Minutes of the 220th meeting of Approval Committee

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Minutes of the 220 Unit Approval Committee Meeting of Kandla SEZ held on 28.11.2025 at 11:00 hrs under the Chairmanship of Shri Dnyaneshwar Bhalchandra Patil, Development Commissioner, Kandla Special Economic Zone.

Following were present:

1.	Ms.	Rajtanil Solanki	—: Joint Development Commissioner,
			KASEZ.
2.	Shri.	Rohit Soni	: Joint DGFT, Office of Jt. DGFT,
			Rajkot.
			(Video Conferencing mode).
3.	Shri.	Jivender Singh	—_: Superintendent of Customs,
			Rep. of Commissioner of Customs, Kandla.
4.	Shri.	Bharat Nakum	: Manager R. M., DIC, Bhuj
			(Video Conferencing mode).
5.	Shri.	Bhanu Jain	: Deputy Commissioner of Customs,
			KASEZ
			(SpecialInvitee)

Absentees:-

1. Director (Banking) 2. SDM 3. I.T.

220.1 Review/Confirmation of the minutes of last meeting (219" UAC) of the Approval Committee:-

Minutes of the last meeting of Unit Approval Committee were confirmed.

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220.2 REQUEST FOR BROADBANDING/ITEM ADDITION

AGENDA ITEM NO. 220.2.1 Permission for addition of items for Trading activity — Request of M/s.Green Poly Plast Industries, a unit of Trading/Warehousing activity in KASEZ.

M/s Green Poly Plast Industries is an approved unit vide LOA No. KASEZ/IA/22/2021-22 dated 24.01.2022 for Trading and Warehousing Service activity.

Now the unit has requested for addition of items in trading activity in their existing LoA.

Shri Parvez Kadri, Partner of the firm appeared before the Committee to explain the proposal. Shri Parvez stated that they have been granted LoA for trading and warehousing activity and now they have requested for addition of 10 items for trading activity.

The Committee asked the Partner as to whether they will import or procure the traded goods and where they will export the traded goods. In reply, Shri Parvez stated that they will procure the goods from domestic market and export the same to African countries.

The representative from Kandla Customs informed that a show cause notice has been issued to the unit on 25.11.2025 for mis-declaration wherein instead of PP granules they have imported areca nut.

The Committee noted that a case has been booked by the SIIB Kandla Customs for mis-declaration and also the items proposed are sensitive in nature and the unit is having outstanding rental dues since last more than 2 years.

case has been booked by the SIIB Kandla Customs for mis-declaration and also the items proposed are sensitive in nature and the unit is having outstanding rental dues since last more than 2 years.

Therefore, the Approval Committee decided to defer their proposal with direction to DC office to examine the sensitivity of the items proposed and details of case booked by SIIB Kandla Customs. The Committee also directed the unit to also clear the outstanding rental dues.

AGENDA ITEM NO. 220.2.2

Request of M/s. Keval Exports for addition of trading activity in their existing LoA for manufacturing activity.

M/s Keval Export, KASEZ is an approved unit for manufacturing activity of micro crystalline cellulose powder, wheat starch, Lactose Monohydrate powder etc. as amended vide LOA No. KASEZ/IA/43/2007-08 dated 09.05.2008.

Now the said unit has requested for addition of trading activity in their existing LoA for manufacturing activity.

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Ms. Shrusti Patel, Authorised Representative of the company appeared before the Committee to explain the proposal. Ms. Patel stated that they are into manufacturing activity of 5 products and now they have requested for addition of trading activity in their existing LoA. The Committee directed the unit representative that they have to apply for separate LoA for trading activity and submit application in Form F for setting up trading activity with separate demarcation for trading activity in their existing premises with separate entry & exit gates for both activities along with layout plan.

The Approval Committee after due deliberations decided to defer their proposal with direction to the unit to submit new LoA application for trading activity in the SEZ online their application and submit separate application in Form F, application fee along with detailed project report with layout plan showing demarcation of manufacturing & trading activity. The Committee also directed the unit to clear the outstanding rental dues before submitting their application for trading activity.

AGENDA ITEM NO. 220.2.3

Addition of new items in their LoA for Manufacturing Activity of Tobacco Products Trading and Warehousing Service Activity — Request of M/s. Summit India Water Treatment & Services Ltd. (Unit-Il), KASEZ

The Committee noted that their proposal was deferred in the last UAC with direction to apply for new LoA for manufacturing activity and submit application in Form F along with detailed project report with layout plan showing demarcation of premises for manufacturing, trading &warehousing activity.

