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MINUTES OF EPCG COMMITTEE MEETING HELD UNDER THE CHAIRMANSHIP OF SHRI JAIKANT SINGH, ADDITIONAL DIRECTOR GENERAL OF FOREIGN TRADE AT 14:30 Hours ON 25.02.2016

Following officers attended the meeting:

a. Shri Akash Taneja, Joint Director General of Foreign Trade, DGFT b. Shri D.K. Gupta, Director (DBK), Department of Revenue c. Smt. Chitra Sharma, Deputy Director General of Foreign Trade, DGFT d. Shri Kumar Rahul, Deputy Director General of Foreign Trade, DGFT e. Shri S.K. Kala, Foreign Trade Development Officer, DGFT f. Shri S.K. Panigrahi, Economic Officer, DGFT g. Shri A.S. Chauhan, Foreign Trade Development Officer, DGFT

II. Minutes of the Meetings held on 20.1.2016 were confirmed.

III. The Committee deliberated upon all the cases and following decisions were taken:

Sl. No. Firm’s Name and Numbers EPCG Authorisation No.
Subject Decision of the Committee 1. M/s Riviera Home Furnishing Pvt. Ltd., Panipat

01/37/218/223/AM- 16/EPCG-II 3330002334 dated 11.05.2012 (Annual EPCG authorization). Condonation of delay in submission of nexus certificate to RA. The Committee took into account the submission of the party that there was a delay on their part in submission of the nexus certificate issued by Chartered Engineer to RA, Panipat within prescribed time period in respect of the capital goods imported against their annual EPCG authorization. The Committee noted that the party has fulfilled 100% EO in the first block period.

ithin prescribed time period in respect of the capital goods imported against their annual EPCG authorization. The Committee noted that the party has fulfilled 100% EO in the first block period.

The Committee deliberated upon the case and decided to recommend to DG for relaxation under Para 2.58 of FTP 2015-20 to allow condonation of delay in submission of nexus certificate subject to payment of composition fee of Rs. 5000/-.

This has the approval of DG.
2. M/s Utility Forms Pvt. Ltd., New Delhi

01/37/218/208/AM- 16/EPCG-II 0530144118 dated 16.07.2007 Extension of block-wise EO period and extension in EOP for 2 years. The Committee noted that party has stated that they could not fulfil EO during the original EOP due to recession in global markets. The Committee took into account the submission of the party that they have sufficient purchase orders in hand now.

2.58 of FTP 2015-20 to allow:

(a) extension in block-wise EOP, as the party could not apply to RA within the prescribed time

party that they have sufficient purchase orders in hand now.

2.58 of FTP 2015-20 to allow:

(a) extension in block-wise EOP, as the party could not apply to RA within the prescribed time

period. This shall be subject to payment of 2% composition fee on duty saved amount in proportion to the shortfall at the end of each block in terms of the provisions of Para 5.14 (c) of HBP 2015-20; and
(b) extension in EOP for 2 years on payment of composition fee equal to 2% of proportionate duty saved amount on unfulfilled EO or an enhancement in EO imposed to the extent of 10% of total EO at the choice of exporter, for each year of extension sought in terms of provisions contained in Para 5.17 (b) of HBP 2015-20, as the party could not apply to RA within the prescribed time period.

M/s SRF Limited, Gurgaon

01/37/218/221/AM- 16/EPCG-II 0530138309 dated 23.03.2005 0530138730 dated 25.05.2005
0530140680 dated 21.03.2006 0530141276 dated 12.06.2006
Acceptance of installation certificate issued by chartered engineer instead of central excise. submission of the party that they had obtained installation certificate from a Chartered Engineer instead of central excise authorities due to an inadvertent error. However, they had approached the Central Excise authority later who rejected their request for issuance of installation certificate because of delay in applying for the same.

rtent error. However, they had approached the Central Excise authority later who rejected their request for issuance of installation certificate because of delay in applying for the same.

The Committee observed that the party had already submitted the installation certificates from Chartered Engineer within time except in the case of one EPCG authorization No. 0530140680 dated 21.03.2006 where there is a delay of about 3 years.

The Committee deliberated upon the acceptance of installation certificate issued by chartered engineer instead of central excise authority subject to payment of composition fee of Rs.5000/- for each authorization. RA is directed to simultaneously send copies of all installation certificates submitted by the firm in respect of the 4 EPCG authorizations to the jurisdictional central excise authority for verification. In case of any discrepancy action may be initiated by

RA under the FT (D&R) Act, 1992 as amended.

