18.10.2021 has issued guidelines regarding change of name, change of shareholding pattern, business transfer arrangements, court approved mergers and demergers, change of constitution, wherein the change of Directors, etc. may be undertaken by the Unit Approval Committee (UAC). Therefore, the Approval Committee after due deliberation decided to take on record the proposal of change in partnership of the firm subject to payment of outstanding rental dues 85 subject to submission of Indemnity bond & also subject to submission of an Affidavit/Undertaking that no Customs/DRI and any other Govt. Department case is booked against the unit and fulfilment of conditions as stipulated vide Instruction No. 109 dated 18.10.2021. The Committee also directed the unit representative to submit revised layout plan of their premises showing demarcation of trading and warehousing area and further directed the DC office to depute a team for physical verification of unit’s premises for physical demarcation of trading and warehousing activities and then permission letter for change in Partners will be issued only after clear report received with regard to demarcation of trading and warehousing area. The Committee also directed to forward the case of change in Name/Constitution/partnership/directorship to the Income Tax Department for necessary action at their end. AGENDA ITEM NO. 209.3.2 Intimation of change in Partnership deed of M/s Texwool Spinners and Clothing, KASEZ M/s Texwool Spinners and Clothing, KASEZ is an approved unit for manufacturing activity of woollen & synthetic yarn vide LoA No. Letter of Approval No. KASEZ/IA/10/2004-05/2755 dated 22.06.2004, as amended. 20

Now the said unit has intimated regarding change in partners of the firm wherein one Partner has retired from the firm and two new Partners have joined the firm and submitted copy of Supplementary Deed dated 01.07.2024. The unit has submitted copy of Form-G issued from Registrar of Firms regarding change in partnership deed of the firm and details of financial consideration made by the incoming partners along with detailed bank statement. Shri Sarfaraz Bara, Partner of the firm along with Shri Khurshid Bara and Shri Riyaz Ahmed, Partners being inducted in the firm appeared before the Committee to explain the proposal. Shri Sarfaraz stated that one of the partner has retired and two new partners have been induced in the firm & also submitted the details of financial consideration made by the incoming partners and also Form G issued by Registrar of Firms and requested to take the change of partners in record. The Committee noted that Department of Commerce vide Instruction No. 109 dated 18.10.2021 has issued guidelines regarding change of name, change of shareholding pattern, business transfer arrangements, court approved mergers and demergers, change of constitution, wherein the change of Directors, etc. may be undertaken by the Unit Approval Committee (UAC). Therefore, the Approval Committee after due deliberation decided to take on record the proposal of change in partnership of the firm subject to submission of Indemnity bond &subject to submission of an Affidavit/Undertaking that no Customs/DRI and any other Govt. Department case is booked against the unit and fulfilment of conditions as stipulated vide Instruction No. 109 dated 18.10.2021. The Committee also directed to forward the case of change in Name/Constitution/partnership/directorship to the Income Tax Department for necessary action at their end. AGENDA ITEM NO. 209.3.3 Request for addition of items under the warehousing service activity - Request of M/s. Flamingo Logistics, KASEZ. The Committee noted that M/s. Flamingo Logistics, KASEZ has requested for permission for warehousing activity of additional items. Shri Kiran Singh Kochhar, Partner of the firm explained their proposal. Shri Kochhar informed that they have requested for permission for 04 items in warehousing activity. He further stated that two items proposed for warehousing are surgical gloves - veterinary and normal gloves and other two items are plastic items. 21

on The Committee asked the partner as to whether they have to obtain registration from concerned department for warehousing of surgical gloves. In reply, Shri Kochhar stated that the surgical gloves are for medical purposes only and no such registration is required from any department. The Committee directed the partner to submit a declaration to this effect. 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 except items at Sr. No. 3 6b 4 of their proposal, subject to payment of outstanding rental dues and also subject to the unit fulfilling NFE criterion and subject to unit submitting KYC of their clients alongwith ITR of last 3 years on whose behalf they will warehouse goods and also subject to following conditions: i) 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. 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. 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. 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. Further, the unit will ensure the compliance of all guidelines, 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. ii) iii) iv) v) vi) vii) viii) 22

