07/08/2019 पर NSEZ के अनुमोदन समिति की बैठक का कार्यवृत्त

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9. 16ro-6 fu+rfl 3nryd (rsBa1 - q.q-drt a?i 6rdTd fi trfr srgan fr frv1 sc ftfirg 3nffid Cit)'Offrce : State Tradrng Corporahon of Indl.l Ltd.-l!h Fl(x)r, Ia$'ahar V1'apar Bharvan, Tt>lstov li'larg, New Delhi-110001 'Iel. Zone Office: [Code- arom olrtsidc t)120 / from Delhi 95120)l 67270,302'1114/ 5/ 6, Fax:256L114,867276 City Otlice Tclefax : 011-26855061: E-mail r<q1]!fg.!!!t!f> : !V0b6ite: <!a{!.nseagqy..!4>

(fuiq, ozlo8/2o1e ti 3nqffrd 3r-{f{fi {fffr # *ao or urfgo The following members of the Approval Committee were present during the meeting:-

1. Shri S.S. Shukla, Jt. Development Commissioner, NSEZ.
2. Shri Rajesh Sharma, Asstt. Commissioner, Customs, Noida Commissionerate.
3. Shri Aman Singh Lohan, Asstt. DGPT, O/o Addl. DGFT, CLA, New Delhi.
4. Shri Sachin Jain, Asstt. Commissioner, DIC, Noida (Rep. of Principal Secretary, Industry, Govt. of UP.)
5. Smt. Nisha Gupta, Income Tax Officer, Income Tax Deptt., Noida'

Besides, during the meeting S/Shri (i) Md. Salik Parwaiz, Specified Officer, NSEZ, (ii) Nitin Gupta, Dy. Development Commissioner, NSEZ, (iii) Pramod Kumar, Asstt. Development Commissioner, NSEZ, (iv) Javir Ali, Steno, NSEZ, and (v) Kapil Muni, JE, UPPCL, Noida were also present to assist the Approval Committee. 3. At the outset, DC, NSEZ welcomed the participants. After brief introduction, each items included in the agenda were taken up for deliberation one by one. After detailed deliberations as well as interaction with the applicants / representatives of the units, the following decisions were taken:- (it hcld on O3lO7 l2ol9. It was informed that no reference against Committee held on 03l07 l2Ol9 was received meeting held on 03l 07 I 2019 were ratified. the decisions of the APProval and, therefore, Minutes of the Noida S Z at 1l:3O AM on O7IO8/2O19 in the Conference Hall ofNSEZ' V/ Page I of 24

I (Eaie, ozlo8/2o19 61 3nqtHn s-1ataa ufrfr fi *co ar ar+go Item wise decisions on proposals included ln agenda: (rAd *Bfi sEtfr ('fi('fifi - fi-sl Ealc arfr6, et{ tr r$ il6.r$ ilrni fi nranl It was informed to the Approval Committee that the M/s. AW Media Servtces LLP has proposed to set up a new unit in NSEZ for "lT/ITES i.e. Web-design & Development, Internet Marketing, Software Development, App Development, Digital Marketing & Alfiliation Services, Search Engine Optimization, Search Engine Marketing, Media Buying through SSA's" with projected exports of Rs. 3451.68 Lakhs and NFE earnings worth Rs.3422.68 Lakhs and proposed investment of Rs. 16 Lakhs and Rs.22.04 Lakhs in imported and indigenous plant & machinery/capital goods respectively, over a period of five years. 1.2 Shri Ved Priy Pandey, partner in the firm appeared before the Approval Committee to explain the project. He informed that AW Media Services LLP is a software and digital marketing entity. They deal u'ith the web and mobile app development to cater the varied range of users. He also stated that they have strong presence into affiliate and digital marketing industry. They are also specialized in targeting Geo's, states, carrier and gender to help their partners get optimized and better results. 1.3 Shri Pandey further informed that all the partners have good experience in the field and they have successfully delivered a good number of web service projects on both mobile applications and web development. 1.4 The Approval Committee observed that detailed work experience/ background of promoters of the firm have not been given in the project report. Shri Pandey informed that the promoters have another ventures in DTA where they are already working. He also claimed to have already submitted relevant documents of their other firms engaged in the same services. However, he could not produce any supporting documents nor did he find any such documents to have been submitted with their application made to O/o DC, NSEZ. Page 2 of

at('fl hrtq 3rfiftfi at-{ rfuia'oz/os/zors 61 3ndfri sr$q rfrtr 4t co rr crfgo 1.5 The Approval Committee further observed that there have been some deficiencies observed in the application which have been conveyed to the applicant for rectification vide this office letter dated 06IOB I 2019. 1.6 The Approval Committee, after due deliberations, deferred the proposal with the directions to Shri Pandey to furnish the following before it is again taken up for consideration: (i). Details of educational background and prior experience of all partners along with name, address, date of incorporation and annual turnover of other ventures of promoters, duly supported with documentary evidence. (ii). Rectification of deficiencies as conveyed vide this office letter dated 06l08l2019. 1.7 Shri Pandey v,'as also directed by the Approval Committee to ensure presence of all three partners before the Approval Committee in its next meeting to be held in September, 2019, arrrdrc r{furr t-+-frdid cr{ic frfrts ({Bs-t) aT 1fi-e-ll qd {+d-lll sFf, SEz ffi 2006 + ft{q 74A t rca sEz t fi-firs qd Eilr6 Ti. 129G/45 T{ Frr fira +' snr 3TT* 3rFndt afi 6rffii d *grf +.;q-dfd rdfizl tntf,ilfis $Stc trfr-s (qfte-tv) r') r+aiaka nTa Fd rFr{l It vvas informed that a proposal dated 24 10612019 was received from M/s. Complete Surveying Technologies Pvt. Ltd. (Unit-l) along with its other two unit (Unit-ll and Unit-lll) (transferor) lor exit from SEZ scheme and transfer of their assets & liabilities including building at Plot No.129G/45, NSEZ in favour of M/s. Complete Surveying Technologies Pvt. Ltd. (Unit-IV). A letter dated 24 l06l2Ol9 from transferee showing its willingness for transfer of building at above respective plot in their favour was also received. 2.2 It was infromed that M/s. Complete Surveying Technologies Pvt. Ltd. has been issued three LOAs which are already running from NSEZ. Plot No' l29G 145, NSEZ has been allotted to Unit-l (i.e. against LOA issued on $/ Page 3 of24