M/s Viswateja Spinning Mills Ltd., Guntur.

01/37/218/145/AM- 16/EPCG-II 0930003343 dated 19.07.2007
0930003402 dated 21.08.2007
0930003512 dated 04.10.2007
0930003604 dated 06.11.2007
0930003647 dated 21.11.2007
0930003717 dated 20.12.2007 EO period and extension in EOP for 2 years.
The Committee noted that the party has stated that they could not fulfil EO during the original EOP due non- availability of exports orders.

2.2007 EO period and extension in EOP for 2 years.
The Committee noted that the party has stated that they could not fulfil EO during the original EOP due non- availability of exports orders. The Committee took into account the have sufficient export orders now and are confident to fulfil their EO during the extended time period.

(a) extension in block-wise EOP, as the party could not apply to RA within the prescribed time period. This shall be subject to payment of 2% composition fee on duty saved amount in proportion to the shortfall at the end of each block in terms of the provisions of Para 5.14 (c) of HBP 2015-20; and
(b) extension in EOP for 2 years on payment of composition fee equal to 2% of proportionate duty saved amount on unfulfilled EO or an enhancement in EO imposed to the extent of 10% of total EO at the choice of exporter, for each year of 5.17 (b) of HBP 2015-20, as the party could not apply to RA within the prescribed time period.

M/s VRV Textile Limited, Guntur

01/37/218/160/AM- 16/EPCG-II 0930004505 dated 30.10.2008 0930002293 dated 12.06.2006 EO period and extension in EOP for 2 years.
The Committee noted that party has stated that they could not fulfil EO during the first block and within valid EOP due to non-availability of export orders. The Committee took into account the submission of the party that they have sufficient export orders now and are confident to fulfil their EO during the extended time period.

export orders. The Committee took into account the submission of the party that they have sufficient export orders now and are confident to fulfil their EO during the extended time period.

(a) extension in block-wise EOP against both authorizations, as the party could not apply to RA within the prescribed time period. This shall be subject to payment of 2% composition fee on duty saved amount in proportion to the shortfall at the end of each block in terms of the provisions of Para 5.14 (c) of HBP 2015-20; and
(b) extension in EOP for 2 years against authorization No.0930002293 dated 12.06.2006on payment of composition fee equal to 2% of proportionate duty saved an enhancement in EO period.

M/s Uttam Galva Steels Limited, Mumbai

01/37/218/212/AM- 16/EPCG-II 0330007280 dated 03.12.2004 Condonation of delay in installation of capital goods. The Committee noted that the party has fulfilled their entire EO within 1st block period.

submission of the party that they had obtained the installation certificate from Central Excise but there was a delay in installation of Capital Goods beyond 18 months. The party has stated that these machines were imported under CKD conditions and assembling and installing the same was complex job which took more time than the normal.

The Committee, therefore, decided to recommend to DG for relaxation under Para 2.58 of FTP 2015-20 to allow condonation of delay in installation of capital goods subject to payment of composition fee of Rs.5000/-

cided to recommend to DG for relaxation under Para 2.58 of FTP 2015-20 to allow condonation of delay in installation of capital goods subject to payment of composition fee of Rs.5000/-

M/s Annamalaiar Mills Pvt. Ltd., Dindigul.

01/36/218/194/AM- 15/EPCG-I 3530002159 dated 24.11.2006 3530002158 dated 24.11.2006 3530002238 dated 20.12.2006 3530002239 dated 20.12.2006 3530001576 dated 16.03.2006 EO and extension in EOP for 2 years. could not fulfil EO during the original EOP due to frequent variability in overseas cotton yarn market during the year 2007 to 2012 and that they have sufficient export/purchase orders now. The Committee noted that the party have fulfilled EO to the extent of US$ 4, 39,065 through third party exports.

Third party exports shall be subject to conditions prescribed in Para 5.10 (d) of HBP 2015-20 read with policy circular 3 dated 02.09.2015.

M/s Hotel Arcadia, Kottayam.

01/36/218/201/AM- 16/EPCG-I 1030000542 dated 14.03.2005 Extension in EOP for 2 years.

d) of HBP 2015-20 read with policy circular 3 dated 02.09.2015.

