Minutes of the 211th meeting of Approval Committee

Minutes of the 211th Unit Approval Committee Meeting of Kandla SEZ held on 28.02.2025 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 : Assistant Commissioner of Income Tax, Gandhidham.
3. Shri. Vincent Colaco : Foreign Trade Development Officer, Rep. of Joint DGFT, Rajkot. (Video Conferencing mode).
4. Shri. Dinesh Chawda
5. Ms. Pinakiniben : Jr. Inspector, Rep. of GM, DIG, Bhuj (Video Conferencing mode). : Deputy Development Commissioner, KASEZ (Special Invitee)
6. Shri. Himanshu Gunawat : Deputy Commissioner of Customs, KASEZ (Special Invitee)
7. Shri. Bhanu Jain Absentees:-
8. Director (Banking)
9. SDM 211.1 Review/Confirmation of the minutes of last meeting (210th UAC) of the Approval Committee:- Minutes of the last meeting of Unit Approval Committee were confirmed. 1

Minutes of the 211* Unit Approval Committee Meeting of Kandla SEZ held on The Committee was informed that in the 204th UAC meeting, it decided not to grant any approval for chemicals & petroleum products in the warehousing and trading activity henceforth till the inspection and review of the existing warehousing & trading units are decided. In this regard, the Committee members constituted for review of existing warehousing & trading units indulged in drumming of chemical & petroleum products appeared before the Unit Approval Committee and submitted draft report inspection and review of review of existing warehousing & trading units indulged in drumming of chemical & petroleum products. The Approval Committee reviewed the draft report submitted by the Committee members and noticed that most of the units indulged in warehousing and trading activity of chemical & petroleum products adhering to the PESO norms, fire safety requirements. The Approval Committee after due deliberations directed the Committee members to submit comprehensive report to DC office which will submit the same to the Approval Committee for further deliberations. was on are 211.1 REQUEST FOR BROADBANDING/ITEM ADDITION AGENDA ITEM NO. 211.1.1 Request of M/s. Royal Petro Oil Refinery LLP, KASEZ for additional materials and finished goods for their authorized operation. raw M/s. Royal Petro Oil Refinery LLP, Plot No. 3/3, Sector-Ill, KASEZ is an approved unit for manufacturing activity of engine oil, hydraulic oil, gear oil, plastic cans/ jars etc. vide Letter of Approval No. KASEZ/IA/17/2015- 16/ 1665 dated 29.01.2016, as amended. Now the said unit has requested for addition of items for manufacturing activity in their existing LoA. Shri Hemant Shah, Partner of the firm appeared before the Committee to explain the proposal. Shri Shah stated that they are in KASEZ for refining of used oil and also manufacturing activity of engine oil, gear oil, etc. And recently used oil permission has been disallowed by DC office and the said facility of used oil refining is being idle now and to utilize the idle machinery they propose to include Bitumen in their manufacturing activity for export to various countries. He further stated that for the proposed manufacturing items the existing facility will be utilized and no major investment will be required and the same source of imports from their suppliers will be made which will enhance their turnover, exports & NFE. He also stated that the proposed manufactured goods will be primarily for exports only. The Committee noted that though the unit has submitted general process flow chart but has not submitted specific flow chart of the items 2

proposed for manufacturing activity and directed the Partner of the firm to submit specific flow chart of each items proposed for manufacturing activity. The Approval Committee after due deliberation decided to approve the proposal for addition of two items in manufacturing activity in their existing LoA subject to furnishing specific process flow chart of each items proposed for manufacturing activity and also subject to standard terms and conditions:- Any restrictions on import/export of manufacturing items and its raw materials will apply. Further, the items will be subjected to the Policy Conditions specified in DGFT’s ITC HS Code wherever applicable. 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 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 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) AGENDA ITEM NO. 211.1.2 Request of M/s. REFINE JUNCTION SEZ PARK LTD., KASEZ for additional raw materials and finished for their authorized operation. M/s. Refine Junction SEZ Park Ltd, KASEZ is an approved unit for manufacturing activity of base oil, Distallate oil etc. vide Letter of Approval No. 13/2024-25 dated.04.07.2024 which was issued to M/s. Stash Barn Enterprises, manufacturing LoA which was transferred to M/s. Refine Junction SEZ Park Pvt. Ltd. in 206th UAC meeting held on 30.09.2024. Now the said unit has requested for addition of items for manufacturing activity in their existing LoA. Shri Yash Gangwani, Director of the company appeared before the Committee to explain the proposal. Shri Gangwani stated that they are into manufacturing and trading activity of petroleum products. He further stated that they are having two plants - distillation plant consisting of llA> acres and blending plant consisting of Vs acres and the construction work of their unit is almost complete and also most of the machinery have been installed and they will start their authorised manufacturing activity in couple of 3

