Trade Bridge Advisors, EXIM, Customs, GST, DGFT, SEZ, FEMA

EOU / STPI · Mumbai, for clients across India

EOU & STPI Consultants in India

EOU and STPI consultants across India: a bridge between your export objectives and the regulatory requirements of the EOU and STPI regimes.

A senior advisor replies within one business day.

Is this you?

Export Oriented Units and STP / EHTP / BTP units.

EOU export-obligation shortfall flagged in the annual return, need the exposure worked out before the review.
Led by
IRS (Retd.) officers
Trade facilitated
₹1,000+ Cr
Litigation handled
₹100+ Cr
Approvals secured
25+

What we do

Your EOU / STPI file, the way we would keep it.

Three stages, fifteen pieces of work, the same advisors at every one. They kept files like this inside the government for decades. Now the file is yours. Open any line for the detail.

  • FTP 2023 Ch. 6
  • HBP Ch. 6
  • Notification 52/2003-Cus
  • DC / STPI Director

Who leads this area

  • R. K. Jain

    R. K. Jain, IRS (Retd.)

    30+ years Indian Revenue Service · Customs, SEZ and Trade Policy

Meet the whole team →
New to EOU / STPI? The 60-second brief

An Export Oriented Unit undertakes to export its entire production (with permitted DTA sales) in exchange for duty-free capital goods and inputs, a regime that lives in Chapter 6 of the Foreign Trade Policy 2023, administered by the Development Commissioner and Unit Approval Committee, and enforced by Customs through the unit's bond. STP and EHTP units are the IT and electronics-hardware variants approved through MeitY's designated officers. Unlike an SEZ, an EOU can sit anywhere. We set units up, keep them compliant, and take them out at the lowest lawful duty.

TRADE BRIDGE ADVISORS LLP · MUMBAI

SUBJECT: EOU / STPI

01 · SET UPBEFORE THE TRANSACTION

What has to be decided, applied for and signed before the first transaction.

  • EOU vs SEZ / MOOWR / DTA-with-schemes: modelled

    The choice usually turns on location (an EOU stays where you are), DTA-sale plans, capital-goods intensity and how you expect to exit. We run all four on your numbers before you apply.

  • Letter of Permission application (UAC/DC; STPI Director for STP/EHTP)

    Investment (para 6.06's ₹1 crore plant-and-machinery threshold and its exceptions), projected exports and NFE, and the exact goods to be manufactured, the DC's office reads these against the sector norms in Appendix 6B.

  • LUT with the DC; B-17 bond with Customs

    The LUT with the DC (para 6.05(c)) and the B-17 general bond with the jurisdictional Customs office, sized to your duty-free procurement, the two documents every later demand is anchored to.

  • Duty-free procurement set-up (Notif. 52/2003)

    Imports under Notification 52/2003-Customs following the IGCR procedure, and domestic procurement on the deemed-export and GST footing, set up so the first consignment does not stall at the port.

  • STP / EHTP registration

    Approval through the MeitY-designated officer, the STPI agreement, and the SOFTEX arrangements a software exporter needs from day one for its export realisation and NFE.

Talk to us about this stage →
02 · OPERATEDURING OPERATIONS

The obligations, records and clocks that keep the benefit from leaking back as a demand.

  • NFE by five-year block, tracked by year

    The para 6.04 obligation is cumulative over five years, and the BoA can extend a block by up to one year on genuine hardship, but only if you ask before the block closes. We keep the ledger that shows where you stand.

  • Annual and quarterly reports to the DC

    The performance reports the Unit Approval Committee monitors under para 6.19, reconciled to your shipping bills, SOFTEX forms and GST returns before they are sent.

  • DTA sales within para 6.07 entitlement

    What can be sold domestically, at what duty and tax, and how it counts against NFE, worked out before the sale, because a DTA sale outside entitlement is a duty demand with penalty.

  • Inter-unit transfer, sub-contracting, repair permissions

    Paras 6.12, 6.13 and 6.15–6.16 permissions and the movement documentation that keeps duty-free goods traceable while they are outside the unit.