M/s Hotel Arcadia, Kottayam.

01/36/218/201/AM- 16/EPCG-I 1030000542 dated 14.03.2005 Extension in EOP for 2 years. The Committee noted that the party has fulfilled 85.86% EO during the original EOP and 17.20% after expiry of original EOP.

extension in EOP for 2 years on payment of composition fee equal to 2% of proportionate duty saved amount on unfulfilled EO or an enhancement in EO imposed to the extent of 10% of total EO at the choice of exporter, for each year of extension sought in terms of provisions contained in Para 5.17 (b) of HBP 2015-20, as the party could not apply to RA within the prescribed time period.

M/s Axa Parenterals Limited, Delhi

01/36/218/160/AM- 16/EPCG-I 0530154824 dated 18.02.2011
0530147933 dated 10.12.2008 Condonation of delay in submission of installation certificate issued by central excise. have obtained the installation certificate from the Central Excise authority on 29.10.2013 i.e. beyond the prescribed time period of 18 months from the date of last import of capital goods. The party has informed that the EO has largely been fulfilled in both the authorizations. The Committee decided to recommend to DG for relaxation under Para 2.58 of FTP 2015-20 to allow condonation of delay in submission of installation certificate subject to payment of composition fee of Rs.5000/.

o recommend to DG for relaxation under Para 2.58 of FTP 2015-20 to allow condonation of delay in submission of installation certificate subject to payment of composition fee of Rs.5000/.

M/s Highland Produce Company Limited, Cochin

01/36/218/85/AM- 16/EPCG-I 1030001279 dated 09.01.2008 Transfer of EPCG authorization on the basis of slump sale. case and decided to defer it for further examination on file. 11. M/s Anshika Fasterners Pvt. Ltd., Nagpur.

01/36/218/179/AM- 16/EPCG-I 5030000025 dated 21.01.2010 5030000112 dated 09.06.2011
5030000074 dated 01.10.2010 i. Extension of block- wise EO period against 2 EPCG authorization nos. 5030000112 dated 09.06.2011 & 5030000074 dated 01.10.2010;
ii. Extension in EOP for 2 years in respect of EPCG authorization no. 5030000025 dated 21.01.2010. The Committee noted that the party has fulfilled 16.86% EO against authorization No.5030000025 dated 21.01.2010 and 34% against authorization No. 5031000112 dated 09.06.2011 and Nil against authorization no. 5030000025 dated 21.01.2010.

were unable to fulfil the EO due recession and that they presently have sufficient exports/purchase orders in hand. They have already paid 2% composition fee against two authorizations.

(a) extension in block-wise EOP against 2 EPCG authorization nos. 5030000112 dated 09.06.2011 & 5030000074 dated 01.10.2010, as the party could not apply to RA within the prescribed time period. This shall be subject to payment of 2% composition fee on duty saved amount in proportion to the shortfall at the end of each block in terms of the provisions of Para 5.14 (c) of HBP 2015-20; and
(b) extension in EOP for 2 years against authorization no. 5030000025 dated 21.01.2010 on payment of composition fee equal to 2% of proportionate duty saved an enhancement in EO period.

M/s Haldyn Glass Limited, Mumbai.

01/36/218/185/AM- 16/EPCG-I 3430000960 dated 04.12.2006 i. Extension of block- wise EO period and extension in EOP for 1 year. ii. Condonation of delay in installation of capital goods. The Committee noted that party has fulfilled 83.97% EO in the second block period and 43.23% EO after the expiry of original EOP.

all be subject to payment of 2% composition fee on duty saved amount in proportion to the shortfall at the end of each block in terms of the provisions of Para 5.14 (c) of HBP 2015-20; and

(b) extension in EOP for 1 year on payment of composition fee equal to 2% of proportionate duty saved an enhancement in EO period.

submission of the party that they had imported the capital goods on 13.12.2006 and due to delay in furnace related installation work there was overall delay in installation of Capital Goods beyond 18 months.

M/s N.A.K.G. Cotfibres Pvt. Ltd., Virudhnagar.

18/181/AM-16/P-5 3530002935 dated 24.10.2007 3530002964 dated 06.11.2007 3530003028 dated 20.12.2007 Extension in EOP for 2 years. could not fulfil EO during the original EOP due to instability in export market and cancellation of export orders and that they have export orders in hand.