Minutes of the 211* Unit Approval Committee Meeting of Kandla SEZ held on months and intimate their commencement of activity. He further stated that they have requested for addition of 4 items for manufacturing activity and one of the item proposed for manufacturing viz. Lapsa which has huge demand in Africa and the production of the same is being undertaken in Arab countries. The Committee noted that the items proposed at Sr. No. 2 of their materials list were already approved in their LoA and asked the Director of the company as to why they have again requested for the said raw materials. In reply, Shri Gangwani stated that due to typo-graphical error, the raw material was mentioned as MTO instead of MHO in their LoA and hence they have requested the change in item description of raw material. The Committee further asked about the use of polymer in their finished products. In reply, Shri Gangwani stated that the raw material polymer is used in grease to improve viscosity. The Committee further noted that the unit has not submitted item- wise finished goods and raw materials list and directed the Director of the company to submit proper proposal giving specification of raw materials required for each manufactured items separately and also flow chart of each items proposed for manufacturing activity. The Committee also noticed that they are in rental dues to the tune of Rs. 25.05 lakhs which is due since last 7 consecutive quarters. raw Therefore, the Approval Committee after due deliberation decided to defer their proposal with direction to the unit to submit detailed proposal giving specification of raw materials required for each manufactured items separately and also flow chart of each items proposed for manufacturing activity. The Committee further directed the DC office to issue amendment with regard to item at Sr. No. 9 of their raw material list in their LoA as requested by the unit in the meeting. The Committee also directed the unit to clear the outstanding rental dues. AGENDA ITEM NO. 211.1.3 Request for addition of manufacturing activity in their existing Letter of Approval No. KASEZ/IA/25/2021-22 dated 21.02.2022 for Warehousing service activity, as amended issued to M/s. S. R. Brothers, KASEZ. M/s. S. R. Brothers, KASEZ is an approved unit vide Letter of Approval No. KASEZ/IA/25/2021-22 dated 21.02.2022, as amended, for warehousing activity. Now the said unit has requested for broad-banding/addition of manufacturing activity in their existing LoA for Warehousing service activity. The unit has expressed their intention for addition of manufacturing activity

of 08 products and submitted the list of items to be manufactured along with ITC HS Code. Shri Sabbir Rayma, Authorised Representative of the firm explained the proposal. Shri Rayma stated that they have earlier got approval for manufacturing, trading and warehousing activity in KASEZ but they have got smaller space in KASEZ and hence they have requested to begin with warehousing activity due to space constraint and once bigger space will be acquired by them they will go into manufacturing and trading activity also. He further stated that the present proposal is for manufacturing activity of tobacco in their existing warehousing LoA and further stated that the Proprietor of the firm is also into used clothing in KASEZ and are already supplying the goods to Madagascar in South Africa and now the supplier has requested for tobacco products also as there is huge demand of tobacco products in Madagascar. The Committee asked the representative of the firm about the present activities being undertaken by them in warehousing. In reply, Shri Rayma stated that they have undertaken warehousing activity of Wet Dates and Screen Guard; however, as there is less business in warehousing they propose to include manufacturing activity of tobacco products in their existing LoA for warehousing. The Committee asked the representative of the unit as to whether the brand name of the products proposed to be manufactured have been registered. If reply, Shri Rayma stated that they will apply for brand name registration after the approval is being granted for their manufactured products. The Committee further asked the representative about the source of funds proposed for the manufactured products. In reply, Shri Rayma stated that the source of funds for the proposed manufactured items will be from Proprietor’s own funds. The Committee asked the representative to furnish documents supporting source of funds/financial strength/net worth of the Proprietor. The Committee also asked the representative as to whether they have demarcated separate space for warehousing and proposed manufacturing activity. In reply, Shri Rayma stated that they require only 2000 sq. ft. area for the proposed manufacturing activity and they will bifurcate the manufacturing and warehousing activity in their existing premises by proper wall for demarcation of both the activities. The Approval Committee after due deliberation decided to defer the proposal with direction to the unit to register their brand name & furnish drawing/layout plan of the proposed manufacturing activity with separate entry & exit gates for each activity and submit the complete proposal for 5