AGENDA ITEM NO. 209.3.4 Permission to warehouse goods on behalf of Overseas/DTA client - Request of M/s. Harmann Lever Exim, KASEZ. The Committee noted that M/s. Harmann Lever Exim, KASEZ has requested for permission for warehousing activity of additional items. The Committee further noted that their proposal for addition items in warehousing was rejected in the 207th UAC meeting held on 28.10.2024 as the Committee noted that ITR of their DTA client submitted was very meagre and how the unit will be able to import the goods of such high value with such financial credentials and directed the unit to first clear their outstanding rental dues and then come up for additional items with complete and valid KYC details of their client. Further, the Committee also noted that there are no additional inputs provided by the unit in the present proposal & also the unit is unable to clear the outstanding rental dues till date. Therefore, the Approval Committee noted that since it has already rejected their proposal in the last UAC and as such the UAC is not taking any decision with regard to the present request of the unit for additional items in warehousing activity as the unit has submitted the same proposal that was rejected in the last UAC. Further, the unit has not cleared the rental dues as yet. AGENDA ITEM NO. 209.3.5 Addition of items in Warehousing service Activity in their existing LoA- Request of M/s. Milak Warehouse, KASEZ. The Committee noted that M/s. Milak Warehouse, KASEZ has requested for permission for warehousing activity of additional items. Shri Vivek Milak, Partner of the firm explained their proposal. Shri Milak informed that they have requested for permission for warehousing of additional items. He further stated that they are into manufacturing, trading and warehousing of food, cosmetics & other items with FDA approval and now they want to add some more products in their warehousing activity. 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 the unit fulfilling NFE criterion and subject to unit submitting KYC of their clients alongwith ITR of last 3 years on whose behalf they will warehouse goods and also subject to following conditions: 23

on i) 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. 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. 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. Further, with respect to warehousing of items for human consumption/food preparation items the same is allowed subject to compliance of FSSAI norms and all other statutory compliance viz. NOC from Ministry of Health and other concerned agencies before such clearance. 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. Further, the unit will ensure the compliance of all guidelines, 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. ii) iii) iv) V) Vi) vii) viii) ix) AGENDA ITEM NO. 209.3.6 Revisit the LoA granted to the M/s. B.V.H Manufacturing India Pvt Ltd., KASEZ, Gandhidham in view of the letter issued from F.No.F.2/6/2019-SEZ dated 26.11.2024 issued from the Department of Commerce (SEZ Section). The Committee was suitably briefed that a reference has been made to the DoC on 10.04.2023 and followed by reminder letter dated 18.04.2024 for guidance as to whether the LoA issued by the Development Commissioner, KASEZ to M/s. B.V.H. Manufacturing India Pvt. Ltd. is in accordance to the provisions of SEZ Act & SEZ Rules or it falls under the purview of Rule 18(4)(c) of the SEZ Rules, 2006and the reply from the DoC on the issue of grant of LoA to the unit is still awaited. Therefore, the Committee directed the DC office to refer the matter again to DoC by way of reminder and 24

suitable decision on the issue may be taken after reference/reply is received from the DoC. AGENDA ITEM NO. 209.3.7 Permission for supplies of Nicotine pouches to duty free shops located at International Airports - Request of M/s. Kamna Tobacco Pvt. Ltd., KASEZ. M/s. Kamna Tobacco Pvt. Ltd., KASEZ is an approved unit for manufacturing activity of Spit Tobacco, Gutkha, Pan Masala, Filter Khaini, Zarda, etc. vide LoA No. 16/2016-17 dated 22.12.2016, as amended. Further, their LoA was further broad-banding vide letter dated 23.08.2021 for Manufacturing activity of White Tobacco products with Nictotine, Nicotine Snus/White Tobacco, Nictotine pouches made from TDN/ Nicotine pouches made from TFN. Now the said unit has requested for permission for supplies of Nicotine pouches to duty free shops located at International Airports. Shri Pankaj Kumar, Authorised Representative of the firm explained their proposal. Shri Pankaj informed that they have received confirmed orders from M/s. NV Lifestyles Pvt. Ltd. for bonded warehouse of M/s. Kuber Sanjivani Pvt. Ltd., Delhi for supply of Nicotine Pouches to their duty­ free shops located at International Airport in Mumbai and Delhi. The Committee noted that the PM Section of Customs, KASEZ has submitted its reply vide U. O. Note dated 20.12.2024 wherein the Customs Section was of the view that the unit may be granted permission to supply of nicotine pouches to public bonded warehouse of M/s. Kuber Sanjivani Pvt. Ltd., Delhi for supply to duty free shops located at Mumbai International Airport subject to the conditions as per SEZ Act and SEZ Rules read with the provisions of Foreign Trade Policy and also subject to certain conditions. The Deputy Commissioner of Customs, KASEZ informed the unit representative that they have to submit 2 warehousing certificate one from the public bonded warehouse and other from the duty free shops within 45 days from the date of clearance of goods from KASEZ and submit the copies of re-warehousing certificate to the KASEZ Customs department within the stipulated time failing which appropriate action will be initiated against the unit. The Approval Committee after due deliberation decided to permit the unit for supply of Nicotine pouches to public bonded warehouse/duty free shops located at International Airport in Mumbai and Delhi subject to quantity restriction of 5,000 cans per month only of Nicotine pouches, subject to payment of outstanding rental dues and also subject to standard terms and conditions: 25