Shri Manpreet Singh Saini, Authorised Representative of the company appeared before the Committee to explain the proposal. Shri Saini stated that they have requested for addition of manufacturing activity. The Committee asked the unit representative as directed in the last UAC as to whether they have submitted application in Form F along with supporting documents for setting up new manufacturing unit, application fee and demarcation of their existing premises for manufacturing, trading & warehousing activity. In reply, Shri Saini stated that he has not submitted the application in Form F, application fees & further stated that they will submit the same by today itself.

g, trading & warehousing activity. In reply, Shri Saini stated that he has not submitted the application in Form F, application fees & further stated that they will submit the same by today itself.

The Approval Committee after due deliberations decided to defer their proposal with direction to the unit to first submit in the SEZ online their separate LoA applications for trading as well as warehousing activity wise and submit separate application in Form F, application fee along with detailed project report with layout plan showing demarcation of manufacturing, trading & warehousing activity. The Committee also directed the unit to first clear the outstanding rental dues before submitting their application for manufacturing activity.

AGENDA ITEM NO. 220.2.4 Request of M/s. United Drilling Tools Ltd., for addition of items in

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manufacturing activity in their existing LoA for manufacturing activity.

M/s. United Drilling Tools Ltd., is an approved unit for manufacturing activity of Casing Pipes with Connector (ITC HS 7304 2990), as amended in KASEZ. The unit have been granted Letter of Approval F.No. KASEZ/IA/01/2011-12 dated 12.04.2011, as amended.

Now the unit has requested for addition of items in manufacturing activity in their existing LOA.

Shri Arun Kumar Thakur, Authorised Representative of the firm appeared before the Committee to explain the proposal. Shri Thakur stated that they are into manufacturing activity in KASEZ since 2014 and now they have requested for addition of two items in their manufacturing activity as their foreign clients has requested for casing pipes without connector.

The Committee asked the unit representative about the present activities being undertaken by them at present. In reply, Shri Thakur stated that they are manufacturing casing pipes with connectors and exporting the same and now their customers have requested for export of casing pipes without connector & the ITC HS code is the same but description of the goods is only changed.

ith connectors and exporting the same and now their customers have requested for export of casing pipes without connector & the ITC HS code is the same but description of the goods is only changed.

The Approval Committee after due deliberation decided that already same HSN code already available in existing LoA hence the proposal for addition of two items in manufacturing activity in their existing LoA is not required .clearly mentioned that UAC committee will allow broad branding only if the HSN code is different than existing . And there is no need of separate broad branding if same HSN code is already allowed. 220.3 MISCELLANEOUS ITEMS

Request for merger of two LoAs —Request of M/s. Eco Plastics, KASEZ.

M/s. Eco Plastics, KASEZ (Plastic recycling unit) is an approved unit for manufacturing of all types of plastic bags, Garbage collection/ carry/ shopping bags etc., Household and allied items, in Kandla Special Economic Zone vide Letter of Approval No. KFTZ/IA/1628/96/1198 dated 14.05.1996, as amended. Now the unit M/s. Eco Plastics, have submitted NOC from M/s. Easy Warehousing for merger of their LoA and stated that as per the provisions of 4th proviso to Rule 19(2) of the SEZ Rules, 2006, the Approval Committee is Competent to permit the merger of two LOAs operating in the same SEZ. Shri Hardeep Singh, Authorised Representative of the firm appeared before the Committee to explain the proposal. Shri Singh stated that they are having two LoAs in KASEZ one for manufacturing and another for warehousing and now they want to merge their two LoAs.

The Committee noted that the unit has requested for merger of LoAs of

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cturing and another for warehousing and now they want to merge their two LoAs.

The Committee noted that the unit has requested for merger of LoAs of

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manufacturing and warehousing activity and in view of the challenges observed in the mixed LoAs (covering manufacturing, warehousing, and trading activities under a single approval), and it was decided to issue separate LoAs for each activity. The mixed LOA system makes it difficult to accurately assess the progress of manufacturing, warehousing and trading activities individually, thereby defeating the core purpose of the SEZ. The Committee further noted that the primary objectives of the SEZs, employment generation and export promotion can be effectively achieved only if each activity has a distinct LoA. One of the key drawbacks of a mixed LOA is that a unit may acquire a large plot for manufacturing but use only a small portion for trading or warehousing while showing a positive NFE without actually engaging in significant manufacturing. This leads to suboptimal utilization of the allotted land. The second dis advantage to unit itself that the government benefits are available activity wise due to mixed LoA the unit can’t claim the benefits. Hence the Committee decided not to entertain such request for merger of LoAs.