Minutes of the 211th Unit Approval Committee Meeting of Kandla SEZ held on addition of manufacturing activity in their existing LoA. The Committee also directed the unit to submit ratio of composition/consumption of major materials in their finished goods and furnish documents supporting of funds/financial strength/net worth of the Proprietor. The Committee also directed the unit to clear the outstanding rental dues. raw source AGENDA ITEM NO. 211.1.4 Request for addition of manufacturing activity and Addition of items for Trading and Warehousing Service Activity in their existing Letter of Approval No. KASEZ/IA/1972/2003-04/1696 dated 10.02.2004 for Trading activity, as amended issued to M/s Unitrade World, KASEZ. new M/s. Unitrade World, KASEZ is an approved unit for Manufacturing/ Trading/Warehousing activity in Kandla SEZ KASEZ/IA/1972/2003-04/1696 dated 10.02.2004 as amended from time to time. vide LoA No. Now the unit has requested for addition of items in manufacturing activity, warehousing and trading activity in their existing LoA. Shri Rajendra Agarwal, Partner of the firm explained their proposal. Shri Agarwal stated that they are in KASEZ since more than 25 years having 3 units - two indulged in manufacturing of plastic scrap recycling weherein they are exporting 70% of their finished products and one unit into manufacturing, trading and warehousing. He further stated that he is also having CHA background wherein he is already dealing in chemical products and to further expand their business they propose to undertake manufacturing, trading and warehousing activity of chemical products. For manufacturing activity, Shri Agarwal stated that they propose to manufacture engine oil, industrial oil from fuel oil and other chemical products. The Committee noted that though the unit has submitted general process flow chart but has not submitted item-wise finished goods and raw materials list and directed the Partner of the firm to submit proper proposal giving specification of raw materials required for each manufactured items separately and also flow chart of each items proposed for manufacturing activity. The Committee further asked the partner about the source of funds proposed for the manufactured products. In reply, Shri Agarwal stated that for the proposed additional items they will make investment of 5.25 crores which will be from their own funds and if need be, ge from banks. He further stated that he had already submitted his ITR~and he will also submit ITR of other company wherein he is also Director in the said company. ^bqut Rs. H witl loan

The Approval Committee after due deliberation decided to approve the proposal for addition of manufacturing activity except items at Sr. No. 15, 42 fit 43 of the finished goods of the Agenda and also addition of items in trading activity except items at Sr. No. 1, 29 86 52 of the Agenda and also addition of items in warehousing service activity except items at Sr. No. 1, 3, 4, 7, 9, 10 86 16 of the Agenda (subject to unit submitting KYC of their clients alongwith ITR of last 3 years on whose behalf they will warehouse goods), subject to unit submitting layout plan of their premises showing separate demarcation for manufacturing activity, trading and warehousing activity and also subject to standard terms and conditions: 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 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. No DTA sale is allowed for the proposed traded items. 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. The above permission is also subject to further condition that the unit shall maintain separate accounts for manufacturing, trading & warehousing service activities and earmark separate space for all the activities with provisions of CCTV & other equipments. Further, the unit will submit separate APRs for their manufacturing, trading & warehousing service activities. Further, the unit will maintain separate stock register for manufacturing, trading & warehousing service activities which will be subject to regular checking by the KASEZ customs authorities. 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 and its raw materials & trading and warehousing items are falling under negative list and are not hazardous or require environmental clearance for storage/ transmission/ i) ii) iii) iv) v) vi) vii) viii) ix) X) xi) 7

Minutes of the 211th Unit Approval Committee Meeting of Kandla SEZ held on handling and if the items are found in negative list or hazardous in nature, penal action may be initiated against them. AGENDA ITEM NO. 211.1.5 Request for Addition of new items in their LoA for Trading and Warehousing Service Activity - Request of M/s. The Variety Impex, KASEZ. M/s. The Variety Impex, KASEZ is an approved unit with LoA dated 09.12.2020 issued from F. No. KASEZ/IA/29/2020-21, as amended for manufacturing activity and Trading activity of (i) In shell Walnuts, (ii) In shell Almonds, (hi) Fresh Kiwi Fruit, (iv) Wet Dates, (v) Cloves and (vi) Cinnamon, as amended. Further, warehousing service activity was also included in their LoA vide this office letter dated 21.02.2022. 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 for trading and warehousing activity. No representative of unit appeared before the Committee to explain the proposal. Therefore, the Approval Committee after due deliberation decided to defer their proposal. The Committee noted that their proposal was taken up in the last meeting wherein also the unit did not turned up for discussion which shows that the unit is non-serious in getting additional items approved in their LoA. Further, the Committee also noted that the unit is in rental dues of about Rs. 19.82 lakhs (8 quarter) for the period up to Mar’25 and directed the unit to clear the outstanding rental dues failing which eviction proceedings will be initiated against the unit and also action for cancellation of their LoA under Section 16 of SEZ Act, 2005 will be initiated. 211.2 MISCELLANEOUS ITEMS AGENDA ITEM NO. 211.2.1 Intimation of change in Partnership deed of M/s. JSD Foods and Beverages, KASEZ M/s. JSD Foods and Beverages, KASEZ is an approved unit for Trading and Warehousing Service activity. The unit has been granted Letter of Approval dated 09.11.2020, issued vide F.No. KASEZ/IA/22/2020-21, as amended. Now the said unit vide their letter dated 17.02.2025 has intimated regarding change in partners of the firm wherein two new Partners have joined the firm and submitted copy of Deed of Agreement of admission of new partners dated 23.04.2024. The unit has submitted copy of PAN, Aadhar & police verification report of new partners and also submitted 8