Minutes of the 209* Unit Approval Committee Meeting of Kandla SEZ held on i) The Nicotine Pouches shall be supplied ONLY to the bonded warehouse of M/s. Kuber Sanjivani Pvt. Ltd., located at Khasara No. 1281-1282, Kahashera Village, Delhi, exclusively for supply to the duty-free shop located at International Airport in Mumbai & Delhi in strict compliance to Rule 46(13) of the SEZ Rules, 2006 read with Instruction No. 63 dated 10.08.2010 issued by the Ministry of Commerce & Industry. No DTA sale of the goods is allowed in any case whatsoever. If the subject goods are found to be sold in the DTA, penal action as per the applicable laws shall be initiated against them. The unit must submit re-warehousing certificate for the public bonded warehouse as per Rule 46(13) read with Instruction No. 63 dated 10.08.2010 within the mentioned timeline. Further unit also must submit proof of receipt of the subject goods at duty-free shops, located at International Airport in Mumbai & Delhi, issued by the jurisdictional Customs Authority. ii) iii) TABLE AGENDA ITEM NO. 209.4.1 Cancellation of Letter of Approval granted to M/s. Aditya Exports, a unit for manufacturing, trading and warehousing activity, KASEZ. M/s. Aditya Exports, KASEZ is KASEZ/IA/1909/2002-03 dated 03.03.2003 for trading activity of Agro Products, Plastic Products, Chemicals, Dies, Textiles, Utensils and all items except prohibited, canalized & restricted items as per amended from time to time. The units LOA was broad-banded various times. The unit is having valid LoA for Warehousing, Trading and Manufacturing Activity and the same is valid is till 21.01.2024. issued LoA from F.No. The Additional Director General, Directorate of Revenue Intelligence, Ludhiana Zonal Unit, Ludhiana has forwarded a letter dated 04.05.2023 issued from F. No. DRI/LDZU/856/INT-NIL/ENQ-15/2023/400 to this office informing that DR1, LDZU is investigating a case corresponding to M/s. Aditya Exports, KASEZ and an intelligence was developed that M/s. Aditya Exports, a warehousing unit in KASEZ has indulged in import of Black Pepper by mis-declaring it of Afghanistan origin thereby wrongly claiming exemption of Customs Import duty while clearing the same into DTA. Further, the Ludhiana Zonal Unit had requested this office to initiate the procedure for cancellation of the Letter of Approval granted to M/s. Aditya Exports, KASEZ under Section 16 of the SEZ Act, 2005. Based on the report received from the Additional Director, Directorate of Revenue Intelligence, Ludhiana Zonal Unit, Ludhiana, DC office had issued Show Cause Notice No. KASEZ/IA/1909/2002-03/Vol.I dated 22/26.05.2023 to M/s. Aditya Exports, KASEZ for indulging in import of black pepper by mis-declaring it to be of Afghanistan origin thereby wrongly 26

claiming exemption of Customs Import duty while clearing the same into DTA and has contravened and violated the conditions of LoA, BLUT and provisions of SEZ Rules, 2006. The Committee deliberated on the issue and noted that the unit has been indulged in import of black paper by mis-declaring it of Afghanistan origin thereby wrongly claiming exemption of customs import duty on the goods and also at the time of clearance of goods, further, it has been noticed that the unit have submitted forged bank guarantee & also fake mail of bank that the bank has issued the said bank guarantee for clearance of their goods in DTA and also the Commissioner of Customs, Kandla has adjudicated the said DRI case imposing penalty on the unit and others who are associated with the firm. Thus, this is a fit case for cancellation of their LoA under Section 16 of the Act for indulging in in import of black pepper by mis-declaring it to be of Afghanistan origin thereby wrongly claiming exemption of Customs Import duty while clearing the same into DTA and violation of terms and conditions of LoA, BLUT and provisions of SEZ Rules, 2006. Therefore, the Approval Committee after due deliberation decided to cancel the LoA issued to the unit and authorised the Development Commissioner, KASEZ being the Adjudicating Authority to adjudicate the Show Cause Notice dated 22/26.05.2023 issued to the unit and the DC office will comply to any outcome of the Court/any other forum which will arise in future with regard to clearance of the subjected goods by the unit. Further, Approval Committee directs the Specified Officer of the KASEZ Customs to submit the detailed report to DC Office alluding the recent developments as elaborated by him during the UAC meeting. TABLE AGENDA ITEM NO. 209.4.2 Violation of terms and conditions of LoA and BLUT and provisions of SEZ Act, 2005 fit SEZ Rules, 2006 by some of the KASEZ units The Committee was briefed that the following units have indulged in unauthorised operations and have violated the terms and conditions of the Letter of Approval and BLUT and provisions of SEZ Act, 2005 & SEZ Rules, 2006 and accordingly the Deputy Commissioner of Customs, KASEZ has forwarded the Demand cum Show Cause Notice to the Commissioner of Customs, Kandla for issuance of Show Cause Notice under the Customs Act, 1962: - Issue in brief Name of the Unit Sr. No. Import of “Wet Dates” (HSN - 08041020) from overseas supplier for trading purposes by M/s Summit (India) Water Treatment and Services Ltd. (Unit-II) Summit Water and Ltd. M/s (India) Treatment Services 1. amounts to unauthorized activity as 27