Therefore, the Approval Committee after due deliberations decided to reject their proposal for merger of LoAs.

AGENDA ITEM NO. 220.3.2

Request for merger of two LoAs — Request of M/s. Navkar Poly Recyclers, KASEZ.

M/s. Navkar Poly Recyclers [earlier known as M/s. Shreeji Polymers (Unit|)], KASEZ is an approved unit for manufacturing of Recycling of LDPE/HDPE Scrap in to granules, Agglomerates & Lumps, etc. in Kandla Special Economic Zone vide Letter of Approval No. KFTZ/IA/1705(A)/97/10787 dated 09.02.1998, as amended.

Now the said unit has requested for merger of LoA of M/s. Maruti Packaging with their LoA under Rule 19(2) of the SEZ Rule, 2006. Shri Jitender Jain, Partner of the firm appeared before the Committee to explain the proposal. Shri Jain stated that they are having two LoAs in KASEZ one is plastic recycling manufacturing unit and other is for manufacturing of polypropylene bags/sheets, etc. & trading activity and now they want to merge their two LoAs.

The Committee noted that for one LoA which is for plastic recycling, their renewal is granted by the Board of Approval and for another LoA for manufacturing & trading, the renewal is granted by the Development Commissioner and as such both the LoAs are different in nature. Hence, the Committee is not in a position to merge their LoAs.

Therefore, the Approval Committee after due deliberations decided to reject their proposal for merger of LoAs as both their LoAs have separate treatment for renewal of LoA as one is approved by Board of Approval and the other is approved by Development Commissioner.

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Intimation for change in Partner of the firm M/s. Soobaika Warehousing LLP.

M/s. Soobaika Warehouse LLP, is an approved unit for warehousing activity in KASEZ. The unit have been granted Letter of Approval No. 11/2023-24 dated 23.11.2023 issued vide F.No.KASEZ-1A1/21/2023-SEZ/KANDLA/3180353/724, as amended.

Now the said unit has intimated regarding change in partners of the firm wherein one Partner has retired from the firm & one partner has joined the firm. Further the unit has not submitted copy of Deed of Agreement for change in partners and has also not submitted copy Form-G issued by Register of Firms.

Shri Mohit Bhanusali, existing Partner along with Shri Prakash Bhanushali, Partner being inducted appeared before the Committee to explain the proposal. Shri Mohit stated that his mother has retired and his father has joined the firm. The Committee noted that there is change within the family members wherein mother of existing partner has retired and father of the existing partner has joined the firm. The Committee further 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).

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 revised Partnership Deed, Form-G issued by Registrar of Firms, 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. 220.3.4 Permission to warehouse goods on behalf of Foreign/DTA client in their the existing LoA — Request of M/s. Harish Processors Pvt. Ltd., KASEZ.

AGENDA ITEM NO. 220.3.4

The Committee noted that M/s. Harish Processors Pvt. Ltd., KASEZ has requested for permission for warehousing activity of additional items.

Shri Sahil Chaturani along with Shri Sajji, Authorised Representatives of the company explained their proposal. Shri Sahil stated that they have requested for warehousing of two additional items.

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The Committee noted that the unit has been granted permission for warehousing of plastic items, chemical items and storage of worn & used clothing and asked the authorised representatives as to whether they are indulged in all these activities. In reply, Shri Sajji stated that they are not having permission for storage of worn & used clothing and further stated that at present they are not doing any activities of plastic items. The Committee directed the authorised representatives to submit letter for withdrawal of permission for storage of worn & used clothing & also plastic items from their existing LoA as they are not undertaking any such activity. The Committee also noted that the two items proposed are flammable.

The Approval Committee after due deliberations decided to defer their proposal with direction to the unit to submit letter for withdrawal of permission for storage of worn & used clothing & also plastic items from their existing LoA and also submit an undertaking to the effect that they will comply with the guidelines/policies of State/Central regarding flammable items for the proposed items.

