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

Shipping & Logistics · Mumbai, for clients across India

Shipping, Port & Bonded Logistics Regulatory Consultants

Regulatory consultants for the operators and carriers that keep India's trade moving: licences, bonds and approvals kept in good standing.

A senior advisor replies within one business day.

Is this you?

Ports, custodians, carriers, bonded facilities, vessels.

“Detention charges disputed after a held consignment, need the position and the recovery route.”
Led by
Retired IRS officers
Trade facilitated
₹1,000+ Cr
Litigation handled
₹100+ Cr
Approvals secured
25+

What we do

Your Shipping file, the way we would keep it.

Fifteen pieces of work, filed by who you are on the waterfront, the same advisors at every counter. They kept files like this inside the government for decades. Now the file is yours. Open any line for the detail.

  • Customs Act ss.7–8, 45, 48, 57–65, 116
  • HCCAR 2009
  • SCMTR 2018
  • MOOWR 2019
  • CBLR 2018
  • MMTG Act 1993

Who leads this area

  • R. K. Jain

    R. K. Jain, IRS (Retd.)

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

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  • Subhash C. Varshney

    Subhash C. Varshney, IRS (Retd.)

    35+ years Indian Revenue Service · Customs, Excise, Service Tax and GST

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  • Ajit U. Nair

    Ajit U. Nair, IRS (Retd.)

    37+ years Mumbai Customs (CBIC) · Customs, Shipping and Trade Disputes

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Meet the whole team →
New to Shipping? The 60-second brief

Between the vessel and the factory, cargo passes through custodians, carriers, agents and warehouses that each hold a Customs approval and carry statutory obligations for it: custodianship under s.45 and the Handling of Cargo in Customs Areas Regulations, 2009; manifests under the Sea Cargo Manifest and Transhipment Regulations, 2018; bonded storage and manufacture under ss.58 to 65; and vessel matters under merchant-shipping law administered by the Directorate General of Shipping. This desk works where shipping, customs and finance meet, so cargo, facilities and working capital keep moving.

TRADE BRIDGE ADVISORS LLP · MUMBAI

SUBJECT: SHIPPING

01 · CUSTODIANS: ICD / CFS / AFSTERMINALS & YARDS

The approval, the HCCAR obligations and the proceedings that threaten the custodianship.

  • ICD / CFS / AFS approvals: IMC Letter of Intent, s.45 custodian

    The IMC application and Letter of Intent, the s.45 custodian appointment, the HCCAR bond and insurance, and the conditions of the approval that will later be enforced against you.

  • Custodian obligations under HCCAR: records, returns, bond

    Records, insurance, security, the s.48 process for uncleared cargo, and the regulation 6(1)(l) waiver mechanics, the day-to-day compliance whose gaps become a suspension notice.

  • Custodian suspension and revocation

    HCCAR regulation 11 proceedings, the show-cause, the inquiry and the record, defended so a condition breach is treated as curable rather than as grounds for revocation.

Talk to us about this stage →
02 · BONDED FACILITIESS.58 & MOOWR

Getting licensed, keeping the records clean and answering the notice when stock or bond slips.

  • MOOWR and private bonded warehousing (ss.58 / 65)

    A s.65 MOOWR licence for import-heavy manufacturing for the domestic market, or a s.58 private warehouse for pure deferral, chosen against FTWZ and EOU on your cash cycle, and structured so removals and returns are routine, not disputed.

  • Bonded warehouse and MOOWR housekeeping

    The s.61 warehousing period and interest, removal and re-warehousing under the 2016 Regulations, MOOWR monthly returns and input-output accounting, and the bond adequacy Customs will test at audit.

  • Warehouse and MOOWR proceedings

    s.58B cancellation, duty demands on bonded goods not accounted for, and MOOWR breach notices, answered on the bond, the records and the Customs ladder.

Talk to us about this stage →
03 · CARRIERS & VESSELSTHE VOYAGE

Registrations, vessel access, manifests and the short-landing penalties that follow the voyage.

  • Carrier and agent registrations (SCMTR, MTO)

    Authorised Sea Carrier and Sea Agent registration under the SCMTR 2018, transhipment bonds, and the arrival and departure manifest obligations under ss.30 and 41 that attach the moment a vessel calls.

