CBIC shouldn't need registration of MEIS transmitted online by DGFT

'In my view, registration should not be necessary at all where MEIS is directly transmitted by the DGFT to the Customs', says the author

For registering the MEIS scrips issued on-line we are required to take a print out of MEIS and send it to the CHA and also incur some costs. Is there any way to register such MEIS scrips online?

The CBEC had removed the requirement for pre-registration verification of the genuineness of MEIS/SEIS for the scrips transmitted directly from the DGFT portal to the Customs portal. However, the requirement of registration itself has not been withdrawn. So, what the CHAs do is to submit a copy of the print out of MEIS and seek registration. The Customs immediately register. That entails some costs. In my view, registration should not be necessary at all where MEIS is directly transmitted by the DGFT to the Customs. But, the CBIC has not issued that specific instruction. I think the CBIC should withdraw the registration requirement where the MEIS/SEIS is directly transmitted from DGFT to Customs. 

Will transfer of RoDTEP credits attract GST?

‘No’, in my opinion. S.No.122A in Schedule to the notification 2/2017-CT(Rate) and similar notifications under the IGST/SGST/UTGST laws fully exempt duty credit scrips falling under the classification 4907. Of course, whether the virtual RoDTEP scrips can be considered as falling under 4907 or whether they can be considered as goods at all is an open question as they have no physical existence but are only credits in an electronic ledger. 
 

We imported some goods that are not compliant with the Plant Quarantine (Regulation of Import into India) Order 2003. We had already filed the bill of entry and paid the duty also. The non-compliance was detected by the authorities after testing the samples from the imported consignment. What is the way forward?

Para 7.2(iii) of Chapter 8 of the CBEC Customs Manual 2018 (relevant part) says that detention order is issued, if the consignment is imported in contravention of the Plant Quarantine Regulations, for arranging deportation failing which the same shall be destroyed at the cost of importer under the supervision of the Plant Quarantine Officer, in presence of Customs Officers after giving due notice in advance i.e. for perishable plant material 24-48 hours and 7 days for other plant material. However, the duty you paid may be remitted in accordance with Section 23(1) of the Customs Act, 1962. It says that without prejudice to the provisions of section 13, where it is shown to the satisfaction of the Assistant Commissioner of Customs or Deputy Commissioner of Customs that ‘any imported goods have been lost (otherwise than as a result of pilferage) or destroyed, at any time before clearance for home consumption, the Assistant Commissioner of Customs or Deputy Commissioner of Customs shall remit the duty on such goods’.

Do we have to get GR waiver for re-export of goods imported as a result of bonafide mistake and shipped contrary to our instructions by foreign party?

No. CBEC Circular no.100/2003-Cus dated 28.11.2003 says that NOC from RBI will not be necessary in such cases.