Quick answer
Marg Tax Advisors LLP is an Advance Authorisation consultant for exporters importing duty-free inputs for export production under Notification No. 21/2023-Customs. The work covers norm fixation under a Standard Input Output Norm, a self-declared norm or an ad-hoc reference to the Norms Committee; the Actual User condition and the consumption register that evidences it; export obligation tracking across the standard 18-month period with extensions or regularisation where needed; the 15 percent minimum value addition under paragraph 4.09 of FTP 2023; and EODC through to bond or bank guarantee redemption. The team works from Noida, Delhi NCR, close to DGFT headquarters and the Delhi Regional Authority.
Marg Tax Advisors LLP is an Advance Authorisation consultant for exporters who need duty-free inputs for export production without the norm fixation, consumption register or export obligation position unravelling months later. Advance Authorisation lets an exporter import inputs physically incorporated into an export product free of basic customs duty under Notification No. 21/2023-Customs dated 1 April 2023, provided the import is consistent with the applicable input-output norm and the resulting export obligation is discharged within the period the authorisation allows.
Where this page sits
- Our Foreign Trade Policy Consultants in Delhi page covers Advance Authorisation alongside EPCG, DFIA and the other DGFT schemes at a comparison level. This page goes into the scheme on its own, in the depth an authorisation actually needs once a business has decided this is the route it wants.
What Our Advance Authorisation Consultant Team Handles
- Norm fixation, whether under an existing Standard Input Output Norm, a self-declared norm, or an ad-hoc norm referred to the Norms Committee.
- Application drafting and filing, including the input-output ratio the authorisation is built on.
- Actual User condition compliance and consumption register maintenance mapping imports to production and exports.
- Export obligation tracking, extension applications, and regularisation where a genuine shortfall has occurred.
- Value addition calculation and verification before the application is filed, not after it is questioned.
- EODC application and the bond or bank guarantee redemption that follows it.
- Clubbing of authorisations and annual requirement licensing for exporters with an established track record.
How Norms Are Fixed: SION, Self-Declaration and Ad-Hoc Norms
The input-output norm an authorisation is built on can come from three different sources, and which one applies changes both the speed of getting the authorisation and the scrutiny it faces later.
| Route | How It Works |
|---|---|
Standard Input Output Norms (SION)Fastest |
A pre-notified ratio published in the Handbook of Procedures for the specific export product; where a SION exists, the authorisation can be issued against it without a separate technical justification |
Self-declared normAudited later |
Used where no SION exists for the product; the applicant declares the input-output ratio, the authorisation is issued on that basis, and the declared ratio is subject to ratification and audit later, which makes getting the underlying calculation right at filing stage important |
Ad-hoc normNorms Committee |
Referred to the Norms Committee for a technical determination where the product or process does not fit an existing SION and a self-declared norm is not the right route; this takes longer and needs a more detailed technical submission |
Marg Tax Advisors works out which route actually fits a client's product before filing, since choosing self-declaration where an ad-hoc reference was really needed, or the reverse, adds delay that a correct route selection avoids.
The Actual User Condition and Consumption Registers
Inputs imported under Advance Authorisation are ordinarily subject to an Actual User condition: they have to be used by the authorisation holder in the manufacture of the export product, not sold in the domestic market or diverted to a different use. Demonstrating that compliance depends on a consumption register that maps each import to the production batch and the export shipment it went into, maintained contemporaneously rather than reconstructed at the time of EODC application. Marg Tax Advisors sets up this reconciliation at the outset, since a consumption register built after the fact, once questions are already being asked, is far harder to defend than one maintained as imports and exports actually happen.
Export Obligation: Period, Extension and What a Shortfall Means
The standard export obligation period runs 18 months from the date the authorisation is issued, though the period, and the extension provisions available if a business is running behind, are revised from time to time in the Handbook of Procedures and should be confirmed against the version in force for a given authorisation. Where the obligation is genuinely at risk of being missed, an extension application or, where the shortfall is limited, a regularisation route allowing payment of duty and interest on the shortfall can keep the authorisation from turning into a full default.
If a default has already happened
- The consequences, and the appeal route available, are covered in full on our Foreign Trade Policy Consultants in Delhi page. This page focuses on avoiding that outcome through active tracking and, where needed, timely regularisation.
Value Addition: The Minimum Threshold
Advance Authorisation carries a minimum value addition requirement, calculated as the difference between the FOB value of the export and the CIF value of the imported inputs, expressed as a percentage of that CIF value. The minimum value addition is 15 percent under paragraph 4.09 of FTP 2023, and the narrower set of product categories where a different threshold applies are set out in the Foreign Trade Policy and revised periodically, so Marg Tax Advisors verifies the current figure against a client's actual costing before an application is filed rather than assuming a threshold that may have moved since the last authorisation was issued.
EODC and Bond or Bank Guarantee Redemption
Closing an Advance Authorisation file means reconciling the consumption register against shipping bills and bank realisation certificates, filing the EODC application, and following it through to bond or bank guarantee cancellation with customs.
The scheme-wide EODC process
- Our DGFT Consultant in Delhi page covers the EODC and redemption process that applies across DGFT schemes generally. The Advance Authorisation specific step on top of that is the input-output reconciliation itself, which is only as strong as the consumption register kept during the export obligation period.
Clubbing of Authorisations and Annual Requirement Licensing
Clubbing of authorisations
Exporters with more than one Advance Authorisation for the same product and duty exemption entitlement can, in defined circumstances, apply to club the authorisations together, which simplifies EODC closure by treating the combined export obligation as one.
Annual requirement licensing
Exporters with an established export track record also have the option of an annual requirement authorisation rather than filing a fresh application against each contract, which reduces the filing burden but still carries the same norm, Actual User and export obligation conditions underneath it.
Why a Delhi Based Advance Authorisation Consultant Matters
DGFT headquarters and the Delhi Regional Authority both sit in the city, which matters when a norm fixation reference goes to the Norms Committee or an export obligation extension needs a Regional Authority follow-up. Marg Tax Advisors' office in Delhi NCR keeps that coordination close to where these applications are actually decided.
Who You'll Work With
Shashank Shekhar Gupta
Founder, Chartered Accountant and Lawyer
Advance Authorisation work at Marg Tax Advisors is led by Shashank Shekhar Gupta, founder of the firm, a Chartered Accountant and a lawyer whose stated areas of practice include export and import law directly.