Income Tax Returns, Net worth certificate of new Partners, Ledger Account & Bank Statement of JSD Foods and Beverages showing the details of financial consideration made by the new partners, Ledger Account of new partners showing the details of financial consideration made in the firm and Form-G issued by Registrar of Firms, Kachchh District, Gandhidham regarding change in partnership firm. Shri Mayur Vyas, existing Partner along with Shri Rahul Wakde and Shri Yogesh Khoiwal, Partners being inducted in the firm appeared before the Committee to explain the proposal. Shri Vyas stated that the other existing partner is having other businesses outside KA.SEZ and hence he does not have time to look after the day to day affairs of the firm and hence they have transferred part of his shares to the new incoming partners and requested to take the change in Partners of the firm on records. The Committee asked the existing Partner about the area acquired by them in KASEZ and the firm’s turnover last year. In reply, Shri Vyas stated that they are having ready built shed admeasuring about 250 sq. mtrs. and during 2023-24 they was no activity however, their turnover in 2022-23 was to the tune of Rs. 26 lakhs. 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). The Committee also noticed that they are in rental dues to the tune of Rs. 3.45 lakhs which is due since last 4 quarters. 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 & 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. 9

Minutes of the 211* Unit Approval Committee Meeting of Kandla SEZ held on AGENDA ITEM NO. 211.2.2 Request of M/s. Nirav Mercantile Pvt. Ltd., KASEZ for change in Directors of the company and also change in registered office address. M/s Nirav Mercantile Pvt. Ltd., KASEZ is an approved unit for Manufacturing Activity of Lime mix tobacco (24039910) vide LoA No. F. No. KASEZ/IA/001/2014-15/3207 dated 19.06.2014, as amended from time to time. Now the said unit has intimated regarding change in Directorship of the company wherein one Director has resigned from the Board of Directors and one new Director has been appointed and also their registered office address stands changed to SEZ unit address at Unit No. 102, 105, 203, 205, 303, 305, Narmada SDK Complex, Phase-II, Kandla Special Economic Zone, Gandhidham. They have submitted copies of Form No. DIR-12 of ROC regarding appointment and resignation of Directors. Shri Anil Pandya, existing Director of the company appeared before the Committee to explain the proposal. Shri Pandya stated that one Director has retired and one new Director has been appointed in the company and there is no change in the shareholding pattern of the company. The Committee asked the Director about the firm’s turnover. In reply, Shri Pandya stated that the unit’s turnover last year is about Rs. 19 crores. 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 Board of Directors of the company & change in registered office address to “Unit No. 102, 105, 203, 205, 303, 305, Narmada SDF Complex, Phase-II, Kandla Special Economic Zone, Gandhidham”, 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. 211.2.3 Intimation of change in Partnership deed of M/s Vedanshi Impex, KASEZ. M/s. Vedanshi Impex, KASEZ is an approved unit with LoA dated 28.11.2022 issued from F. No. KASEZ/IA/16/2022-23 for Trading activity of (i) Wine, (ii) Beer and (iii) All kind of Liquor, as amended. Now the said unit has intimated regarding change in partners of the firm wherein two Partners have retired from the firm and one new Partner has joined in the firm and submitted copy of Partnership Deed of admission cum retirement dated 01.12.2024, copy of aadhar card and pan card of new partner and copy of Form-G issued from Registrar of Firms regarding change in partnership deed. Shri Vikram Singh Pawar, Authorised Representative of the firm appeared before the Committee to explain the proposal. Shri Pawar stated that two partners have retired and one new partner has been inducted in the firm and requested to take the change in partners of the firm on record. The Committee asked the representative of the firm about the consideration received from the new partner being inducted in the firm and whether they have submitted ITR of the new Partner. In reply, Shri Pawar stated that they have not submitted the consideration amount received from the new partner and also ITRs of the new Partner. Therefore, the Approval Committee after due deliberation decided to defer their proposal regarding change in Partners of the firm and directed the unit to submit the details of financial consideration made by the incoming partner along with detailed bank statement, net worth and ITRs of the new Partner for the last 3 years. AGENDA ITEM NO. 211.2.4 Permission to take over the assets and infrastructure M/s Swan Laxmi Pvt. Ltd., Unit No. 101, 201 fit 301, Narmada SDF Complex, Phase-II, in Kandla SEZ under Rule 74A of SEZ Rules, 2006 - Request of M/s. Vishnu Export, KASEZ. M/s. Vishnu Export, Unit No. 101 to 206, Gokul SDF Complex, Phase-II, KASEZ vide letter dated 15.02.2025 has made a request seeking permission to take over the assets & liabilities of M/s Swan Laxmi Pvt. Ltd., Unit No. 101, 201 & 301, Narmada SDF Complex, Phase-II, KASEZ under Rule 74A of SEZ Rules, 2006. In this regard, they have also submitted NOC for transfer of assets & liabilities issued by M/s. Swan Laxmi Pvt. Ltd., Unit No. 101, 201 & 301, Narmada SDF Complex, Phase-II, KASEZ 11