fc,i6 oTlosl2ole 6i 3nqttrfr rrgeIaa sAfr fi r *r ar{-go 27 lO4 l2ol1). Other two units (Unit-ll & Unit-lll - both LOAs issued on 17 10312016) are working on sharing basis with Unit-l at Plot No. 129G145, NSEZ. 2.3 It was further informed that the said request of M/s. Complete Surveying Technologies Pvt. Ltd. (Unit-l) along with its other two unit (Unit-ll and Unit-lll) (transferor) for exit from SEZ scheme and transfer of their assets & liabilities including building at Plot No. 129G/45, NSEZ in favour of M/s. Complete Surveying Technologies Pvt. Ltd. (Unit-IV) was considered by the Committee constituted to examine the cases under Rule 74 (A) and 3rd proviso to Rule 19 (21 of SEZ Rules, 2O06. 2.3.1. Brief details of the proposal are siven below:- Values in Rs. Lalchs Whether formal request for exit from SEZ Scheme has been made by the transferor. Name & Address of Transferor M/s. Complete Surveying Technoiogies Pvt. Ltd. (Unit-l) Plot No. l29Gl45. NSEZ Details of LOA of Transferor: Date of LOA DCP Date of LOA validi 27l04l2OtL 06l to l2ot4 o5lLot20L9 Main Authorized Operations of Transferor l Manufacturing of Professiona-l work bench 2.Manufacturing of PTC Tile Cutter i.e. PTC640 and PTC470 3.Manufacturing of Components/ Spares of Professional Work Bench. 4.Manufacturing of Components/ Spares of PTC Tile Cutter. Yearwise performance of Transferor unit durlng last five years 2014- l5 117.45 2015- 16 181.39 2016-17 2017-\8 514.1E Whether the unit (transferor) has held a valid Letter as on date. \D, Page 4 of 24

il(r$ frrlq 3Trfrfi at-d (friaio ozlo8/2o19 6l JnqtRa :r{m<a {frfr 4l *rc *,t ar+go 7. Whether the unit (transferor) has held a valid lease of land for not less than a period of five years on date of transfer- Yes, Sub lease deed is valid upto 30 /tt /2026. 8. Whether the unit has been operational for a continuous period of minimum two years after the commencement of production as on the date of transfer. Yes 9. a, Whether NOC for mortgage of building has been granted to any Bank/ Financial institution- b. Ifyes, whether No Dues Certificate has been received No 10. Whether No Dues Certificate from EM section received No 11. Whether any Show Cause Notice has been served to the unit under FT(D&R) Act, 1992. No t2. Whether any penalty under FTDR Act has been imposed No r3. Whether any notice under P.P. Act, 1971 has been issued. No 14. Name & Address of Transferee M/s. Complete Surveying Technologies Pvt. Ltd. (Unit-IV). 15. Authorized operations of Transferee Meta-I Sawhorse (lTC HS Code 82060090) 16. Whether the transferee fulfils all eligibility criteria applicable to a unit; if yes, details of LOA of transferee: Date of LOA DCP Date of LOA Validitv 26 /04l2Ot9 N/A 2s /o4l2o2o 17. Performance of the transferee Unit has not yet commenced its activities 18. Whether the transferee has submitted an undertaking on Rs.10O/- non judicial stamp paper for taking over assets & liabilities of transferor unit. Yes Page 5 of 24

o (funia, ozlo8/2o19 tr} 3ndfra rtqf,iq-d rfrtr 4t tco rr ar+p 2.3.2. Details of Unit -ll & Unit-III are as under:- Unlt -[ Untt-III LOA Date t7 /03 12016 17 l03l2016 DCP t8l07 12016 14l07 l20t6 LOA Vatidity 17 / 07 12021 131 07 l2O2t Authorized operations Manufacturing of Articles and Equipments for Table Tennis and accessories/ spares thereof. Manufacturing of (i) Metal Detector (Magnetic Locator), (ii) Spare/Parts of Metal Detector (Magnetic) Performance Values in Rs. Lakhs Values in Rs- l,akhs Year Export NFE Earning Year Export NFE Earnlng 201,6- t7 85.57 39.54 2016-17 46.64 3A.92 20 t7 -t8 150.50 72.94 20t7 - t8 0.00 0.00 Total 236.37 tL2.4a Total 46.64 38.92 2.4 It was informed that in terms of Rule 19(2) proviso 3 of SEZ Rules, 2006 "Provided also that and subject to the provisions of Rule 74A, the Approval Committee may also approve change of the entrepreneur of an approved unit, if the incoming entrepreneur undertakes to take over the assets and liabilities of the existing Unit". 2.5 It was also informed that Rule 74A of the said Rules inter alia provides as under:- "The unit maA opt out of Special Eanomic Zone bg transfering its assels and liabilities to another person bg waA of transkr of otunership including sale of Special Economic Zone units inter alia subject to the follouLing conditions : - 0. The unit hos held a ualid Letter of Approual as well as lease land for not /ess than a peiod of fiue gears on the date transfer. (iil. The unit has been operational for a minimum peiod of two gears afier the commencement of production as on tLrc date of transkr. (iil. Such sale or transkr transactions shall be subject to the approual of the Approual Committee; to a unit; of of The transferee all eli criteia Page 6 of24