AGENDA ITEM NO. 220.3.5

Permission to Warehouse goods on behalf of DTA Clients M/s Fastrack Filteration — Request of M/s. Centrax Warehousing and Trading LLP.

The Committee noted that M/s. Centrax Warehousing and Trading LLP, KASEZ has requested for permission for warehousing activity of additional items.

No representative of unit appeared before the Committee to explain the proposal. Therefore, the Approval Committee after due deliberation decided to defer their proposal.

AGENDA ITEM NO. 220.3.6

Request of M/s. Krishna Enterprises for addition of items in Warehousing activity in their existing LoA for Trading and Warehousing activity.

The Committee noted that M/s. Krishna Enterprises, KASEZ has requested for permission for warehousing activity of additional items.

No representative of unit appeared before the Committee to explain the proposal. Therefore, the Approval Committee after due deliberation decided to defer their proposal.

AGENDA ITEM NO. 220.3.7

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 Kandla Special Economic Zone vide Letter of Approval No. KASEZ/IA/17/2022-23/7852-55 dated 28.11.2022, as amended.

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Now the said unit has requested for addition of new items for Trading and warehousing service Activity.

Shri Zamir Dosani, Authorised Representative of the firm appeared before the Committee to explain the proposal. Shri Dosani stated that they have requested for addition of new items in their trading and warehousing activity. The Committee noted that the unit has submitted list of 219 items for trading and warehousing wherein some of the items are not available in the DGFT import/export policy and some of the items are restricted which the Committee is not permitting in trading & warehousing activity.

arehousing wherein some of the items are not available in the DGFT import/export policy and some of the items are restricted which the Committee is not permitting in trading & warehousing activity.

The Approval Committee after due deliberation decided to approve the proposal for addition of new items in trading activity and warehousing service activity (except trading & warehousing items at Sr. No. 18, 19, 26, 29, 47, 80, 86, 89, 91, 92, 93, 95, 96, 110, 112, 114 to 123, 126, 127, 138, 139, 159, 198, 203, 210, 217 & 218) subject to unit submitting KYC of their clients alongwith ITR of last 3 years on whose behalf they will warehouse goods, to DC office before commencing first transaction by that client, in terms of Instruction No. 117 in their existing LoA and also subject to the following standard terms and conditions:

• i. 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.

• ii. 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.

• ii. Further, no DTA sale is allowed for the approved traded items.

• iv. Further, the items will be subjected to the Policy Conditions specified in DGFT’s ITC HS Code wherever applicable.

il.

• ii. Further, no DTA sale is allowed for the approved traded items.

• iv. Further, the items will be subjected to the Policy Conditions specified in DGFT’s ITC HS Code wherever applicable.

• v. 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.

• vi. Further, the unit must ensure that they should have a tamper-proof ERP/SAP/Tally system for their trading activity and warehousing activity.

• vii. 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.

• viii. Further, the unit will submit separate APRs for their trading and warehousing service.

• ix. Further, the unit will maintain separate stock register fortrading and warehousing service which will be subject to regular checking by the KASEZ customs authorities.

• x. Further, the unit will obtain registration/clearance/any other mandatory requirement prescribed under any Act/Rules from concerned agencies before

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undertaking of such activities.

• xi. 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.

• xii. Further at the time of import/export/DTA procurement of any items, the HSN code has to be examined by the Customs officers at the time of clearance of the goods.

• xiii. 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. 220.3.8

Permission to warehouse additional items Warehousing Activity and Trading Activity in their existing LoANo. KASEZ/IA/018/2013-14 dated 07.04.2014 for manufacturing, trading and warehousing activities, as amended issued to M/s Siddhi Vinayak Enterprises, KASEZ.

The Committee noted that M/s. Siddhi Vinayak Enterprises, KASEZ has requested for permission for warehousing activity of additional items.

No representative of unit appeared before the Committee to explain the proposal. Therefore, the Approval Committee after due deliberation decided to defer their proposal.

AGENDA ITEM NO. 220.3.9

Permission to warehouse goods on behalf of DTA/Foreign clients — Request of M/s. Soobaika Warehouse LLP, KASEZ.

The Committee noted that M/s. Soobaika Warehouse LLP, KASEZ has requested for permission for warehousing activity of additional items.