Minutes of the 211th Unit Approval Committee Meeting of Kandla SEZ held on Shri Ankur Garg, Partner of the firm appeared before the Approval Committee and explained their proposal. Shri Garg stated that they are into manufacturing activity of pan masala, gutkha, etc. in since last 7-8 years and to further expand their business they intends to take over the assets and liabilities of M/s. Swan Laxmi Pvt. Ltd., who wants to exit from SEZ subsequent to approval for transfer of assets and liability. The Committee asked the Partner of the firm as to whether they have submitted ITRs and Balance Sheet of M/s. Swan Laxmi Pvt. Ltd. and whether all the legal dues of M/s. Swan Laxmi Pvt. Ltd. have been paid by them or not. In reply, Shri Garg stated that they will submit ITRs and Balance Sheet of M/s. Swan Laxmi Pvt. Ltd. and regarding rental dues he stated that they will clear all the pending dues outstanding against the unit. Therefore, the Approval Committee after due deliberation approved their proposal under Rule 74A of SEZ Rules, 2006, subject to fulfilment of all the requirements prescribed thereof and also submit to submission of ITRs of last 3 years and Balance Sheet of M/s. Swan Laxmi Pvt. Ltd. and clearance of the outstanding rental dues of M/s. Swan Laxmi Pvt. Ltd. and subject to submission of Affidavit/Undertaking for taking over of assets and liabilities of M/s. Swan Laxmi Pvt. Ltd. AGENDA ITEM NO. 211.2.5 Request for addition of items in Warehousing Activity in their existing LoA No. 16/2015-16 dated 02.02.2016 issued to M/s Centrax Warehousing and Trading LLP (Formerly known as M/s Central Warehousing & Trading), KASEZ. The Committee noted that M/s. Centrax Warehousing and Trading LLP, KASEZ has requested for permission for warehousing activity of additional items. Shri Sushil Mehta, Partner of the firm explained their proposal. Shri Mehta informed that they have requested for permission for warehousing of additional items such as heating furnace, millstones, grindstones, etc. The Committee noted that the unit has not submitted KYC & ITRs of their client on whose behalf they will warehouse the goods and also item proposed at Sr. No. 4 is not available in the DGFT website and directed the unit to submit the correct ITC HS code with regard to item at Sr. No. 4 of their warehoused goods. The Committee after due deliberation decided to defer their proposal with direction to the unit to submit the correct ITC HS code with regard to item at Sr. No. 4 of their warehoused goods and also submit the KYC & ITRs of last 3 years of their client on whose behalf they will warehouse the goods. 12

AGENDA ITEM NO. 211.2.6 behalf of DTA Permission to warehouse additional item on Importer/Foreign client - Request of M/s. Commodities Trading (SEZ Warehousing Division), KASEZ. The Committee noted that M/s. Commodities Trading (SEZ Warehousing Division), KASEZ has requested for permission for warehousing activity of additional items. Shri Venkat Piteni, Manager of the firm explained their proposal. Shri Venkat informed that they have requested for permission for warehousing of additional items i.e. solar panels. The Committee asked the Manager of the firm as to whether they have permission for trading and warehousing activity or only warehousing and if trading activity is there, then the turnover of trading activity. In reply, Shri Venkat stated that they have approval for trading and warehousing activity and the turnover of their trading activity last year was about Rs. 4 crores. The Committee after due deliberation decided to permit the additional item 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 also subject to following conditions: 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. Further, the items will be subjected to the Policy Conditions specihed in DGFT’s ITC HS Code wherever applicable. 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 obtain registration/clearance/any other mandatory requirement prescribed under any Act/Rules from concerned agencies before undertaking of such activities. i) ii) iiil iv) v) vi) 13