nT(rfi fualc sflftffi ar* rBaia'oz/oe/2o19 a,I sndBa 3rgm{a rfrft fi *co rr erfSo and The applicable duties and liabilities, if any, as calculated under rule 74, as well as export obligations of the transferor Unit, if ang, shall stand transferred to the transkree Unit uthich shall be under obligation to discharge the same on the same terms and conditions as the transferor Unit." 2.6 It was further informed that the said Committee observed that the transferor unit has held a valid LOA and lease deed is valid upto 31.05.2026 and has been in operation for more than two years. The Committee was further informed that transferee unit has also valid LOA and has given an undertaking on Rs. 100/- non-judicial stamp paper bearing No. EY 257972 to take over all the assets & liabilities of transferor unit. 2.7 It was also informed that Plot No. 129G/45, NSEZ has been allotted to Unit-l only and other two units are working on sharing basis from the same plot. However, proposal has been given for exit & transfer of all three existing units (Unit-I, II & III) of same company to new unit of same company. 2.a It was further informed to the Approval Committee that the said Committee has decided not to recommend the above proposal as the transferor and transferee are same person. 2.9 Shri Vishwani Puri, director of the company appeared before the Approval Committee. He informed that they have planned to close their existing NSEZ units (Unit-I, II & III) as the export orders for those respective products are very low. 2.7O \t was informed to Shri Puri that in terms of Section 2(v) of SEZ Act, 2005 the definition of persons is as under: "person" includes an indiuidual, whether resident in India or outside India, a Hindu undiuided familg, co-operatiue societg, a companA, u.thether incorporated in India or outside India, a firm, propietary concelT4 or an association of persons or bodg of (v). Page 7 of 24

at('fl hrtq 3fififfi qi{ rEaia'oz/oe/2o1e 61 3ndfur %ratqa sfrfr 6Y tco or rrfgo indiuiduals, whether incorporated or not, local authoritg and any agencA, office or branch oraned or controlled bg such indiuidua| Hindu undiuided familg, co-operatiue, association, body, authoritg or compana; 2.11 lt was further informed that in terms of Rule 74A, a unit may opt out of SEZ by transferring its assets and liabilities to another person. However, in this case proposal is for transfer of assets & liabilities of one unit to another unit of same company, lr.hich does not meet criteria of "another person". 2.12 lt was also informed that even in case of plots where sharing permission have been given, if original allottee is non-functional and unit on sharing permission is working, permission for transfer of assets & liabilities under Rule 74A is not being accorded. Original allottee is required to surrender the plot to NSEZ Authority. 2.13 The Approval Committee, after due deliberations, rejected the proposal of M/s, Complete Surveying Technologies Pvt. Ltd. (Unit-l) along with its other two unit (Unit-ll and Unit-lll) (transferor) for exit from SEZ scheme under Rule 74A of SEZ Rules, 2006 by transferring their assets & liabilities including building at Plot No. l29G 145, NSEZ in favour of their 4s unit. d. hlr v$-.cs fr frLs - LoA il 3Tfr ftTd 3rft -f -d cfi lurrdt +t ilrfril m.{i iq retm; It was informed to the Approval Committee that M/s. Dr. Fresh Assets Ltd. has been issued an LOA dated 19 11211995 for 'Trading, sorting, grading and packaging of: (i) Essential Oils such as Lemon Gross, Lavender, Rosemary, Rose Geranium and Peppermint oil etc. (ii) T\rrmeric Powder, Ginger Powder, Peppercorns Polvder & Dry Extract, Cow Ghee, Honey, Dates and Nuts bars, Ashwagandha Powder, Triphla Tablets, Guduchi Por,"der, Amaranth Muesli, Oats Granola, Other related products. (iii) Organic Ragi Flour, Himalayan Rock Dark Pink Sa1t, Paper Bags (printed craft), Arimedadi Oi1 and Neelibhrigandi Oil. (iv) Amukkura Choornam (12I19049), Meera Herbal Hair Wash Powder (3004901 1), Cinnamon Powder (09062000), Dhanwantaram Tab (3003901 1), Page 8 of24

o #(-fl Fdrtq 3nFfo, qfT tffi ozloet2olg lri 3nq'lfr{ er{rtrff sRfr *l tco ar arfgat Green Cardamom Seeds Powder/ Mixed Spices (09109 100), Chukku Kappi (09 109020), Vata, Pitta, Kapha & Turmeric Soap(340 1 1 19O) , Glass Bottles (70109000), Cardboard Box (48191010), Stickers (49089000), Plastic bottles for packaging(3g241090), Printed Labeis (58071020), Curcuma Longa Jelly (30049079), Organic Desi Chana (lTC HS 0713}". The unit commenced its export production w.e.f. 1510611996 and its LOA is valid till 14 l06l2O2l, 3.2 It was further informed that unit has submitted a proposal for inclusron of Trading of Copper Lota (ITC HS 74181022) in its authorized operations. 3.3 Shri Vijay Pathak, director of the company appeared before the Approval Committee. He informed that they intend to procure the proposed product from domestic market and the packaging and branding will be carried out in the factory for these products. He further stated that they will not claim any Income Tax exemption for such trading export in terms of Instruction No. 4. He further informed that they have made exports worth approx. Rs. 5O Lakhs during May-July 2019. 3.4 It was informed that LOA of the unit was prevlously amended vide this office letter dated 25/06/2019 (afier approual granted bg Approual Committee held on 12/ 06/ 2019) to include trading of Organic Desi Chana in its authorized operations. However, unit has neither submitted acceptance of the said letter nor has executed Bond-cum-LUT, which is non-compliance of terms & conditions of LOA amendment letter dated 251 06l2Ol9. 3.5 It was further informed that Unit, in reply to this office letter dated 29 /O7 l2ol9 vide its letter dated 29 lO7 /2019 has submitted acceptance of LOA Amendment letter dated 2510612019. However, Bond-cum-LUT has sti1l not been executed. 3.6 It was informed to Shri Pathak that the Bond-cum-LUT contains the approval letter no. and its date and it is required to execute revised Bond- cum-LUT before starting procurement for the approved operations. The Approval Committee warned the unit to be careful in compliances of approval Page 9 ol24