Shri Mohit Bhanushali, Partner along with Shri Prakash Bhanushali, Partner being inducted in the firm appeared before the Committee to explain the proposal. Shri Mohit stated that they have requested for warehousing of additional items. The Committee noted that the unit has submitted 4 digit ITC HS code for some of the items proposed and directed the unit representatives that the Committee is not allowing 4 digit ITC HS code.

The Committee after due deliberation decided to permit the addition of 05 items except items at Sr. No. 4 to 6, 9 to 14 of the Agendato be warehoused by the above unit on behalf of DTA/Foreign clients as submitted by the unit subject to unit submitting KYC of their clients alongwith ITR of last 3 years on whose behalf they will warehouse goods, to DC office before commencing first transaction by that client, in terms of Instruction No. 117. subject to payment of outstanding rental dues & the unit fulfilling NFE criterion and also subject to following conditions:

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• i. None of the items which are restricted or prohibited will be allowed to be warehoused and any restrictions on import/export of any items will apply unless specifically permitted by the UAC. This clause will have overriding effect for any approval granted in LoA now or before.

housed and any restrictions on import/export of any items will apply unless specifically permitted by the UAC. This clause will have overriding effect for any approval granted in LoA now or before.

• ii. Further, the items will be subjected to the Policy Conditions specified in DGFT’s ITC HS Code wherever applicable.

• ii. Further, the unit must ensure that they should have a tamper-proof ERP/SAP/Tally system with provisions of CCTV with sufficient longer duration of storage & other equipments.

• iv. Further, the transfer of goods from one FTWZ to another FTWZ shall not be allowed except in specific and exceptional cases after consideration by the UAC.

• v. In case of any discrepancy/mismatch between the Description of Goods’ as provided by the Unit & ‘Description of goods as per DGFT Import Policy’, the later will prevail.

• vi. Further, the unit will obtain registration/clearance/any other mandatory requirement prescribed under any Act/Rules from concerned agencies before undertaking of such activities.

• vii. Further, the unit will ensure the compliance of all guidelines, policies issued by any Ministry from time to time pertaining to the items approved in LOA.

• viii. Further at the time of import/export/DTA sales of any items, the HSN code has to be examined by the Customs officers at the time of clearance of the goods.

g to the items approved in LOA.

• viii. Further at the time of import/export/DTA sales of any items, the HSN code has to be examined by the Customs officers at the time of clearance of the goods.

• ix. Further, the unit will give an undertaking that none of the items proposed are falling under negative list and are not hazardous or require environmental clearance for storage/ transmission/ handling and if the items are found in negative list or hazardous in nature, penal action will be initiated against them.

AGENDA ITEM NO. 220.3.10

Addition of items in trading and warehousing activity intheir existing LoA for Warehousing and Trading Activity — Request of M/s. ISHA IMPEX, KASEZ

The Committee noted that M/s. ISHA IMPEX, KASEZ has requested for permission for warehousing activity of additional items.

Shri Jaydat Goswami, Partner of the firm explained their proposal. Shri Jaydat stated that they have requested for warehousing of additional items.

The Committee noted that the unit has submitted list of 56 items for warehousing wherein some of the items are not available in the DGFT import/export policy and some of the items are sensitive in nature which the Committee is not permitting in warehousing activity.

The Committee after due deliberation decided to permit the addition of 45 items except items at Sr. No. 1, 2, 45, 46, 49 to 56 of the Agendato be warehoused by the above unit on behalf of DTA/Foreign clients as submitted by the unit subject to unit submitting KYC of their clients alongwith ITR of last 3 years on whose behalf they will warehouse goods, to DC office before commencing first

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transaction by that client, in terms of Instruction No. 117.subject to payment of outstanding rental dues & the unit fulfilling NFE criterion and also subject to following conditions:

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transaction by that client, in terms of Instruction No. 117.subject to payment of outstanding rental dues & the unit fulfilling NFE criterion and also subject to following conditions:

• i. None of the items which are restricted or prohibited will be allowed to be warehoused and any restrictions on import/export of any items will apply unless specifically permitted by the UAC. This clause will have overriding effect for any approval granted in LoA now or before.

• ii. Further, the items will be subjected to the Policy Conditions specified in DGFT’s ITC HS Code wherever applicable.

• ii. Further, the unit must ensure that they should have a tamper-proof ERP/SAP/Tally system with provisions of CCTV with sufficient longer duration of storage & other equipments.