Minutes of the 211th Unit Approval Committee Meeting of Kandla SEZ held on 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, 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. 211.2.7 Permission to warehouse additional item on behalf of DTA Importer/Foreign client - 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. No representative of M/s. Flamingo Logistics appeared before the Committee to explain the proposal. The unit vide email dated 27.02.2025 has informed that the Partner is travelling out of Town and will not be able to attend the UAC meeting to be held on 28.02.2025. Therefore, the Approval Committee after due deliberation decided to defer their proposal. AGENDA ITEM NO. 211.2.8 Permission to warehouse goods on behalf of DTA/Foreign Clients - Request of M/s. Naman Marketing, a unit for warehousing activity, KASEZ. The Committee noted that M/s. Naman Marketing, KASEZ has requested for permission for warehousing activity of additional items. The unit vide email dated 27.02.2025 has informed that due to some unavoidable reasons from the material supplier vendor’s side, they would like to withdraw their application of adding items in their LoA and hence they would not appear in the UAC meeting. Therefore, the Approval Committee accepted the request of the unit for the withdrawal of their proposal. AGENDA ITEM NO. 211.2.9 Permission to warehouse goods on behalf of DTA/Foreign Clients - Request of M/s. Zip Zap Exim Pvt. Ltd. Unit-II, KASEZ. The Committee noted that M/s. Zip Zap Exim Pvt. Ltd. Unit-II, KASEZ has requested for permission for warehousing activity of additional items. Shri Vaibhav Baid, Director of the company explained their proposal. Shri Baid informed that they have requested for permission for some more items in warehousing activity on behalf of their foreign clients. 14

The Committee asked the Director about the items proposed viz. Watches/Clocks as to whether it will be branded or unbranded and the items already approved in their LoA and the items they have undertaken. In reply, Shri Raid stated that the items proposed will be assembled & un­ assembled and spare parts of the watch/clock movement & also clock movement complete and all the watch/clock will be un-branded items and till date they have undertaken warehousing of about 140-150 items approved in their LoA. 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. 9 to 21, 27 & 28 of their proposal, subject to the unit fulfilling NFE criterion and also subject to following conditions: 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. Further, the items will be subjected to the Policy Conditions specified in DGFT’s ITC HS Code wherever applicable. 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 86 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 86 ‘Description of goods as per DGFT Import Policy’, the later will prevail. 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) 15

Minutes of the 211* Unit Approval Committee Meeting of Kandla SEZ held on AGENDA ITEM NO. 211.2.10 Request of M/s. H S Flavours and Exports LLP, KASEZ for extension of their LOA for further period of one year for Manufacturing Activity. M/s. H S Flavours and Exports LLP, KASEZ has been issued LoA for manufacturing activity of Guthka, Khaini, Zarda, Pan Masala etc. vide LoA No. 12/2021-22 dated 08.09.2021. The unit has been allotted Unit No. 103 & 203, SDF-VIII, Dwarika SDF, KASEZ. The LoA was valid upto one year i.e. 07.09.2022 which was further extended for two years upto 07.09.2024. Shri Anand Mehta, Authorised Representative of the firm explained the proposal. Shri Mehta stated that they have been granted LoA for manufacturing activity of Pan masala, gutkha, etc. and due to unavoidable circumstances they have not started their authorised manufacturing activity. He further stated that they have already purchased the packing materials valued at about Rs. 16.62 lakhs and also they install capital goods required for manufacturing activity once their LoA is renewed for further one year period. The Committee noted that the unit has been granted LoA dated 08.09.2021 with initial validity of one year upto 07.09.2022 which further extended for two years period upto 07.09.2024 as per Rule 19(4) of the SEZ Rules, 2006. Further, as per second proviso the DC may grant further extension of one year subject to the condition that two-thirds of activities including construction, relating to the setting up of the Unit is complete and a chartered engineer’s certificate to this effect is submitted by the entrepreneur. was The Committee further noted that the unit has submitted Chartered Engineer certificate detailing the list of machines required along with capital investment for procurement of machinery and quotations of the machinery. The DC office has constituted a Committee of officers for physical verification of the unit’s premises and the Committee of officers have submitted its verification report informing that the unit has procured plastic laminated pouches valued at Rs. 16.62 lakhs and no plant & machinery were found installed in unit’s premises. The Committee also noticed that they are in rental dues to the tune of Rs. 36.54 lakhs which is due since last 9 consecutive quarters. The Committee deliberated on the issue and directed the unit representative to furnish Chartered Engineer certificate certifying the expenditures made by them till date and also to submit an undertaking to the effect that by what time they will commence their authorised manufacturing activity in KASEZ. The Committee also directed the unit representative to pay outstanding rental dues. 16