o (kaio, ozlo8/2o1e irl 3nqifra sr{atqa {frfr *l tco +r orf{frr letters issued to them in future. 3.7 The Approval Committee, after due deliberations, approved the proposal of M/s. Dr. Fresh Assets Ltd. for inclusion of trading of Copper Lota (ITC HS 7 4181022) in its authorized operations subject to compliance with export policy in force as on date of export and further subject to the following conditions: (i). Import and/or Export of restricted / prohibited items as per ITC(HS) of DGFT will not be allowed. (ii). Unit shall comply with pending statutory compliances already communicated earlier. (iii). Unit shall comply with other prescribed statutory norms, wherever applicable. (iv). 100% physical export shall be done and no DTA sale shall be carried out by the unit. (v). Unit shall not claim Income Tax benefits for trading of items procured from DTA in terms of Instruction No.4 dated 24 lOSl2006. srfd Rfrt.s - fraer6t q?i q'lTrdftiIl d Tffir{ t diifud rFr{l It was informed to the Approval Committee that M/s. Cyient Ltd. has been issued an LOA dated 10 I 11 I 2OOB for Development of Software & IT Enabled Services. The unit commenced its export activities w.e.f . 31 /07 12012 and its LOA is valid rill3} l07 I 2022. 4,2 Shri Sanjit Kumar Pal, authorized representative of the company, appeared before the Approval Committee. He informed that three directors namely Ms. Krishnan Ramachandran, Mr. Paterson John Paul and Mr. Andrea Higgins Bierce have resigned from board of directors w .e.f . 06l 06 I 2019. He further informed that nou, there are 9 directors in the company as under: \y- Page l0 of 24

a a't('sr fretq 3nFf6 qfd tffi oztoet2ole qi 3ndfra $Egtc? {frfr fi *ra ar ar+go

1. Mr. BVR Mohan Reddy
2. Mr. Krishan Bodanapu
3. Mr. MM Murugappan
4. Mr. Alain A De Taeye
5. Mr. Som Mittal
6. Mr. Vinai Kumar Thummalapally
7. Mr. Vikash Sehgal
8. Ms. Matangi Gowrishankar
9. Mr. Vivek Narayan Gour 4.3 It was informed that there have been around 42%o changes in shareholding pattern of the company now with respect to the shareholding pattern intimated by the unit earlier and already taken on records as per following changes:- Shareholdrng in percentage Category Shareholdlng pattenr (as on 13.O7.2O17) Shareholding pattern (as on O6.06.2O19) Foreign portfolio Investors 38.65 44.45 Promoters 22.tA 22.79 Foreign Collaborators t3.49 1.36 Mutual Funds 6.19 t4.74 Foreign lnstitutional Investors 6.01 Resident Individual 5.O2 6.23 Bodies Corporates 4.65 0.88 Non Resident Indians 2.64 2.68 Employees 0.41 o.94 Foreign Nationals o.27 o_26 Trusts o.t4 0.15 Non Resident Indian Non Repatriable o.10 0.10 HUF o.08 0.13 Banks o.o I 0.09 NBFC 0.00 0.00 IEPF 0.08 Clearing Members o.o3 Alternate Investment Fund o.o2 Insurance Company 3.95 \rr-- Page ll of 24

o (frai*, ozloa/2o1e at srqffrfr 3rTfra sftft ft tco ar arfEo 4.4 It was informed that the DOC vide Instruction No. 89 dated 17 lOSl2018 has issued guidelines regarding change in shareholding pattern, name change of SEZ Developer and SEZ Units which inter alia states as under: "s(ii) Re-organisation including Change of name, change in shareholding pottern, business transfer arrangements, court approued mergers and demergers, change in constitution of Units located in SEZs moy be undertaken with the pior approual of Approual Committee in respect of Units subject to the condition that the unit shall not opt out or eit out of the Special Economic Zone and continues to operate as a going concem. All liabilities of the unit utill remain unchanged on such reorganization. 6. Such reorganization shall be subject to the following safeguards: i) Seomless continuity of the SEZ actiuities uith unaltered responsibilities and obligations for the altered entitA; ii) Fulfilment of all eligibilitg criteia opplicable, including secuity clearances etc., bg the altered entity and its constituents ; iii) Applicabilitg of and compliance uith all Reuenue / Compang Affairs / SEBI etc. Acts/ Rules uhich regulote issues like capital gains, equitg change, transfer, taxabilitg etc. iu) FulI financial details relating to change in equitg/ merger, demerger, amalgamation or transfer in ounership etc. shall be furuished immediatelg to Member (lT), CBDT, and Department of Reuenue and to the juisdictional Authoitg. u) The Assessing Offrcer shall haue the right lo assess fhe taxability of the gain/ loss arising out of the transfer of equitg or merger, demerger, amalgamation, transfer and ownerships etc. as may be applicable and eligibility for deduction under releuanl secfions of the Income Tax Act, 1961. ui) The applicant shall complg with releuant State Gouemment latus, including those relating to lease of land, as applicable. Page 12 of

