Customs.
Import/export duty positions, trust programmes, port and audit matters, MOOWR
Customs Act 1962 · Customs Tariff Act 1975 · Valuation Rules 2007 · IGCR 2022 · MOOWR 2019 · CAROTAR 2020
Engagement models: Annual retainership · Project-based mandates · One-time representations & opinions

Structure
Positions settled before the transaction
<1 day
Senior advisor first response
01 / 03 · BEFORE THE TRANSACTION
Structure — getting in, on the right terms
Classification memos and advance rulings (CAAR)
A written classification position under the GRI, chapter notes and HSN explanatory notes, and — where the stakes justify it — an application to CAAR under s.28H so the heading is settled before the first Bill of Entry rather than at audit.
Valuation and the Special Valuation Branch (related-party imports)
Transaction value under s.14 and Rules 3 and 10, related-party disclosure and SVB registration and renewals, and the treatment of royalties, licence fees and post-import payments before an officer adds them for you.
Exemption and end-use structuring (IGCR)
Notification conditions read the way the department reads them; IGCR 2022 intimations, bonds and consumption records for concessional-rate imports; and the customs side of Advance Authorisation and EPCG.
MOOWR (s.65) bonded manufacturing and duty deferment
A s.65 MOOWR licence for bonded manufacturing with no export obligation and no NFE; AEO tiers T1–T3 and LO; and the Eligible Manufacturer Importer duty-deferment introduced by Circular 08/2026-Customs — chosen on your cash cycle, not on a brochure.
AEO T1–T3, ICEGATE / AD code, first-import readiness
ICEGATE and AD-code registration, product-specific partner-agency requirements and document sets that do not trigger a query memo on the first consignment.
02 / 03 · DURING OPERATIONS
Operate — keeping the benefit
Held cargo and query memos — shipment-level hand-holding at ports
Answering a query, a first-check examination or an alert-list hold with the classification, valuation or exemption position already on file, and using provisional assessment under s.18 or provisional release under s.110A so goods move while the question is argued.
Post-clearance audit (PBA / OSPCA) readiness and replies
Premises-based and transaction-based audits under the 2018 Regulations: the records the auditors ask for, the reconciliations they run, and how an audit objection is answered so it does not become a show-cause notice.
Drawback, RoDTEP at the port, IGST refunds
Shipping-bill declarations, scroll generation and the ICEGATE–GSTN reconciliation errors that stall refunds; recovery notices where realisation or documents fell short.
FTA claims under CAROTAR
The importer's Form I knowledge, certificate-of-origin management and the five-year record; how a verification request from the origin authority is handled without losing the preferential rate.
MOOWR / IGCR / bond housekeeping; compliance health-checks
Monthly returns and consumption records, bond adequacy, re-warehousing and the removal formalities — the routine paperwork whose gaps become the audit's findings.
03 / 03 · WHEN CHALLENGED
Defend — when the department disagrees
First reply to the SCN (ss.28 / 124)
A show-cause notice answered on limitation, on the merits and on quantification together — the extended period, the classification or valuation argument, and the arithmetic — because the first reply frames every later stage.
DRI, SIIB and audit investigations; summons
Summons under s.108, statements and their retraction, seizure under s.110 with the six-month notice clock in s.110(2), and provisional release under s.110A while the enquiry runs.
Adjudication and the personal hearing
Written submissions, the personal hearing and the record — built so the order, whichever way it goes, is appealable on a clean record.
Appeals — Commissioner (Appeals) → CESTAT → High Court; pre-deposit
Commissioner (Appeals) within 60 days plus 30 condonable; CESTAT within three months; s.129E pre-deposits computed correctly, and refunded with interest under s.129EE when you win.
Penalty and interest exposure
Interest under s.28AA, penalties under ss.112, 114A and 114AA, and the reduced-penalty windows on early payment — quantified before you choose between paying, contesting and settling.
Your advocates at the port — classification, valuation and exemptions settled correctly from day one, and defended when tested.
A senior advisor replies within one business day, not a call centre.