Therefore, the Approval Committee after due deliberation decided to renew their LoA for the fourth year period upto 07.09.2025 subject to the unit furnishing Chartered Engineer certificate certifying the expenditures made in KASEZ; Undertaking by what time they will start their authorised activity in KASEZ and subject to payment of outstanding rental dues and also subject to standard terms and conditions. AGENDA ITEM NO. 211.2.11 Request of M/s. HRJ Warehousing & Trading Co., KASEZ for renewal of their LOA for Warehousing and Trading Activity. M/s HRJ Warehousing & trading Company, KASEZ is an approved unit for Warehousing Service & trading Activity as approved vide LoA No. 047/2010-11 dated 04.03.2011. The unit vide letter dated April 26, 2011 (received on April 29, 2011) informed DC office that they have commenced their authorized operations with effect from April 26, 2011. However, no supporting documents were provided by unit with said letter dated April 26, 2011. DC office vide letter dated December 11, 2014 requested the unit to provide documents in support of its claim regarding commencement of authorized operations on April 26, 2011. As per clause 11 of LOA dated March 4, 2011, the validity period of LOA is for period of five years from the date of commencement of authorized operations by the unit. DC office vide Eligibility Certificate No. KASEZ/34/2015-16 dated January 7, 2016 has affirmed on record that the LOA dated March 4, 2011 issued to the unit is valid up to April 25, 2016. Accordingly, this office has acknowledged on record that April 26, 2011 has been considered as the relevant date of commencement of authorized operations by the unit, in consequence of which the validity period of LOA is till April 25, 2016. The unit vide Letter dated March 5, 2016 (received on March 8, 2016) requested this office for renewal of LOA dated March 4, 2011 expiring on April 25, 2016. The unit also filed an online application vide Request ID 201600000991 for renewal of LOA. The unit vide Letter dated November 9, 2020 (received on November 10, 2020) requested to renew their LOA for period of five years. The unit vide said letter provided documents such as copy of Bill of Entry and bank statement in support of their claim regarding commencement of their authorized operations with effect from April 26, 2011. Subsequently, the unit again vide Letter dated December 13, 2020 (received on December 17, 2020) and Application in Form FI dated December 15, 2020 requested DC office for extension/renewal of their LOA for period of five years. The Committee noted that the LoA of the unit was valid upto 25.04.2016 as they have commenced their authorised activity w.e.f. 26.01.2011 and as per Eligibility Certificate dated 07.01.2016 issued by DC office. The Approval Committee after due deliberation decided to approve renewal of their LoA for two five year block period from 26.04.2016 to 17

Minutes of the 211th Unit Approval Committee Meeting of Kandla SEZ held on 25.04.2021 and 26.04.2021 to 25.04.2026 and also to take on record the date of commencement of authorised operation of the unit w.e.f. 26.01.2011. The Committee further directed that the renewal of LoA will be subject to the condition that the unit is not allowed import and warehousing of used/worn clothes, plastic scrap/second hand materials to be warehoused in the units warehouse & subject to payment of outstanding rental dues and subject to physical verification of the unit so as to ensure that no sub-letting activity is taking place in terms of clause (2) of DoC’s Instruction No. 117 dated 24.09.2024. AGENDA ITEM NO. 211.2.12 Ratification of O-I-Os issued to Kandla SEZ units. The Development Commissioner, KASEZ briefed the Committee members on the issue of Orders-in-Original issued to the KASEZ units. The members of the UAC unanimously agreed on the issues discussed in the Orders-in-Original in view of the contravention made therein. The Approval Committee ratified the following Orders-in-Original issued by Development Commissioner, KASEZ: - Name of the Unit Sr. Order-in-Original No. & Date Issue in brief No. 1. Shanlok International KASEZ/14/2024-25 dated 12.02.2025 For violation of terms and conditions of LoA and BLUT - unauthorized activity leased/rented out premises, 07.11.2023 issued to the unit issued to the unit and the adjudicating authority has issued 0-1-0 imposing appropriate penalty. their dated SCN 2. Bajaj Warehousing Services KASEZ/15/2024-25 dated 12.02.2025 For violation of terms and conditions of LoA and BLUT - unauthorized leased/rented activity their dated out SCN premises, 02.11.2023 issued to the unit issued to the unit and the adjudicating authority has issued 0-1-0 imposing appropriate penalty. KASEZ/16/2024-25 dated 12.02.2025 For violation of terms and conditions of LoA and BLUT - Texpoly Impex 3. unauthorized dated 23.11.2023 issued to the unit issued to the unit and the activity, SCN 18