a frsT E{q 3rfifn qt* rfuio, ozlos/zorg al srdtrfr rnelfi wAfr fi *c+ ar trflo srfiar rt 1<fu igr€da1 5.3 It was further informed that unit has submitted addition achieved in respect of Plain Gold jewellery during five years (upto 31/03/2O19) in INR and USD as under: details of value current block of uii)The unit shall fumish details of PAN and juisdictional assessing offtcer of the unit to CBDT." 4.5 It was further informed that DOC vide Instruction No. 90 dated O3lOgl2OlS has also clarified that " Prior approual of BOA/UAC means approual of BOA/ UAC, as the case may be, taken before th.e SEZ entitg / unit is recognized bg the new name or such arrangement in all records. It may not be interpreted that pior approual of BOA/ UAC is to be taken before approaching the Registrar of Companies or the National Compang Laut Tibunal as is being some in some cases came to the notice of this departmenf . 4.6 The Approval Committee, after due deliberations, approved the intimation of M/s. Cyient Limited for change in directors and sharehoiding pattern of the company in terms of Instruction No. 89 dated 17 lOSl2OlS & Instruction No. 9O dated 03/0812018. ftrra ara Fi.dq cr{ie frfttc - fffi6 i'loe fi arrdr t rdilo,,ur qii 3rdcla It was informed that M/s. Kishan Lal Jewels Pvt. Ltd. has been issued an LOA dated 28l08l2OO8 for Manufacturing & Export of Gold, Silver, Platinum Jewellery and Artificial Jewellery with production capacity of 800 kgs per annum. The unit commenced its export production w.e.f . 2610812009 and its LoA is valid till 25 I 08 l2ol9 . 5.2 It was further informed that unit has submitted application for renewal of its LOA for third block of five years and enhancement in production capacity from 80O kgs to 15O0 kgs per annum. Page 13 of24

o (fur+. oTto*t2ore +i fiqtBa rdm{i sfrfr fi iao ar arfEo Value in Rs. takhs Year Export Inputa used Value addltlon requlred Value addltlon achleved 2014- 15 7067.24 701 8.58 3o/" o,69v, 2015- 16 14500.8 1 14364.71 3.5% o.92vo 2016-17 12200.3t 12180,16 3.5o/o 0.1.6% 2017 -14 74593.97 14507 .25 3.5% O.60o/o 20 18- 19 23480.89 2327 4.44 3.5% O.88o/o v 5.4 appeaft achieve fluctuat value a there is seems l USD fo: 5.5 emPloY, and 10( 5.6 20l02l conditi( 22 cts. value a custom "rru .U.rrroo ,o U", ,"r-", O'0.,0 OUU Year : - -Export Inputa 1ffi used I requlred achieved 2014-15 ,l 11606498 l1373526 I 3 lzors-te l:l zzzzottg I zraastoa ) s.sv. I z.stv. 2016-17 , I t8++39tO 17a67a68 I 3,5% 3.220/" 20t7-1a l,l zzqszzzq I 22200300 3.5% I 3.29"/o | 2ot9.te l:l xe4se44 | 32884t28 | 3.s'/, | 3.22% Shri Ajay Gupta, director of the company and Shri Sanjay Gr :d before the Approval Committee. He informed that they I d prescribed value addition in USD. However, due to foreign exchz :ion and difference in import custom rates of USD, it does not s ddition of 37o and 3.5% in INR. He further stated that someti even gold rates fluctuation, hence the value addition in terms of iess but they have achieved the minimum value addition in terrr : every invoice. Shri Gupta further informed that currently there are approx :es in the unit. They have installed machinery worth Rs. 35 Le )7o manufacturing is done in-house. It was informed that unit has been issued a Show Cause Noticr 2015 for Violation of SEZ Rules & Act and non-fulfilment of tern rn of LOA in view of the seizure of 6.225 kgs. Gold & Gold Jewelle: Purity (3 kgs Gold & 3.225 kgs gold jewellery) by NSEZ Custorr bout Rs. 1.73 Crores u,'hile leaving the zone with an intention to e' duty of approx. Rs. 25 Lakhs. The said SCN is yet to be adjudicat was further informed that Show Cause Notice was also is rpta lave mge how mes INR Ls of 4a Lkhs :on rs& ryof Ls of rade ed. iued u- Page 14 of 24

(fuiic' ozlo8/2o1e 61 3nqlBa lrfiff sRtr 6T *co +,t a,rflo against M / s. Kishan Lal Jewels, Plot No. 164, NSEZ dated 27 .01 .20 16 by the Additional Commissioner, Noida Customs Commissionerate and subsequently the case was adjudicated vide impugned Order-in-Original No. 01/JC/CUS/lCD-DD/ 17 dated 25.O1.2OI7 wherein the Joint Commissioner, Noida Customs Commissionerate has ordered for confiscation of goods and imposition of penalty on the unit, its directors and others. 5.8 Shri Ajay Gupta stated that their employee had made an error of negligence without the director's knowledge on 29 lOl l2O 15, where he was exchanging jewellery with gold. At the same time, SEZ Custom verilied their stock found as per book and issued the stock clearance certilicate. Jt. Commissioner, Noida Custom Commissionerate demanded a duty of Rs. 35,82,11O/- before which they had deposited amount ol Rs. 35 Lakhs to safeguard against any duty evasion. He further stated that they have been regularly exporting after this incident since 4-5 years and there has been no violation on their side in these years. 5.9 Shri Gupta further informed that they have also filed an appeal against the Order-in-Original No. 01 /JClCUS/ICD-DD/ 17 dated 25.0 1.2017 issued by the Joint Commissioner, Noida Customs Commissionerate at CESTAT, Allahabad which is still under consideration and is expected to come for hearing in October 2O 19. (A) It was informed that NSEZ Customs vide this office Internal Memo dated 27 l06l2017 was requested to provide details of other offences, irregularities committed by the unit earlier, details of violations to SEZ Act, 2005 and SEZ Rules, 2006, if any along with details of import and export made by the unit during 2016-17 and 2Ol7-18. NSEZ Customs, in reply to Internal Memo dated 27 l0612Ol7 vide their internal note dated 0610812019 has informed as under: "As per information available with this office, it is informed that a Show Cause Notice was issued against M/s. Kishan Lal Jewels, Plot No. 164, NSEZ dated 27.O1.2016 by the Additional Commissioner, v,- Page 15 of24