The Committee noted that description of the items given in the export order is not matching with the export items allowed in the said authorizations.

The Committee decided to defer the same for seeking export orders for the item of export as stated in the authorizations. 14. M/s Bharat Potteries Limited, Jaipur.

01/36/218/200/AM- 16/EPCG-I 1330001541 dated 09.03.2007 EO period and extension in EOP for 2 years.

em of export as stated in the authorizations. 14. M/s Bharat Potteries Limited, Jaipur.

01/36/218/200/AM- 16/EPCG-I 1330001541 dated 09.03.2007 EO period and extension in EOP for 2 years. The Committee noted that party has fulfilled 60% EO during the second block period and also submitted a composition fee for Rs.65100/-.

submission of party that they could not fulfil the EO during original EOP due to slump in international market.

Now they have sufficient export orders and are confident to fulfil their EO during the extended time period.

M/s Excel Nets, Chennai

01/36/218/179/AM- 15/EPCG-I 0430007616 dated 19.08.2009
0430008811 dated 04.08.2010 EO period.
The Committee noted that the party has not fulfilled any EO till date. The Committee took in to account the have sufficient export orders in hand.

extension in block-wise EOP, as the party could not apply to RA within the prescribed time period.

any EO till date. The Committee took in to account the have sufficient export orders in hand.

extension in block-wise EOP, as the party could not apply to RA within the prescribed time period. This shall be subject to payment of 2% composition fee on duty saved amount in proportion to the shortfall at the end of each block in terms of the provisions of Para 5.14 (c) of HBP 2015-20.

M/s Gillette Diversified Operations Pvt. Ltd., Chennai.

01/37/218/103/AM- 16/EPCG-II 0430006003 dated 02.04.2008 Condonation of procedural lapse of not- mentioning the name of the supporting manufacturer in the shipping bills. submission of party that they have fulfilled 100% EO within original EOP.

The Committee noted that party has stated that they had endorsed the name of three supporting manufacturer i.e. M/s Moldwell product India (P) Ltd, M/s Rialto Enterprises (P) Ltd. and M/s Suba Plastic Pvt. Ltd in the said EPCG authorization. However, when the shipping bills were generated, the Customs EDI online software module showed only one supporting manufactures name viz Rialto Enterprises (P) Ltd. for discharge of EO against Advance Authorization due to a limitation in the EDI software which accepts the endorsement of only one supporting manufacturer.
The names of Mouldwell Products India Pvt. Ltd and M/s Suba Plastics Pvt Ltd, Coimbatore are not appearing in the shipping bills generated though the invoice number and authorization no. figures in the shipping bills.

India Pvt. Ltd and M/s Suba Plastics Pvt Ltd, Coimbatore are not appearing in the shipping bills generated though the invoice number and authorization no. figures in the shipping bills.

condonation of procedural lapse of the name of the supporting manufacturer not being reflected in the shipping bills.

M/s Ultratech Cement Limited, Mumbai

01/36/218/154/AM- 16/EPCG-I 0330007967 dated 22.02.2005 0330007968 dated 22.02.2005 Counting of exports prior to endorsement of Group Company for fulfilment of EO. At the first stage RA may examine whether the case is covered under group company provisions as per the Hon’ble High Court’s order dated 20.12.2014 in the matter of M/s Tata Teleservices Ltd WP No.233/2013 and M/s TTML filed WP No.237/2013.

Once RA approves the same the matter will be considered for relaxation.
18. M/s Rothe Erde India Pvt. Ltd., Nashik

01/37/218/65/AM- 16/EPCG-II 3130005607 dated 23.03.2011 3130005308 dated 01.12.2010 3130005372 dated 22.12.2010 Counting of exports made by Group Company for fulfillment of EO. The Committee decided to defer the case for comments from DRI, Kolkata in the matter.

.12.2010 3130005372 dated 22.12.2010 Counting of exports made by Group Company for fulfillment of EO. The Committee decided to defer the case for comments from DRI, Kolkata in the matter.

3130005590 dated 16.03.2011 3130005587 dated 16.03.2011 3130003976 dated 22.04.2009 3130004721 dated 06.04.2010 19. M/s Adhunik Cement Limited.