  • Bond, IGCR and procurement housekeeping

    B-17 bond adequacy as procurement grows, IGCR intimations, and re-warehousing certificates, the small documents whose absence becomes a large notice.

Talk to us about this stage →
03 · DEFENDWHEN CHALLENGED

Notices, exits, investigations and appeals, argued by people who sat on the deciding side of the desk.

  • Exit priced before it is announced: debonding duty

    Duty on capital goods at depreciated value and on unused duty-free inputs and stock, computed on the dates that matter, timing the intimation can move the bill materially.

  • Exit routes via EPCG or Advance Authorisation

    Para 6.17(d) allows exit on payment of duty on capital goods under the EPCG scheme, and 6.17(g) a one-time exit under Advance Authorisation, both conditional on positive NFE and scheme eligibility. Where the numbers dispute, a BG-backed bond or instalments can keep the exit moving (6.17(e)).

  • STP / EHTP simplified debonding

    For units that never took duty benefit on inputs or capital goods, para 6.17(h) contemplates a fast-track exit, the paperwork still has to prove that negative.

  • Customs demands on the bond

    Show-cause notices for duty-free goods not accounted for, DTA sales beyond entitlement or unfulfilled conditions of Notification 52/2003, answered on the s.28 / s.124 ladder, with the B-17 bond as the department's starting point.

  • FT(D&R) Act penalty for NFE shortfall

    Where NFE or LoP conditions were not met, penalty proceedings under s.11, with the appeal under s.15, run in parallel with any Customs duty demand and are defended separately.

Talk to us about this stage →

LICENCES OBTAINED HERE: EOU APPROVAL (LOP) · STPI REGISTRATION

ON FILE: 6 ANSWERS, READY BEFORE YOU ASK

The EOU / STPI situations we see most, and how we would handle each.

Open the file ▾
Our annual return has flagged an NFE shortfall. What do you do first?

Reconcile before we argue: the five-year block is recomputed from shipping bills and procurement records, because a fair share of shortfalls are reporting errors rather than real ones. Then the exposure is priced, the representation to the Development Commissioner is made before the block closes, and if the FT(D&R) penalty proceeding comes anyway, we defend it on the record we have just rebuilt.

Can you set up a new EOU or STP unit end to end?

From the model to the operating unit: EOU tested against SEZ, MOOWR and DTA-with-schemes on your numbers first, and only then the Letter of Permission before the UAC or the STPI Director, the LUT with the Development Commissioner, the B-17 bond with Customs, and duty-free procurement under Notification 52/2003 switched on properly, so the benefits start on day one, not month six.

Who keeps the unit compliant year to year?

That is this page's standing work: NFE tracked by year inside the five-year block, the quarterly and annual reports to the DC reconciled to your books, DTA sales kept inside the para 6.07 entitlement, inter-unit transfer and job-work permissions current, and the bond and IGCR housekeeping that a Customs visit checks first.

We export software. Do you handle STPI registration and Softex?

Yes, as standing work: STP registration, or non-STP unit registration for exporters outside the scheme, and the Softex certification that FEMA requires for every software export, kept inside its thirty-day window and reconciled so proceeds match in the banking system. Unfiled Softex surfaces years later as blocked remittances and RBI queries; keeping it current is cheap insurance.

We want to leave the scheme. How do you run a debonding?

Priced before it is announced: duty on capital goods at the Handbook's depreciated rates, duty on stock, and where routing the exit through EPCG or an Advance Authorisation lowers the cost, structured that way from the start. Then the DC process, Customs' no-dues certificate and the final order. STP and EHTP units get the simplified route, which we run the same way.

Customs has raised a demand on our B-17 bond. Is that your work or a litigator's?

Ours, because the bond is enforced on scheme conditions, and the defence is scheme knowledge: procurement records, permissions and the NFE position argued to Customs in the reply and hearing. We answer the demand and then fix the housekeeping that produced it, so the bond ledger and the department's stop matching again.

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Tell us what is happening and attach the notice or approval if there is one. A senior advisor replies within one business day. Scope and fees are agreed in writing before work starts: annual retainership · project-based mandates · one-time representations & opinions.

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