(fraic, o7lo8/2o1e fiI3nqffrd rrge}fi sBfa fi *co a,t arfqo Noida Customs Commissionerate and subseque ntly the case was adjudicated vide impugned Order-in-Original No. 01/JC/CUS/ICD- DD I 17 dated 25.0 1 .2017 by the Joint Commissioner, Noida Customs Commissionerate. Further, it is also informed that the prosecution complaint has also been filed against Shri Ajay Gupta, director of M/ s. Kishan Lal Jewels and Shri Aminul Islam, one of the employees on 27.05.2019 before Chief Judicial Megistrate (Economic Offences), Meerut with prior approval of Chief Commissioner, Meerut Zone. Further, as per 335-J Register, it is informed that no other offences, irregularities has been noticed against M/s. Kishan Lal Jewels." The details of import and export made by the unit during 2016-17 &' 2Ol7-lB has also been given as under: Year Export (FOB Value) Import 20t6-17 Rs. 1,22,00,31,338/- Rs. 1,23,55,44,860 I - 20L7-tA Rs. 1,53,64,05,8411- Rs. 1,50,66,60,454/- (B) It was further inlormed that there are some mismatch in data of import & export given in APRs for the year 2016-17 & 2017-18 as compared to details received by NSEZ Customs. 5.10 It was informed to the Approval Committee that there is an Instruction No. 41 issued by Deptt. of Commerce which clarifies that in case a unit is NFE negative and claims that it is due to foreign exchange fluctuation, the Approval Committee may consider such cases provided that the unit gets the computations certified by the Authorised Bank, on a case to case, basis' Accordingly, unit vide this office letter dated OSlOSl2Ol9 inter alia has been asked to submit yearwise computation details of value addition for current block of five years duly certified by Authorized Bank in terms of Instruction No.41. 5.1 1 The Approval Committee directed the unit to submit following details: Page 16 of24

rrcr nlfq srfil-o'anr (Eaia, o?/o8/2o1e +i 3rnffrd grdf,trr sfrfr I ttm at ar+go (i) Status of their appeal filed against Order-in-Original issued by Noida Customs Commissionerate. (ii) Yearwise computation details of value addition for current block of five years duly certified by Authorized Bank in terms of Instruction No.41. (iii) Other details/documents as requested vide this office letter dated os l08l2ot9. (iv) Reconcile the data as indicated by them in APRs with the data provided by Customs, NSEZ and submit reconciled data along with revised APRs to this office giving reasons of variation. 5.13 The Approval Committee, after due deliberations, decided to renew the LOA of the unit for a period upto 3110312020 subject to condition that unit shall carry 1007o in-house manufacturing and no sub-contracting shall be allowed. The Approval Committee further directed that the case for further renewal be placed before it on receipt of the information/documents from the unit after examination thereof including achievement of value addition, on file. The Approval Committee also directed to find out the current status of Customs case against the unit and place before it along with other reply from unit for consideration of further renewal of LOA and adjudication of SCN. r.rsis rrcrd (ifgcD Rfrfs - T.r$ fi sTfrfr v{ BoA +'Botq fi srfsr 1o,r$ t rEtttr w g-dfrER tq nranl It was informed to the Approval Committee that M/s. Advance Ispat (lndia) Pvt. Ltd was granted an LOA dated 01/06/2OO4 for Manufacturing & Export of Scaffolding. The unit has commenced its export production w,e.f . 24l11l2006 and LOA of the unit was valid up to 23l11l2016, 6.2 It was further informed that the Approval Committee in its meeting held on 05/ 12 l2Ol8 had decided to treat LOA of M/ s. Advance Ispat (lndia) Ltd. as cancelled as already lapsed w.e.f. expiry of its validity i.e. from 23l1l12016 (conveyed to the unit vide this office letter dated 28l12l2ol8l on the following PagelT of24

(kir, o?/o8/2o19 6t 3ndfrf, rr"f,t'rfr Tfrfr fi tro ar ar{-qo t. \t$|" \t ,/ grounds: i) In view of no export by the unit from 20 10- 1 1 ; ii) LOA has already been expired on 23.\l.2016 and consequently lease deed has also expired in terms of Rule 11(5) on 23.tt.2Ot6; iii) Unit has not applied for extension of LOA and iv) Despite opportunity no one has appeared before the Approval Committee to explain its position with regard to extension of LOA. 6.3 It was also informed that the unit filed an appeal before the BOA against the said order dated 2811212018, which was considered by the BOA in its meeting held on 25l02l2Ol9. As per the minutes of BOA received vide DOC's letter dated OB I 03 I 2Ol9: "The Board heard the appellant and noted that they were not prouided sufficient opportunitg to be heard before the cancellation of their LOP. The appellant also stated that duing the alleged period uLhen exports were not affected due to unfauourable market conditions, the unit was engaged in job work of other SDZ units. The appellant has further stated that the details of such job u-tork done & clearances made would be submitted to the juisdictional DC. The case was remanded to the UAC, NSEZ for reconsideration." 6.4 It was also informed that in pursuance of above directions of BOA this office vide letter dated 26104 l2Ol9 had requested the unit to submit details of job-u,ork done & clearance made by them. The unit vide its letter dated 0610612019 submitted details of job-work done and clearances made by it from 1"t April 2015 to 31st March 2018 along with job-work challan. Page l8 of 24

