New requirements for filing of Annual RODTEP Return (ARR)
NEW DELHI : In a major update to its export policy, the Government of India has issued a directive mandating the filing of an Annual RoDTEP Return (ARR) for exporters benefiting from the Remission of Duties and Taxes on Exported Products (RoDTEP) scheme. This new requirement, announced by the Directorate General of Foreign Trade (DGFT) aims to ensure accuracy in duty remission claims by exporters and streamline compliance in the use of RoDTEP benefits.
The ARR filing directive, detailed under the newly added Para 4.94 in the Foreign Trade Policy (FTP) Handbook of Procedures (2023), requires exporters with RoDTEP claims exceeding Rs. 1 crore in a financial year to file their returns by March 31 of the subsequent financial year. Failure to file the ARR will lead to the suspension of benefits under the RoDTEP scheme, and additional fees will be imposed for late filing.
Pharma exporters claiming more than Rs. 1 crore under RoDTEP for a financial year must submit the ARR by March 31 of the following year. For example, claims made in Financial Year (FY) 2023-24 must be filed by March 31, 2025.
Non-compliance will lead to a denial of benefits. A grace period until June 30 will allow late filing with a composition fee of Rs. 10,000. After June 30, this fee doubles to Rs. 20,000. Once applicable fees are paid, RoDTEP claims processing will resume within 45 days. Exporters must maintain records for five years to support their ARR submissions. Records will be subject to periodic assessments by the DGFT and may influence future RoDTEP rates, especially if discrepancies are identified.
ARR filings may also be periodically assessed for necessary due diligence and presented before RoDTEP Committee for suitable revision of rates including for the consideration of higher rates wherever warranted.
Certain ARR cases may also be identified by the Income Tax (IT)-assisted risk-based criteria, for further scrutiny to assess the nature of inputs used in export production and the amount of actual taxes and duties incurred, as permissible under Para 4.54 of FTP. After due assessment is made by the concerned authority, who has been mandated in this regard, the RoDTEP scrip holder will be liable to refund/surrender any excess claims based on the order passed after the scrutiny under the relevant customs head. Failure to regularise the excess claims within a specified time frame will lead to stopping of further benefits under the Scheme.
This directive marks an essential step in enhancing the transparency of duty remission claims and ensuring the proper utilization of the RoDTEP scheme for India’s exporters.