• iv. Further, the transfer of goods from one FTWZ to another FTWZ shall not be allowed except in specific and exceptional cases after consideration by the UAC.

• v. In case of any discrepancy/mismatch between the Description of Goods’ as provided by the Unit & ‘Description of goods as per DGFT Import Policy’, the later will prevail.

• vi. Further, the unit will obtain registration/clearance/any other mandatory requirement prescribed under any Act/Rules from concerned agencies before undertaking of such activities.

• vii. Further, the unit will ensure the compliance of all guidelines, policies issued by any Ministry from time to time pertaining to the items approved in LOA.

e undertaking of such activities.

• vii. Further, the unit will ensure the compliance of all guidelines, policies issued by any Ministry from time to time pertaining to the items approved in LOA.

• viii. Further at the time of import/export/DTA sales of any items, the HSN code has to be examined by the Customs officers at the time of clearance of the goods.

• ix. Further, the unit will give an undertaking that none of the items proposed are falling under negative list and are not hazardous or require environmental clearance for storage/ transmission/ handling and if the items are found in negative list or hazardous in nature, penal action will be initiated against them.

Addition of items in warehousing activity in their Existing LoA for Warehousing Activity— 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.

Shri Rajveer Singh, Authorised Representative of the firm explained their proposal. Shri Singh stated that they have requested for warehousing of additional items.

The Committee noted that the unit has submitted list of 37 items for warehousing wherein some of the items are not available in the DGFT import/export policy and some of the items are sensitive in nature which the Committee is not permitting in warehousing activity.

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The Committee after due deliberation decided to permit the addition of 33 items except items at Sr. No. 1, 2, 23, 35, 36 & 37 of the Agendato be warehoused by the above unit on behalf of DTA/Foreign clients as submitted by the unit subject to unit submitting KYC of their clients alongwith ITR of last 3 years on whose behalf they will warehouse goods, to DC office before commencing first transaction by that client, in terms of Instruction No. 117.subject to payment of outstanding rental dues & the unit fulfilling NFE criterion and also subject to following conditions:

• i. None of the items which are restricted or prohibited will be allowed to be warehoused and any restrictions on import/export of any items will apply unless specifically permitted by the UAC. This clause will have overriding effect for any approval granted in LoA now or before.

housed and any restrictions on import/export of any items will apply unless specifically permitted by the UAC. This clause will have overriding effect for any approval granted in LoA now or before.

• ii. Further, the items will be subjected to the Policy Conditions specified in DGFT’s ITC HS Code wherever applicable.

• ii. Further, the unit must ensure that they should have a tamper-proof ERP/SAP/Tally system with provisions of CCTV with sufficient longer duration of storage & other equipments.

• iv. Further, the transfer of goods from one FTWZ to another FTWZ shall not be allowed except in specific and exceptional cases after consideration by the UAC.

• v. In case of any discrepancy/mismatch between the Description of Goods’ as provided by the Unit & ‘Description of goods as per DGFT Import Policy’, the later will prevail.

• vi. Further, the unit will obtain registration/clearance/any other mandatory requirement prescribed under any Act/Rules from concerned agencies before undertaking of such activities.

• vii. Further, the unit will ensure the compliance of all guidelines, policies issued by any Ministry from time to time pertaining to the items approved in LOA.

• viii. Further at the time of import/export/DTA sales of any items, the HSN code has to be examined by the Customs officers at the time of clearance of the goods.

g to the items approved in LOA.

• viii. Further at the time of import/export/DTA sales of any items, the HSN code has to be examined by the Customs officers at the time of clearance of the goods.

• ix. Further, the unit will give an undertaking that none of the items proposed are falling under negative list and are not hazardous or require environmental clearance for storage/ transmission/ handling and if the items are found in negative list or hazardous in nature, penal action will be initiated against them.

AGENDA ITEM NO. 220.4.1

Addition of raw materials for manufacturing of Nicotine Products in their existing LoA - Request of M/s. Vishnu Export, KASEZ.

M/s. Vishnu Export, KASEZ is an approved unit for manufacturing activity of Pan Masala and Pan Masala containing tobacco-Guthka vide Letter of Approval F.No. KASEZ/IA/010/2013-14/6250 dated 18.09.2013, as amended.

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Now the said unit has requested for addition of raw materials in their existing LoA for manufacturing activity. The unit has expressed their intention for addition of raw materials for manufacturing of nicotine products which was already approved in their LoA.