(friaio ozlo8/2ole dl3ndkd rrgataa sfrfr ft *co ar ar+go 6.5 It was further informed to the Approval Committee that the details of Job-work done and clearances made by M/s. Advance Ispat (lndia) Ltd. during 01.04.2015 to 31.03.2018 has been cross verified by NSEZ Customs and found to be tallied. 6.6 It was further informed that now the unit has submitted application in Form-F1 for renewal of LOA for current block of l-rve years showing following cumulative projections: Value in Rs. Lakhs FOB Value of Export 4t4 Forex Outgo 250 NFE Earnings r64 Imported Capital goods Nil Indigenous Capital goods 31.11 Imported raw material Nit Indigenous raw material 250 6.7 Shri Aashish Aggarwal, director in the company, appeared before the Approval Committee. He informed that the company was doing well until the year 2008-09. However, they faced difficulties due to slowdown in market and unfavourable conditions and their activities of export became negligible from 2008-09 onwards. 6.8 Shri Aggarwal stated that they also have units in DTA from which they have made exports of approx. Rs. 10 Crores. He further stated that their group turnover during previous financial year is approx. Rs. 5O0 Crores. 6.9 The Approval Committee observed that employment of 8 people only in Form-F1. Further, against raw materials to be procured from DTA, Hence, Form-F 1 needs revision. 6.10 It was further informed to the Approval Committee that there have been mistakes in APRs submitted by the unit for the year 2015-16 onwards which also require rectification and unit needs to submit revised APRs. unit has shown projected unit has shown forex outgo which is also not correct. Page 19 of 24

o tfual+- o7toet2o19 a,} 3rnffua sr-dfir rfrfr fi c's,r +rfgat t 6.I 1 Shri Aggarwal informed that they will install machines worth approx. Rs. 25-30 Lakhs as existing machines are very old and require upgrading. He further stated that they are projecting to employ approx. 20-25 peoples for their project. Shri Aggarwal further ensured that they will try to start export production at the earliest. He requested for renewal of LOA and give him sufficient time to re-start their activities. 6.12 The Approval Committee, keeping in view the decision of BOA and having regard to the job-work amounting to approx. Rs. 32 Lakhs annually done by the unit which was duly verified by NSEZ Customs, decided to renew the LOA for a period upto 3l/O3/2O2 l, subject to submission of revised online Form-F1 and a write up regarding his submission about turnover of RS. 500 Crores and export of approx. Rs. 10 Crores of their group and directed the unit to commence their export activities within the renewed period. fttrrrv-s xil{fl crfic Rfrfs - atrsr El}{ 3IIffi6 rl-d d' (fft 7m6 ilrA pg cTiTr(fl It was informed to the Approval Committee that the M/s. Neokraft Global Pvt. Ltd. has proposed to set up second unit in NSEZ for Manufacturing & Export of Base metal mounting fittings and similar articles suitable for furniture, door, staircases, windows (Door/ Furniture Knobs, Hooks, Handles, etc.) of Zinc/ Aluminium/ Iron/Wood/ Stainless Steel with projected exports of Rs. 2lal7 Lakl:,s and NFE earnings worth Rs.2O359 Lakhs and proposed investment of Rs. 383 Lakhs & Rs. 368 Lakhs in indigenous & imported plant & machinery/capital goods respectively, over a period of five years. 7.2 Shri P.K. Jain, Shri Deepak Sharma and Shri Rajeev Ranjan, authorized representatives of the company, appeared before the Approval Committee to explain the project. Shri Jain informed that Neokraft is one of the largest manufacturers of Home Lighting and Home Furnishing articles for IKEA in India. He further stated that they already have an existing unit in NSEZ for manufacturing & export of Home Lighting and Home furnishing articles' Neokraft is having in-house facilities for design, testing, development and Page20 of24

tfudtr 07loel2o19 6) 3lrdfud 3i-.r{fqa rRfr fl *cd' +r qirtgO manufacturing and presently employs more than 45O persons in their existing NSEZ unit. 7.3 Shri Jain further informed that the company is a part of Neolite group which began its operations in 1952. The other division of Neolite group is NeoliteZKW Lighting which is engaged into manufacturing of automobile lightings. The combined workforce of the group is over 2000. 7 .4 Shri Jain informed that the instant project shali be implemented from Plot No. 1364, NSEZ. They have orders from their existing customer viz IKEA as well as other new customer in European countries for the proposed products. 7 .5 It was informed that there were some deficiencies observed in the application which were conveyed to the applicant for necessary rectification. Reply of the same is awaited. Shri Jain ensured to rectify the deficiencies and submit required information at the earliest. 7 .6 The Approval Committee, after due deliberations, approved the proposal of M/s. Neokraft Global Pvt. Ltd. for setting up its second unit in NSEZ for Manufacturing & Export of Base metal mounting fittings and similar articles suitable for furniture, door, staircases, windows (Door/ Furniture Knobs, Hooks, Handles, etc.) of Zinc/ Aluminium/ Iron/Wood/ Stainless Steel, subject to removal of deficiencies conveyed vide this office letter dated 06l 08 I 2019 . ftqr rri?Frfi - dkrcr Eely 3Trft, Etd * r$ Tfirg irrrri fi r+anl It was informed to the Approval Committee that M/s. Shimmer International has proposed to set up a new unit in NSEZ for Manufacturing & Trading of (i) Home Furnishing (5906) and (ii) Ladies, Mens and Kids Garments Apparel Clothing (6202) with projected exports of Rs. 7661.92 Lakhs and NFE earnings worth Rs.2621.92 Lakhs and proposed investment of Rs. 50 Lakhs & Rs. 150 Lakhs in indigenous & imported plant & machinery/capital goods respectively, over a period of five years. Page2l of24