  • Vessel access, finance and multimodal matters

    MTO registration under the Multimodal Transportation of Goods Act 1993 with DG Shipping, coastal-trade licensing for foreign-flag vessels, and, for owners considering leasing entities, the GIFT City ship-leasing route on our IFSC desk.

  • Manifests and short-landing

    SCMTR-compliant arrival and departure manifests, amendments, and the s.116 short-landing enquiries that follow a container the manifest said was on board.

  • Transhipment and coastal movement

    Transhipment permits and bonds, movement between customs stations, and coastal-cargo procedure, kept clean so a routine movement does not become a demand.

  • Short-landing and manifest penalties (s.116)

    s.116 enquiries answered with the tally, discharge and survey records that show what actually landed, and the manifest-amendment position that shortens the argument.

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04 · AGENTS, BROKERS & STUCK CARGOAROUND THE CARGO

AEO accreditation, broker licence defence, operator penalties, and the consignment that is stuck right now.

  • AEO-LO for logistics operators

    AEO status for custodians, warehouse operators and logistics providers under the AEO programme, and the facilitation and BG relaxations that come with it.

  • Customs Broker licence proceedings (CBLR)

    For licensed brokers facing CBLR 2018 action, suspension under regulation 16, the regulation 17 inquiry with its 90-day stages, and the appeal, advised on strategy and record; we are not a broker and do not do clearance work.

  • Penalties on carriers, agents and custodians

    ss.112, 114 and 117 penalties on the logistics chain for someone else's declaration, the knowledge and role questions that decide whether the penalty stands.

  • Demurrage, detention and stuck consignments

    The statutory waiver for Customs-held goods, the carrier detention position, and the upstream fix, the classification, document or approval problem that keeps producing the same stuck container.

Talk to us about this stage →

LICENCES OBTAINED HERE: AEO–LO CERTIFICATION · MOOWR LICENCE

ON FILE: 5 ANSWERS, READY BEFORE YOU ASK

The Shipping situations we see most, and how we would handle each.

Open the file ▾
We want to set up a CFS or ICD. Do you take it from Letter of Intent to operations?

The full ladder on this page: the IMC Letter of Intent, the Section 45 custodian appointment, and the HCCAR 2009 conditions negotiated with eyes open, bond, insurance, cost-recovery, because what you accept at appointment governs the next decade. Then the records, returns and bond machinery a custodian must run from the first container onward.

Customs has issued a short-landing notice on our vessel. What is the defence work?

Documentary and immediate: outturn reports and tally sheets secured at the port in the first days, the manifest amended where the gap is clerical, and the Section 116 penalty contested on that record rather than reconstructed a year later in adjudication. The same desk runs the SCMTR and manifest compliance that stops the next notice from being issued at all.

Our Customs Broker licence is under CBLR proceedings. Do you appear?

Yes: the suspension hearing, the inquiry and the defence, built from mandates, KYC records and correspondence, which is to say from what the broker actually knew and did. We also advise brokers and agents on the file discipline beforehand, because in these proceedings the file is the insurance, and we say so on this page in exactly those terms.

As custodians, we face proceedings over cargo that went missing from our facility. Can you defend the approval?

That is custodian defence work: your HCCAR obligations read precisely against what actually happened, the records and returns marshalled, the bond exposure computed, and the suspension or revocation proceeding answered at the Commissioner's desk. The custodianship is the business; we defend it with that weight in mind.

Demurrage and detention are eating a stuck consignment. What can you actually do?

Name the hold's legal basis first, a Customs hold, a custodian's lien, or the carrier's bill-of-lading terms, because the remedy differs entirely with each. Then the right lever: provisional release under Section 110A where goods stand seized, and the charges contested where the law bars them, including HCCAR's bar on rent for periods when Customs itself held the goods. That sorting is a one-day exercise for people who know the waterfront.

YOUR SITUATION IS NOT ON FILE? TWO LINES ARE ENOUGH.

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Start here

Two lines are enough to start.

Tell us what is happening; the notice or approval can follow on WhatsApp or email. 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.

If you have them to hand

  • Your role: custodian, carrier, agent or bonded facility
  • The approval, licence or penalty in question
  • The port or ICD concerned
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