Shri Anand Mehta, Authorised Representative of the firm appeared before the Committee to explain the proposal. Shri Mehta stated that they have requested for addition of raw materials in their existing LoA for manufacturing of nicotine products as they have received inquiry from new clients.

The Committee asked the unit representatives about the employment they are generating in KASEZ and whether they will be any change in the projected foreign exchange balance sheet. In reply, Shri Mehta stated that they are around 150 persons employed in their plant & regarding projected foreign exchange due to addition of raw materials, they will submit the same.

lance sheet. In reply, Shri Mehta stated that they are around 150 persons employed in their plant & regarding projected foreign exchange due to addition of raw materials, they will submit the same.

The Approval Committee after due deliberation decided to approve the proposal for addition of 14 items in their raw materials list for manufacturing activity in their existing LoA subject to unit submitting revised projected foreign exchange balance sheet and also subject to standard terms and conditions:-

• i. Any restrictions on import/export of manufacturing items and its raw materials will apply.

• ii. Further, the items will be subjected to the Policy Conditions specified in DGFT’s ITC HS Code wherever applicable.

• ii. IN case of any discrepancy/mismatch between the Description of Goods’ as provided by the Unit & ‘Description of goods as per DGFT Import Policy’, the later will prevail.

• iv. Further, the applicant will obtain registration/clearance/any other mandatory requirement prescribed under any Act/Rules from concerned agencies before undertaking of such activities.

• v. Further at the time of import/export/DTA procurement of any items, the HSN code has to be examined by the Customs officers at the time of clearance of the goods.

• vi. 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.

he time of clearance of the goods.

• vi. 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.

• vii. Further, the applicant will give an undertaking that none of the raw materials proposed are falling under negative list and if the items are found in negative list, penal action may be initiated against them.

Addition of items in Warehousing service Activity in their existing LoA— Request of M/s. M M International, KASEZ

The Committee noted that M/s. M M International, KASEZ has requested for permission for warehousing activity of additional items.

No representative of unit appeared before the Committee to explain the

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proposal. Therefore, the Approval Committee after due deliberation decided to defer their proposal.

AGENDA ITEM NO. 220.4.3

Addition of raw material their Existing LoA for Manufacturing Activity —- Request of M/s. D. RikuTazgi Exim LLP- KASEZ.

M/s. D. RikuTazgi Exim LLP- KASEZ is an approved unit for Trading and Manufacturing service activity in Kandla Special Economic Zone vide Letter of Approval No. 24/2024-25 dated 20.01.2025, as amended.

Now the said unit has requested for addition of raw materials in their existing LoA for manufacturing activity.

Shri Ritesh Patavari, Authorised Representative of the firm appeared before the Committee to explain the proposal. Shri Ritesh stated that they have requested for addition of raw materials in their existing LoA as they are receiving inquiry from Europe & USA for existing manufacturing items with change of ingredients.

The Approval Committee after due deliberation decided to approve the proposal for addition of 12 items in their raw materials list for manufacturing activity in their existing LoA subject to unit submitting revised projected foreign exchange balance sheet and also subject to standard terms and conditions:-

• i. Any restrictions on import/export of manufacturing items and its raw materials will apply.

• ii. Further, the items will be subjected to the Policy Conditions specified in DGFT’s ITC HS Code wherever applicable.

• ii. 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.

herever applicable.

• ii. IN case of any discrepancy/mismatch between the Description of Goods’ as provided by the Unit & ‘Description of goods as per DGFT Import Policy’, the later will prevail.

• iv. Further, the applicant will obtain registration/clearance/any other mandatory requirement prescribed under any Act/Rules from concerned agencies before undertaking of such activities.

• v. Further at the time of import/export/DTA procurement of any items, the HSN code has to be examined by the Customs officers at the time of clearance of the goods.

• vi. 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.

• vii. Further, the applicant will give an undertaking that none of the raw materials proposed are falling under negative list and if the items are found in negative list, penal action may be initiated against them.

AGENDA ITEM NO. 220.4.4 Addition of items inWarehousing service Activity in their existing LoARequest of M/s. Maheshwaram Corporation, KASEZ

The Committee noted that M/s. M M International, KASEZ has requested for permission for warehousing activity of additional items.

KASEZ-IA1/15/2025-SEZ-KANDLA

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No representative of unit appeared before the Committee to explain the proposal. Therefore, the Approval Committee after due deliberation decided to defer their proposal.