o (Eaio. ozlo8/2or9 a} sndfrr r.rdrff TfrA f,T bo ar ar+go 8.2 It was informed that M/s. Shimmer International had submitted proposal for "(i) Manufacturing of Home Furnishing (5906); (ii) Manufacturing & Trading of Ladies, men's and kids garments, apparel clothing (62021; (iii) Manufacturing of Footwear(6404); (iv) Manufacturing of Imitation jewellery(71 17)". The Approval Committee in its meeting held on 12l06l2Ol9 deferred the proposal keeping in view unrealistic export/ NFE projections vis-a- vis the value of projected raw material and the proposed items being from unrelated sectors. Now, the proposal has been revised with proposed authorized operations as Manufacturing & Trading of (i) Home Furnishing (5906) and (ii) Ladies, Mens and Kids Garments Apparel Clothing (6202). 8.3 Ms. Nidhi Khu11ar, proprietor of the firm and Shri Pramod Khullar appeared before the Approval Committee. Ms. Khullar informed that she has done Fashion Designing from NIFT and also done MBA in International Business. She further informed that she started Shimmer International in the year 2OO5 dealing in High fashion women's wear, Garments and fashion accessories. She further informed that their main export markets are USA, UK and UAE. a.4 Ms. Khullar further informed that she is also a director in M/s. Pertech Exports Pvt. Ltd., an existing unit in NSEZ for Manufacturing & Trading of electronic consumer goods, parts & accessories of mobiles phones etc. 8.5 Ms. Khullar further informed that right now she has orders from UK and UAE for Home furnishing items and Garments. She stated that they will start with 15- 18 employees which will gradually increase. She further informed that they will import the fabric and other raw materials as well as also procure it from DTA. She further stated that they will carry out entire manufacturing activities viz cutting, stitching etc. in the proposed unit. 8.6 It was informed that NSEZ Customs has pointed out that in the items of manufacture submitted by M/s. Shimmer, 'Men's and Kids' Garments Apparel clothing and Home furnishing has also been mentioned in the proposed manufacturing activity. 'Men's and Kids' Garments' falls under Tariff Heading Page 22 of 24

a a'treT E{q 3Trffifi et{ tffi ozloetzors dr sr{tB-d rdm{a {frfr fi tco ar orfEo 6201 whereas Home Furnishing items falls under Tariff Heading 6304. Accordingly, M/s. Shimmer International is required to submit revised list of items of manufacture along with their correct Tariff Heading. 8.7 The Approval Committee deliberated on the proposal and gave Ms. Khullar option to start the proposed unit with manufacturing activities ftrst. Ms. Khullar gave her consent to the Approval Committee to set up unit for manufacturing activities only in start. 8.8 The Approval Committee, after due deliberations, approved proposal of M/ s. Shimmer International for setting up a new unit in NSEZ for Manufacturing of (i) Home Furnishing and (ii) Ladies, Mens and Kids Garments Apparel Clothing only subject to submission of revised Form-F with correct ITC (HS) Code of proposed items of manufacture. ar{trrs - tfrrrd r€$fi *i tr'.t Trfi f,r nraqq+ar ,i 1a.fu sd ciq sfr +'-drfi' fi dqfi r";rfi-dt rf ricmra ilg rranl It was informed to the Approval Committee that M/s. Naimex has been issued an LOA dated 22l08l2OO7 for manufacturing as well as trading activities. The unit commenced its export production w.e.f. 17 lL2l2OO8 and its LOA is valid Lill 16 I 12 I 2023. 9.2 It was further informed enhancement in imported capital revision in projections for current that unit has submitted a request for goods and raw materials requirement and block of hve years as per following details: Rs. in Lakhs FOB Value of Export Forex Outgo Imported Capital goods Indigenous Capital goods Imported raw material Indigenous raw material v- Page 23 of 24

o 1fu 97 1ss12o1e +,t firqtB-fi r{m{n rfrfr *t tco w arfp 9.3 Shri Arjun Uppal, authorized representative of the unit, appeared before the Approval Committee. Shri Uppal informed that their existing machinery was purchased over ten years ago, which need to be upgraded now with a new iine of capital goods. Accordingly, they have submitted revised foreign exchange balance sheet for enhancement of capital goods (imported) and raw materials requirement. 9.4 It was informed that as per proviso 1 of Rule 19(21 of SEZ Ru1es, 2006 the Approval Committee may also approve proposals for broad-banding, diversification, enhancement of capacity of production, change in the items of manufacture or service activiry, if it meets the requirements of Rule 18. 9.5 The Approval Committee, after due deliberations, approved the proposal of M/s. Naimex for enhancement in value of capital goods (imported) and raw materials requirement and revision in projections for current block of five years in terms of Rule 19(2) of SEZ Rules, 2006. Meeting ended with a vote of thanks to the ,""w Jt. Development Commissloner (Dr. L. B. Development Page 24 of 24