01/36/218/168/AM- 16/EPCG-I 0230002133 dated 06.02.2007
0230002194 dated 02.03.2007
0230002938 dated 16.01.2008 0230003121 dated 24.03.2008
0230003166 dated 07.04.2008
0230003729 dated 23.10.2008 i. Counting of exports made by Group Company prior to the endorsement of Group Company for fulfilment of EO; ii. Extension of block- wise EO period. At the first stage RA may examine whether the case is covered under group company provisions as per the Hon’ble High Court’s order dated 20.12.2014 in the matter of M/s Tata Teleservices Ltd WP No.233/2013 and M/s TTML filed WP No.237/2013.

Once RA approves the same the matter will be considered for relaxation.

subject to payment of 2% composition fee on duty saved amount in proportion to the shortfall at the end of each block in terms of the provisions of Para 5.14 (c) of HBP 2015-20.

M/s Zee Entertainment Enterprises Limited, Mumbai

01/37/218/195/AM- 16/EPCG-II

Issuance of EPCG authorization for import of Van & Vanity Box without engine Buccaneer Crusier classified ITCHS code 87161000.
case and decided to defer the case due to absence of the concerned technical member.

M/s Jakhau Salt Company Pvt. Ltd, Chennai

01/36/218/265/AM- 13/EPCG-I 3730000107 dated 29.09.2008 Regularization of import of capital goods (i.e. Truck Model Tipper) under EPCG Scheme for the EPCG authorization issued prior to issuance of Policy Circular No. 48 dated 19.12.2008. This case was earlier placed before the EPCG Committee meetings held on 14.06.2013 and 27.04.2015 wherein the case was rejected as extraction of Sea Salt was not found to be a mining activity and that the tipper/dumpers were being used only for transportation of material.

The representative of the party appeared for PH before the Committee. He informed that they are using the trucks only in the

/dumpers were being used only for transportation of material.

The representative of the party appeared for PH before the Committee. He informed that they are using the trucks only in the

premises of their unit and not on road for transportation or for any other purposes.

case and decided to defer it with directions to obtain Registration certificate of the vehicle issued by the Road Transport Authority, confirming that the trucks have been used only in the premises of the mining area. 22. M/s Mahindra CIE Automotive Limited, Mumbai

18/106/AM-16/P-5 0330008519 dated 29.04.2005 Condonation of delay in installation of capital goods. The Committee noted that the party has fulfilled their entire EO within original EOP. However, the capital goods have been installed after 5 years from the date of imports and installation certificate has been submitted thereafter.

submission of the party that the capital goods were cleared by Customs and were kept temporarily at their plant located at Pune for the purpose of refurbishment. This step was taken by them to avoid the heavy demurrage and any damage to capital goods as some of the CG’s were very sensitive to climatic conditions and were installed in three phases finally till the month of November, 2010.

to recommend to DG for relaxation under Para 2.58 of FTP 2015-20 to allow condonation of delay in installation of capital goods subject to payment of composition fee of Rs.5000/.

M/s Ajay (India) Limited, Bhilwara.

01/36/218/189/AM- 16/EPCG-I 1330001717 dated 07.11.2007
1330001447 dated 31.10.2006
1330001625 dated 19.06.2007
1330001506 dated 17.01.2007 EO period and extension in EOP for 2 years. The Committee noted that party has stated that they could not fulfil any EO during the original EOP due to slump in the international market and now they have sufficient exports orders.

(a) extension in block-wise EOP, as the party could not apply to RA within the prescribed time period. This shall be subject to payment of 2%

composition fee on duty saved amount in proportion to the shortfall at the end of each block in terms of the provisions of Para 5.14 (c) of HBP 2015-20; and
(b) extension in EOP for 2 years on payment of composition fee equal to 2% of proportionate duty saved an enhancement in EO period.

M/s BCH Electric Limited, Faridabad.

