FTWZ · Mumbai, for clients across India
FTWZ Consultants in India
FTWZ consultants in India: specialised support for the operational demands of an FTWZ unit, and for the foreign supplier or distributor using one.
A senior advisor replies within one business day.
Is this you?
Free Trade Warehousing Zone units and their clients.
“Holding re-export stock in an FTWZ, need the duty-deferment position and the unit approval route.”
- Led by
- IRS (Retd.) officers
- Trade facilitated
- ₹1,000+ Cr
- Litigation handled
- ₹100+ Cr
- Approvals secured
- 25+
What we do
Your FTWZ 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.
- SEZ Act s.2(n)
- SEZ Rules rr.5, 11, 17–19, 53, 74
Who leads this area
R. K. Jain, IRS (Retd.)
30+ years Indian Revenue Service · Customs, SEZ and Trade Policy
New to FTWZ? The 60-second brief
A Free Trade Warehousing Zone is a Special Economic Zone in which mainly trading, warehousing and related activities are carried on, s.2(n) of the SEZ Act, 2005. Goods can be held in India without payment of duty, re-exported freely, and released to the domestic market only when sold, on a bill of entry. We advise foreign suppliers, Indian distributors and logistics providers on structuring, approval and operation of FTWZ activity, and on the disputes that arise when stock, value or NFE is questioned.
TRADE BRIDGE ADVISORS LLP · MUMBAI
SUBJECT: FTWZ
What has to be decided, applied for and signed before the first transaction.
Own unit vs client of an existing FTWZ unit
A unit needs UAC approval, a bond and its own NFE; a client uses the unit's approvals under a warehousing agreement. We model both against your volumes, control needs and the tax position of the eventual DTA sale.
Fit-check against a Customs bonded warehouse (s.58)
For pure duty deferral of a single importer's goods, a private bonded warehouse under Customs Act s.58 can be simpler. FTWZ wins on multi-country distribution, holding goods for non-residents, and services on goods. We compare both on your actual flows.
Form F proposal to the FTWZ's UAC → LoA
Authorised operations drafted to cover exactly what you will do to the goods, warehousing, packing, labelling, kitting, re-export, because anything not authorised is a later dispute.
Warehouse service agreement
For clients of a unit: title, custody, insurance, who declares value on removal, and who answers the Specified Officer if stock does not reconcile. These clauses decide who carries the demand.
Entry structure for the foreign supplier
Whether the non-resident holds title in the zone, sells to a distributor before or after removal, and how invoicing and FEMA remittance run, settled with the International Trade desk before the first consignment.
The obligations, records and clocks that keep the benefit from leaking back as a demand.
Inventory that reconciles to SEZ Online
Receipt, storage, service and removal records maintained so the Specified Officer's stock check matches your books, the single most common trigger for a demand in a warehousing zone.
Authorised operations on the goods (labelling, kitting, repacking)
Packing, labelling, kitting and similar operations performed only within the LoA's authorised list, with the paperwork that shows the goods stayed within the zone while it happened.
Removals to the DTA: bill of entry, value, duty
The bill of entry, the value declared at removal, and the classification, settled with the eventual buyer before the goods move, because valuation at removal is where FTWZ disputes usually begin.
NFE for a trading unit; APR
Rule 53 applied to trading and warehousing turnover, tracked by year so the five-year block is never a surprise. Trading and manufacturing, if both exist, are kept in separate records under Rule 22.
GST at each leg (supply into / out of the zone)
Supplies into the zone for authorised operations are zero-rated under s.16 of the IGST Act; sales while goods remain in the zone, and IGST on removal, are treated correctly so the DTA buyer's credit is clean.
Notices, exits, investigations and appeals, argued by people who sat on the deciding side of the desk.
Stock-difference demands
Answering a show-cause notice that presumes diversion: reconciling receipts, services and removals from your own records and the zone's, and confining the demand to what is actually unexplained.
Valuation on removal
Where the officer rejects the declared value on a DTA removal, the Customs Valuation Rules apply, related-party pricing, later sale prices and additions are argued the same way as at a port, and the SVB position of the buyer matters.
Exit under r.74
Duty on goods in stock and on capital goods at depreciated value, the Form L undertaking, and the NFE position at exit; where NFE is short, penalty exposure under s.11 of the FT(D&R) Act.
Developer / operator disputes
When the FTWZ unit, the developer and the client disagree about custody, charges or who answers a notice, the agreements and the LoA decide, and are read before the first letter is sent.
Board of Approval appeals
Against an Approval Committee order or an LoA cancellation, Form J to the Board within thirty days of receipt (Rules 55–56), separate from any Customs demand running in parallel.
LICENCES OBTAINED HERE: FTWZ UNIT ONBOARDING
ON FILE: 4 ANSWERS, READY BEFORE YOU ASKThe FTWZ situations we see most, and how we would handle each.
Open the file ▾Close ▴
We want to hold re-export stock in an FTWZ. What exactly do you set up?
The structure before the paperwork: your own unit or client-of-unit status with an existing FTWZ unit, tested against a Section 58 bonded warehouse before you commit, because sometimes the simpler instrument wins. Then the Form F proposal to the zone's UAC, the Letter of Approval, the warehouse service agreement, and the entry structure for the foreign supplier whose title stays on the goods.
Our foreign principal will not open an Indian entity. Can it still use an FTWZ?
Yes, as a client of a unit, and that is precisely the design work on this page: the agreement between the foreign owner, the unit and the eventual buyers written so that title, duty and GST land where intended. The law fully supports foreign-title inventory resting in the zone; the paperwork has to be built to deserve it.
Who handles our removals from the zone into India?
We build that machinery once: the bill of entry practice on removal, valuation positions settled in advance rather than argued shipment by shipment, GST mapped at each leg into and out of the zone, and inventory that reconciles to SEZ Online, so a stock-difference demand never finds a gap to stand on.
The zone has raised a stock-difference or valuation demand. Do you defend it?
Yes, it is this page's defend stage: the reconciliation first, because these demands are won on records, then the reply and hearing, and the Board of Approval appeal where the matter must go up. Where the dispute is with the developer or operator rather than the authorities, we handle that lane too; it is listed here because it happens.
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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.