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The Federation of Freight Forwarders’ Associations in India (FFFAI) has presented their recommendations to the Central Board of Excise & Customs, Ministry of Finance, Government of India to consider the same in the Finance Bill 2017-18, in order to accelerate smooth exim transactions. In the Pre-Budget Memorandum, which was submitted by Mr Amit Kamat, Honorary Secretary, FFFAI, with detailed analysis, the Federation included the major recommendations that they received from 27 member associations from across the country. Major points included in the recommendations are: Sections 15 (1), 28, 30 (3), 54, 60, 68, 69, 74, 111 (D), 110 (2), 149, 154 and SEZ/FTWZ.
Highlights of the Recommendations:
- The Concept of linkage between of Section 15 and Section 31 should be done way with to facilitate faster clearance and promote the process of Advance Noting 30 days prior to arrival of a vessel.
- In the case of Section 28, where government authority gets two years whereas exporters/importers get only one year to resolve disputes and to claim refunds, it is recommended that the time frame should be the same for both government and exporters/importers.
- Minor amendment or supplement should be allowed electronically by a CHA/Importer as per the requirement of Section 30 (3) and satisfaction of a proper officer.
- Filing of Transshipment Permit (as per Section 54) should be allowed electronically.
- When the provisions of Section 59 have been complied in any respect of any goods, the proper officer may make an order permitting the deposit of goods in a warehouse. In this case jurisdictional authorities of the warehouse should be able to feed the data of warehousing.
- In the provision of Section 69, third country should be allowed for warehousing of goods, for facilitate exporting of imported goods.
- In respect of Section 74, manual filling of Shipping Bill or Bill of Export should be substituted with EDI.
- In view of the introduction of Section 110 (2) pertaining to return of seized goods, Section 110 (2) should be deleted.
- Section 111 D should be amended to “Restricted Goods” than “Prohibited Goods”, to facilitate revenue generation to the government; except the items which can harm domestic market.
- The scope of Section 149 should be widened with suitable insertion that when there is no fraudulent intention and revenue implication, no fine and penalty be levied under this Section.
- Process should be simplified under Section 154 regarding corrections of clerical mistakes.
- SEZ/FTWZ should be synchronized with ICEGATE.
- Mandatory participation of Customs Brokers in Post clearance audit should be enhanced. The Customs Brokers who undertook the clearances should facilitate the Post Clearance Audit.
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