DGFT Compliance, Show-Cause & PRC Representation

Consultant reviewing a notice with a client

Overview

Compliance Support at a Glance

When an obligation is missed or a notice arrives, acting early usually limits the damage. We review the facts, explain your options, prepare replies, regularisation requests and hearing submissions, and help you put checks in place so it does not happen again.

Who needs this

Businesses that have received a DGFT or Customs show-cause notice
Authorisation holders who missed an export obligation deadline
Firms placed on the Denied Entity List
Exporters who want a health check of open licences and claims

WhatsApp Us +91 86888 47997

FT(D&R) Act, 1992 Legal Defense

Show-Cause & Adjudication Proceedings

Failure to fulfill export obligations under Advance Authorisation or EPCG schemes within the statutory window triggers Demand-cum-Show-Cause Notices from Regional Authorities under Section 11(2) and Section 14 of the Foreign Trade (Development & Regulation) Act, 1992.

Detailed Reply Drafting: Reconstructing historical export performance, reconciliation of Shipping Bills against BRCs, and legal justification under FTP provisions.
Personal Hearing Support: We prepare written submissions and hearing notes, and support you or your authorised representative before the Adjudicating Authority.
DEL (Denied Entity List) Delisting: When an IEC is placed under DEL (blacklisted from cross-border trade and incentives), we file for immediate stay, bank guarantee substitution, and formal removal.
Appellate Representation (Section 15): Filing statutory appeals before the Zonal Additional DGFT or Central Government against adverse adjudication orders.

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Common Triggers for DGFT Notices

Expiry of 18-month export window under Advance Authorisation without filing ANF-4F.
Failure to achieve 50% block export obligation by Year 4 under EPCG scheme.
Non-submission of Chartered Engineer Installation Certificate within 6 months.
Rejection of ad-hoc norms by the DGFT Norms Committee creating duty shortfalls.
Discrepancy between ICEGATE export shipping bill records and DGFT e-BRC registers.

Powers of the PRC (Para 2.58)

Under Paragraph 2.58 of the Foreign Trade Policy 2023, the Director General of Foreign Trade (DGFT) possesses discretionary plenary powers to relax any provision or procedure of the policy or handbook in cases of genuine hardship or bona fide operational difficulties.

PRC requests are decided at DGFT Headquarters, New Delhi. We prepare the case file and supporting documents for submission.

DGFT Headquarters, New Delhi

Policy Relaxation Committee (PRC) Petitions

When regional DGFT offices exhaust their statutory jurisdiction to extend export timelines or forgive procedural omissions, the matter can only be salvaged by petitioning the apex Policy Relaxation Committee (PRC) in New Delhi.

Condonation of Procedural Lapses: Petitions for accepting delayed submission of installation certificates or unlinked shipping bills.
Special Extension of Export Obligations: Securing additional time beyond standard limits due to force majeure, geopolitical disruptions, or factory strikes.
Composition Fee Settlement: Regularising defaults through nominal composition fees rather than confiscatory penal interest.
Clubbing Across Dissimilar Policy Periods: Special relaxation to merge older authorisations with modern schemes.

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Proactive Governance

Annual EXIM Compliance & Health Audits

Rather than firefighting after receiving customs summons or DGFT recovery orders, enterprise exporters engage our annual compliance retainer to monitor risk continuously.

Input-Output Waste Register Maintenance: Verifying factory consumption accounts against SION ratios to prepare for Central Tax audits.
Mandatory Annual IEC Profile Confirmation: Ensuring annual updating before the statutory June cutoff to prevent customs suspension.
EDPMS & IDPMS Reconciliation: Reconciling bank foreign inward remittances (FIRC/e-BRC) with the Reserve Bank of India portal to avoid RBI caution-listing.

Indirect Tax Liquidity

GST Refund on Exports & IGST Clearing

Zero-rated exports entitle businesses to full refund of taxes paid on input goods and services, as well as automatic refund of IGST paid on export shipping bills.

Refund of Accumulated ITC (Without Payment of Tax): Filing RFD-01 for zero-rated supplies under Letter of Undertaking (LUT).
Resolving ICEGATE Error Codes: Rectifying invoice number mismatches, port code discrepancies, and bank PFMS verification failures (SB005, SB006 errors).
Inverted Duty Structure Refunds: Recovering cash balances where tax on inputs exceeds tax on finished export outputs.