on (Unit-II) trading of Wet Dates is not permitted in unit’s LoA. Mis-declared the description of the goods, mis- declared the quantity (weight and number of the packages of the goods) as well as mis-classified the CTH of the subject goods during the time of import and tried to mislead and defraud the Customs authorities by using different sets of documents (viz. Invoice and Packing list) for the purpose of presenting during examination vis-a-vis for the purpose of uploading on NSDL SEZ Online portal alongwith B/E._________________ The said SEZ Unit M/s. Enterprises appears to have mis-used the documents such as Bill of Lading (BL), Invoice, Packing list and also issued an NOC to facilitate improper import of the subject goods into Kandla SEZ by wilfully mis-stating and suppressing the truth with a malafide intention. Further, the LoA of the unit had expired on 11.06.2024, therefore it could not import the subject goods into its unit at Kandla SEZ. Accordingly, to import the subject goods, it appears to have provided these documents as supporting documents for the purpose of import of subject goods vide the mentioned B/E which is filed by and in the name of SEZ unit M/s Shiv Trading Co., Kandla SEZ. The activity of providing manufacturing services to their foreign client/providing sub-contracting services to their foreign client appears to be in contravention to the provisions of SEZ Act & Rules and also contrary to the permissions granted to them as per their LOA as per SEZ Act, 2005 read with SEZ Rules, 2006 and hence, appears to be an unauthorized activity as per SEZ Act, 2005 read with SEZ Rules, 2006.____________________ 2. M/s Trading Company Shiv 3. M/s Siddhi Vinayak Enterprise Siddhi Vinayak M/s. Impex Ltd.(Unit II) 4. Varsur Pvt. The Approval Committee deliberated on the issue and directed the DC office to initiate action for issuance of parallel Show Cause Notices to the above KASEZ units for violation of the terms and conditions of the Letter of Approval and BLUT and provisions of SEZ Act, 2005 & SEZ Rules, 2006 read with the Foreign Trade (Development and Regulation) Act, 1992and authorised the Development Commissioner, KASEZ to adjudicate the show cause notices being issued.

TABLE AGENDA ITEM NO. 209.4.3 Ratification of SCN to be issued to Kandla SEZ units The Committee was briefed on the issue of Show Cause Notice to be issued to the KASEZ unit. The members of the UAC unanimously agreed on the issues discussed of the contravention made therein for violation of terms and m view conditions of LoA and BLUT. The Approval Committee ratified the following Show Cause Notice to be issued by the Development Commissioner, KASEZ and authorised the Development Commissioner, KASEZ to adjudicate the show cause notice being issued. Issue in brief Show Cause Notice No. & Date Name of the Unit Sr. No. Parallel SCN for contravention Yet to be issued M/s. Zest Marine Services Pvt. Ltd. (Unit-II) 1. of provisions of SEZ Act and SEZ Rules - imported goods of alleged USA origin (inshell walnuts), were brought into KASEZ from abroad (Dubai), warehousing, paying any duty or producing country-of for without any certificate. Bill of entry for warehousing these alleged USA origin goods, without paying any Customs duty, was filed by M/s Zest Marine Services Pvt. Ltd. and origin undervalued invoices were presented before the Customs authorities for clearing the said goods to DTA in order to evade duties of customs and defraud the exchequer. For their act of omission, the Commissioner of Customs, Kandla vide ND-CUSTM-000- dated 08.11.2024 issued to M/s. Aditya Exports, KASEZ has also imposed penalty of Rs. 5.00 crores against M/s. Zest Marine Services Ltd. and Rs. COM-13-2024-25 29

on 5.00 crores against Shri Sharad Shetty, its Director- Other observations The Committee also directed the DC office that the units who have been granted approval in the UAC may be given 3 weeks’ time to submit the requisite documents/undertaking otherwise the approval granted by the UAC will be liable for cancellation. Notwithstanding to the decisions of the Committee, if the DC Office/Approval Committee notices any instance of default in rent or pending legal proceedings as on date of decision of the Committee or any legal proceedings that may be initiated after the decision of the Committee against the unit/firm/company and/or its Proprietor/Partner/Director, which has a bearing on the decision taken/LoA issued to the firm in any manner, the LoA granted will be liable for cancellation including action under the FT (D&R) Act and necessary action will be taken against such units in terms of applicable provisions of law. The meeting ended with a vote of thanks to the Chair. Development Commissioner Kandla Special Economic Zone 30