01/36/218/226/AM- 14/EPCG-I

0530136991 dt. 14.09.2004
0530138420 dt. 07.04.2005
0530138421 dt. 07.04.2005
0530138705 dt. 20.05.2005
0530139378 dt. 25.08.2005
0530139627 dt. 30.09.2005
0530139670 dt. 04.10.2005
0530140049 dt. 15.12.2005
0530140021 dt. 21.12.2005

0530143007 dt. 05.02.2007 11. 0530143261 dated 12.03.2007 12. 0530151469 dt.

dt. 30.09.2005 7. 0530139670 dt. 04.10.2005 8. 0530140049 dt. 15.12.2005 9. 0530140021 dt. 21.12.2005 10. 0530143007 dt. 05.02.2007 11. 0530143261 dated 12.03.2007 12. 0530151469 dt. 09.03.2010
Extension of block wise EOP in 12 authorizations and extension in EOP in respect of 10 EPCG authorizations issued during the period of AM- 05 to AM-10. The Committee noted that the party has fulfilled their entire EO against 2 authorizations No. 0530138420 & 0530138421 dated 07.04.2005.

The Committee further observed that out of other 10 EPCG authorizations in four authorizations the party has not fulfilled any EO and in other 06 authorizations they have fulfilled partial EO.

(a) extension in block-wise EOP against all the 12 Nos. of EPCG authorizations (S.No.1- 12), as the party could not apply to RA within the prescribed time period. This shall be subject to payment of 2% composition fee on duty saved amount in proportion to the shortfall at the end of each block in terms of the provisions of

Para 5.14 (c) of HBP 2015-

20; and
(b) first extension in EOP for 2 years against 09 authorizations (S.No.1 and 4 to 11) on payment of composition fee equal to 2%

of proportionate duty saved an enhancement in EO period. (c) second extension in EOP for further 2 years against 06 EPCG authorizations(S.No.4 to 9) on payment of 50% of duty as per Para 5.11 of HBP (RE:2005).

M/s EIH Limited, Delhi

01/36/218/126/AM- 12/EPCG-I 0530146374 dated 10.06.2008 0530146406 dated 12.06.2008 0530146837 dated 07.08.2008 0530146838 dated 07.08.2008 0530147305 dated 25.09.2008 0530147771 dated 18.11.2008 Reduction in average EO as per para 5.7.4 (ii) of HBP (RE: 2013) for authorizations issued in 2008-09. case and decided to defer if for further examination on file. 26. M/s National Textile Corporation Limited, New Delhi

18/93/AM-16/P-5 1030001059 dated 16.01.2007 1030001036 dated 15.11.2006 EO period. The party took into account the submission of party that due to global market slowdown they could not export during the first block period.

be subject to payment of 2% composition fee on duty saved amount in proportion to the shortfall at the end of each block in terms of the provisions of Para 5.14 (c) of HBP 2015-20.

M/s Viswateja Spinning Mills Ltd., Guntur.

01/37/218/146/AM- 16/EPCG-II 0930002864 dated 02.02.2007
0930002986 dated 16.03.2007
0930003114 dated 25.04.2007 0930002210 dated 03.05.2006
0930002728 dated 30.11.2006 EO period.
were unable to fulfil 50% EO in the first block due to non- availability of export orders. However, they have fulfilled their entire EO 2nd block period.

M/s Krypton Industries Limited, Kolkata

01/36/218/232/AM- 14/EPCG-I 0230001185 dated 18.10.2005 Extension in EOP up to 31.10.2016. The Committee noted that the request of the party for first extension in EOP for one year was earlier placed before the EPCG Committee meeting held on 18.11.2013, wherein committee had granted extension in EOP for one year i.e. up to 30.09.2014.

submission of party that they have exported to the tune of US$ 33,327.92 i.e. about 33% of the total EO during the extended period i.e. up to 30.09.2014 and have 2 purchase orders in hand to fulfil the balance EO.

they have exported to the tune of US$ 33,327.92 i.e. about 33% of the total EO during the extended period i.e. up to 30.09.2014 and have 2 purchase orders in hand to fulfil the balance EO.

second extension in EOP for further 2 years on payment of 50% of duty as per Para 5.11 of HBP (RE:2005).

DGFT = Directorate General of Foreign Trade DG = Director General FTP = Foreign Trade Policy HBP v1 = Handbook of Procedure Vol. I EO = Export Obligation EODC = Export Obligation Discharge Certificate EOP = Export Obligation Period EPCG = Export Promotion Capital Goods

RA = Regional Authority BG = Bank Guarantee FFE = Free Foreign Exchange FE = Foreign Exchange IEC = Importer-Exporter Code DOR = Department of Revenue CLA = Central Licensing Area IEM = Industrial Entrepreneurs Memorandum RCMC = Registration-cum-Membership Certificate

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