Annual RoDTEP Return (ARR)

Navigating the Annual RoDTEP Return (ARR): A Comprehensive Guide for Exporters

Introduction

The Directorate General of Foreign Trade (DGFT) has introduced the Annual RoDTEP Return (ARR) as a mandatory compliance requirement under Chapter 4 of the Handbook of Procedures (HBP) 2023. The ARR is a crucial filing for exporters leveraging the Remission of Duties and Taxes on Exported Products (RoDTEP) scheme, ensuring transparency and accuracy in claims. In this guide, we will break down the essential aspects of ARR compliance, helping professional exporters understand the filing process and optimize their RoDTEP benefits.

What is the Annual RoDTEP Return (ARR)?

The ARR is a newly mandated annual filing aimed at refining the RoDTEP mechanism by thoroughly reviewing exporters' claims. This compliance measure primarily applies to exporters whose total RoDTEP claims exceed INR 1 crore in a financial year.

Key Compliance Considerations

1. Threshold-Based Filing Requirement

• Exporters with total RoDTEP claims exceeding INR 1 crore are mandated to file the ARR.

• If claims are below INR 1 crore, filing is not required.

2. ITC-HS Code Specific Filing

• If no single 8-digit ITC-HS code claim exceeds INR 50 lakhs, the ARR must be filed only for the ITC-HS code with the highest claim amount.

• If any ITC-HS code claim exceeds INR 50 lakhs, ARR must be filed for each of those specific codes.

Example:

If an exporter has a total RoDTEP claim of INR 1.2 crore, distributed as:

• ITC-HS1: INR 20 lakhs

• ITC-HS2: INR 30 lakhs

• ITC-HS3: INR 40 lakhs

• ITC-HS4: INR 30 lakhs

The ARR should be filed only for ITC-HS3, as it has the highest claim amount.

However, if any single ITC-HS code exceeds INR 50 lakhs, separate ARR filings are required for each of those codes.

3. Separate ARR for DTA and AA/EoU/SEZ Exports

• Exporters must file separate ARR applications for:

  • Domestic Tariff Area (DTA) exports

  • Advance Authorization (AA) / Export Oriented Unit (EoU) / Special Economic Zone (SEZ) exports

4. Tax/Duties/Levies Reporting

• All applicable taxes, duties, and levies must be reported on a pro-rata basis for the export products covered in the return.

• Approximations must be justified and properly documented for potential scrutiny.

• Excluded Taxes: The ARR must not include taxes and levies that are already refunded through GST refunds, duty drawback, or any other central/state exemptions.

5. Accuracy & Record Maintenance

• Complete and accurate data submission is mandatory to avoid scrutiny or rejection.

• Minor, low-value claims may be omitted, provided they do not significantly impact remission calculations.

• Exporters must maintain records for at least 5 years for audit and verification purposes.

Practical Implications for Exporters

Given the detailed and structured nature of the ARR, exporters must:

• Implement robust internal controls to track RoDTEP claims.

• Ensure correct classification of ITC-HS codes.

• Maintain accurate tax and duty calculations.

• Align their internal data validation process with ARR filing requirements.

Conclusion

The Annual RoDTEP Return (ARR) is a significant compliance requirement, ensuring that exporters claim benefits accurately and transparently. By adhering to these guidelines, businesses can optimize their RoDTEP claims while remaining compliant with DGFT regulations.

Need Professional Assistance?

Filing the ARR correctly is crucial to avoid compliance issues and maximize your export incentives. If you need expert guidance on the RoDTEP Annual Return, our professional team is here to assist you.

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