AGENDA ITEM NO. 220.4.5

Monitoring of ANNUAL PERFORMANCE REPORT (APR) of the 26 units whose LOA is due for renewal/renewed.

As per Rule 54 of the SEZ Rules, 2006, the performance of the units shall be monitored by the Approval Committee as per the guidelines given under Annexure appended to these rules.

The Committee noted that the performance of the 26 units as per the APRs received from the units is submitted for monitoring as per the provisions of SEZ Rules, 2006.

The Committee perused the performance, export/import data of the 26 units whose LOA is renewed or due for renewal and directed the DC office to examine the performance on a case to case basis to ensure as to whether the said units have submitted their APRs in time, whether any foreign exchange realisation is pending, NFE status whether positive or negative and any rental dues/penalty is pending and put up the individual case mentioning the above details before the Committee to monitor their performance and take a decision for renewal of their LoA for further period. The Committee further directed the DC office to inform the individual units to appear before the Committee in next UAC physical/hybrid mode for review of their performance.

LoA for further period. The Committee further directed the DC office to inform the individual units to appear before the Committee in next UAC physical/hybrid mode for review of their performance.

AGENDA ITEM NO. 220.4.6 Constitution of Zonal level team in terms of SEZ instruction No. 117 regarding Guidelines for Operational Framework of FTWZ and Warehousing units in SEZ issued by Ministry of Commerce and Industry dated 24.09.2024 The Committee noted that the SEZ instruction No. 117 regarding Guidelines for Operational Framework of FTWZ and Warehousing units in SEZ issued by Ministry of Commerce and Industry vide F. No. K-43022/24/2024-SEZ dated 24.09.2024 and following guideline is conveyed for strict compliance.

1. Review of guidelines issued by the Department of Commerce regarding the operational framework for FTWZ and Warehousing units.

2. Status of compliance by units relating to KYC, ERP/SAP systems, CCTV surveillance and online processing of transactions through SEZ Online/ICEGATE.

3. Review of physical inspections, Customs audits and monitoring of highrisk commodities.

4. Constitution of a Zonal level team comprising JDC/ DDC/ DC(Customs) /other officers as deemed fit by DC is to be constituted in consultation with Customs wing to study data of NSDL to properly analyse on continuous basis for any

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glaring discrepancy and for strengthening risk assessment measures.

The Committee perused the Instruction No. 117 dated 24.09.2024 and directed the DC office to constitute a Committee to ensure compliance of Instruction No. 117 wherein the Committee so constituted will visit the warehousing on a random basis and report any discrepancy and non-compliance of Instruction No. 117 dated 24.09.2024.

Separate Letter of Approval (LoA) for Manufacturing Activity, Trading Activity and warehousing Service Activity.

The primary objectives of the SEZ, employment generation and export promotion can be effectively achieved only if each activity has a distinct LoA. One of the key drawbacks of a mixed LOA is that a unit may acquire a large plot for manufacturing but use only a small portion for trading or warehousing while showing a positive NFE without actually engaging in significant manufacturing. This leads to suboptimal utilization of the allotted land.

To maintain clarity in monitoring and apply activity specific norms correctly, the Development Commissioner’s office has proposed that the unit should obtain separate Letters of Approval for Manufacturing Activity, Trading Activity and warehousing Service Activity at the time of renewal of existing LoAs of the unit.

Manufacturing, trading and warehousing is different in terms of operational conditions, NFE calculation, performance monitoring, and space or security requirements. Treating them under one approval is difficult to evaluate the unit's performance or future extension or amendment requests.

calculation, performance monitoring, and space or security requirements. Treating them under one approval is difficult to evaluate the unit's performance or future extension or amendment requests.

The Committee noted that many of the units in KASEZ is holding a single LoA for manufacturing, trading and warehousing activity and in view of the challenges observed in the mixed LoAs and the Committee decided to issue separate LoAs for each activity henceforth at the time of renewal/issuance of fresh LoA to new unit as the mixed LOA system makes it difficult to accurately assess the progress of manufacturing, trading and warehousing activities individually, thereby defeating the core purpose of the SEZ.

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

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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.

Digitally signed by Dnyaneshwar Bhalchandra Patil Date: 06-12-2025 19:17:27

(Dnyaneshwar Bhalchandra Patil) Development Commissioner Kandla Special Economic Zone