EOU / STPI.
Export Oriented Units and STP / EHTP / BTP units
FTP 2023 Ch. 6 · HBP Ch. 6 · Notification 52/2003-Cus · DC / STPI Director
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
EOU vs SEZ / MOOWR / DTA-with-schemes — modelled
The choice usually turns on location (an EOU stays where you are), DTA-sale plans, capital-goods intensity and how you expect to exit. We run all four on your numbers before you apply.
Letter of Permission application (UAC/DC; STPI Director for STP/EHTP)
Investment (para 6.06's ₹1 crore plant-and-machinery threshold and its exceptions), projected exports and NFE, and the exact goods to be manufactured — the DC's office reads these against the sector norms in Appendix 6B.
LUT with the DC; B-17 bond with Customs
The LUT with the DC (para 6.05(c)) and the B-17 general bond with the jurisdictional Customs office, sized to your duty-free procurement — the two documents every later demand is anchored to.
Duty-free procurement set-up (Notif. 52/2003)
Imports under Notification 52/2003-Customs following the IGCR procedure, and domestic procurement on the deemed-export and GST footing — set up so the first consignment does not stall at the port.
STP / EHTP registration
Approval through the MeitY-designated officer, the STPI agreement, and the SOFTEX arrangements a software exporter needs from day one for its export realisation and NFE.
02 / 03 · DURING OPERATIONS
Operate — keeping the benefit
NFE by five-year block, tracked by year
The para 6.04 obligation is cumulative over five years, and the BoA can extend a block by up to one year on genuine hardship — but only if you ask before the block closes. We keep the ledger that shows where you stand.
Annual and quarterly reports to the DC
The performance reports the Unit Approval Committee monitors under para 6.19, reconciled to your shipping bills, SOFTEX forms and GST returns before they are sent.
DTA sales within para 6.07 entitlement
What can be sold domestically, at what duty and tax, and how it counts against NFE — worked out before the sale, because a DTA sale outside entitlement is a duty demand with penalty.
Inter-unit transfer, sub-contracting, repair permissions
Paras 6.12, 6.13 and 6.15–6.16 permissions and the movement documentation that keeps duty-free goods traceable while they are outside the unit.
Bond, IGCR and procurement housekeeping
B-17 bond adequacy as procurement grows, IGCR intimations, and re-warehousing certificates — the small documents whose absence becomes a large notice.
03 / 03 · WHEN CHALLENGED
Defend — when the department disagrees
Exit priced before it is announced — debonding duty
Duty on capital goods at depreciated value and on unused duty-free inputs and stock, computed on the dates that matter — timing the intimation can move the bill materially.
Exit routes via EPCG or Advance Authorisation
Para 6.17(d) allows exit on payment of duty on capital goods under the EPCG scheme, and 6.17(g) a one-time exit under Advance Authorisation — both conditional on positive NFE and scheme eligibility. Where the numbers dispute, a BG-backed bond or instalments can keep the exit moving (6.17(e)).
STP / EHTP simplified debonding
For units that never took duty benefit on inputs or capital goods, para 6.17(h) contemplates a fast-track exit — the paperwork still has to prove that negative.
Customs demands on the bond
Show-cause notices for duty-free goods not accounted for, DTA sales beyond entitlement or unfulfilled conditions of Notification 52/2003 — answered on the s.28 / s.124 ladder, with the B-17 bond as the department's starting point.
FT(D&R) Act penalty for NFE shortfall
Where NFE or LoP conditions were not met, penalty proceedings under s.11 — with the appeal under s.15 — run in parallel with any Customs duty demand and are defended separately.
A bridge between your export objectives and the regulatory requirements of the EOU and STPI regimes.
A senior advisor replies within one business day, not a call centre.