authority has imposing adjudicating issued 0-1-0 appropriate penalty. For violation of terms and KASEZ/17/2024-25 dated 12.02.2025 S. R. Warehousing & Trading Co. (Unit-I) 4. conditions of LoA and BLUT - unauthorized leased/rented premises, 11.01.2024 issued to the unit issued to the unit and the adjudicating authority has issued 0-1-0 imposing appropriate penalty. activity out their SCN dated For violation of terms and conditions of LoA and BLUT - unauthorized leased/rented premises, 20.09.2023 issued to the unit issued to the unit and the adjudicating authority has issued 0-1-0 imposing appropriate penalty. KASEZ/18/2024-25 dated 12.02.2025 Adinath Warehousing Co. 5. activity out their SCN dated For violation of terms and KASEZ/19/2024-25 dated 25.02.2025 Lohadia Warehousing Company 6. conditions of LoA and BLUT - unauthorized activity leased/rented out their SCN dated premises, 07.11.2023 issued to the unit issued to the unit and the adjudicating authority has issued 0-1-0 imposing appropriate penalty.____________ AGENDA ITEM NO. 211.2.13 Ratification of request already approved in file The Approval Committee ratified the permission granted to the following units by the Development Commissioner, KASEZ: Time Permission letter issued Remarks Name of Unit One Permission granted Sr. No. for on Warehousing of imported goods viz. Heating Furnace - ITC HS 85141900 M/s. Centrax Warehousing & Trading LLP 12.02.2025 1. Warehousing of imported goods viz. M/s. Cargo Agency________ 2. Care 12.02.2025 19

Minutes of the 211th Unit Approval Committee Meeting of Kandla SEZ held on Cashew nut, roasted, salted or roasted and salted and other nuts preserved otherwise, Mixtures - ITC HS 20081910 TABLE AGENDA ITEM NO. 211.3.1 Violation of terms and conditions of LoA and BLUT - unauthorised activity - Report received from Police Department, Gandhidham vide letter dated 25.11.2024 wherein it was intimated that M/s F.N. Impex, KASEZ warehousing unit of KASEZ is indulged in the illicit activity of smuggling Areca Nuts by mis-declaration. M/s. F.N. Impex, KASEZ is an approved unit of Warehousing activity & Trading vide LoA No. 11/2021-22 dated 16.09.2021. The LoA is valid up to 15.09.2026. The Committee was informed that based on letter received from the Superintendent of Police of East-Kutch, Gandhidham intimating DC office that Gandhidham-B DV. Police Station has registered the case and case is being investigated by Local Crime Branch against M/s F.N. Impex, KASEZ wherein quantity of betel nut was seized from the trailer reg. no. reg.no-GJ- 12-BY-6342 with a total weight-27170 kg and trailer reg no-GJ - 12-BZ- 9563 from container no.CAXU9715380-45Gl Quantity of betel nuts total weight-26780 kg. and during their investigation the quantity of betel nut found was ordered by F.N. Impex company through UAE's Anant Star General Trading LLC company under the guise of Rock salt. Based on the above incident report from the Superintendent of Police of East-Kutch, Gandhidham, the matter was taken up in the 208th UAC meeting held on 27.11.2024 wherein the Approval Committee after due deliberation authorised the Development Commissioner, KASEZ being the Adjudicating Authority to initiate action against the unit by issuance of Show Cause Notice and decide on further course of action against the said unit. Accordingly, Show Cause Notice dated 29.11.2024 was issued to the unit for violation of terms and conditions of LoA and personal hearing was granted number of times however the unit did not appeared in any of personal hearings granted and requested for adjournment of personal hearing citing different reasons every time. The Committee deliberated on the issue and noted that the unit has been indulged in smuggling of import of areca nuts in guise of rock salt,

failed to submit APRs since inception of the unit and are defaulter in payment of rental dues. Thus, this is a fit case for cancellation of their LoA under Section 16 of the Act for indulging in smuggling of import of areca nuts in guise of rock salt, failed to furnish APRs and defaulter in rental dues 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 29.11.2024 issued to the unit. 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. A (Dinesh Singh) Development Commissioner Kandla Special Economic Zone 21