AIA: Notification 21/2023-Cus more useful for advance authorization

We have received an invalidation letter from an exporter holding advance authorisation. We want to obtain advance intermediate authorisation so that we can import our inputs duty free and fulfil our export obligation by supplying our finished goods to the advance authorisation holder. Our confusion is whether we should opt for import under customs notification 21/2023-Cus dated April 1 2023 or 22/2023-Cus dated April 1 2023. In fact, we do not understand why two exemption notifications are there for the same purpose of supply to advance authorisation holder. Please guide us. 

I suggest that you opt for notification no.21/2023-Customs dated 1st April 2023 because under that notification you can import without payment of BCD, SWS and IGST, whereas under the notification 22/2023-Customs dated 1st April 2023, you get exemption from BCD and SWS but not the IGST. Secondly, under the said notification 22/2023-Customs, exemption from anti-dumping duty or safeguard duty or countervailing duty on inputs are denied where the supply is to advance authorization holder.  Regarding two exemption notifications for the same purpose, the background goes back to the introduction of GST when IGST was required to be paid on all imports under advance authorizations and there were separate notifications for physical exports and deemed exports. That policy was reviewed in October 2017 and IGST exemption was allowed under the said notification 21/2023-Cus for imports under advance authorisation for physical imports and certain categories of deemed exports also were included under the same notification but the separate notification for deemed exports no. 22/2023-Cus was left undisturbed. 

We have obtained an EPCG authorisation. We intend to fulfill the export obligation mostly by making deemed exports supplies to an export oriented unit (EOU). Is it allowed? 

Yes. Para 5.04 (f) of the FTP clearly says that ‘eexport obligation may be fulfilled both by physical exports as well as deemed exports’. However, please note that the related Customs exemption notification no. 26/2023-Cus dated April 1 2023 allows you to fulfil the export obligation against EPCG authorisations through deemed exports only if you have not availed the IGST exemption on imports of your capital goods under the EPCG authorisation. 

We understand that to help the exporters cope with the difficulties caused by the 50 per cent duty by the United States on goods imported from India, the RBI has given some relief to exporters in respect of the credit facilities availed by them. Please give the specific reference and link for its text so that we can put it before our bankers? 

Through its notification no. RBI/2025-26/96 dated 14th November 2025, the RBI has issued Reserve Bank of India (Trade Relief Measures) Directions, 2025. For the actual text of the notification, please see this link 

Has the government notified the interest equalisation scheme for exporters? 

Not yet. The government had approved the Niryat Protsahan scheme on 15th November 2025 for giving affordable trade finance to MSMEs through interest subvention, export factoring, collateral guarantees, etc. but has not yet notified the details.

Email: tncrajagopalan@gmail.com