AGARWAL SHRAFF & CO.

CHARTERED ACCOUNTANTS
52 Weston Street, 5th Floor
KOLKATA – 700 012
PHONE: 22259194 (O), 98300 61359 (M)
e-mail: vshraff@hotmail.com

Shri Giriraj Maheswari, July 11, 2006

Director,
M/s Aparna Paper Processing Industry (P) Ltd
Sedarapet,
Pondicherry- 605 111.

Dear Sir,

Re: Storage of inputs outside the factory premises

As desired by you, our opinion in relation to storage of inputs outside the factory
premises is as follows:-

Rule 8 of the Cenvat Credit Rules, 2004 provides the provision for storage of input
outside the factory of the manufacturer. It specifies that the Deputy Commissioner of
Central Excise or the Assistant Commissioner of Central Excise, as the case may be,
having jurisdiction over the factory of a manufacturer of the final products may, in
exceptional circumstances having regard to the nature of the goods and shortage of
storage space at the premises of such manufacturer, by an order, permit such
manufacturer to store the input in respect of which CENVAT credit has been taken,
outside such factory, subject to such limitations and conditions as he may specify.

No standard procedure has been prescribed under Central Excise Rule for such storage.
However, Commissioner of Central Excise, Ahmedabad – III has issued a Trade Notice
no. 93/2004-2005 (179) E.L.T. (T16) prescribing the procedure for assesses wishing to
store cenvatable inputs outside the factory which can be referred to while approaching the
jurisdictional AC/DC for formal approval to store the inputs outside the factory.

In my opinion following procedure can be adopted subject to approval of the

jurisdictional AC/DC for storage of the inputs outside the factory:-

a) A register shall be maintained at the godown providing particulars of documents

under which inputs are received, description of goods, quantity received /
removed & closing balance. Register can be maintained in the format suggested in
Annexure A.

b) The movement of goods from the place of storage to the factory shall be effected
against challans which would be in running serial number for the whole of
financial year. Challan can prepared in the format suggested in AnnexureB.
 AGARWAL SHRAFF & CO.
CHARTERED ACCOUNTANTS
52 Weston Street, 5th Floor
KOLKATA – 700 012
PHONE: 22259194 (O), 98300 61359 (M)
e-mail: vshraff@hotmail.com

c) Cenvat credit shall be taken only when inputs covered by invoice are received in
the factory.

Please feel free to contact the undersigned for any further clarifications on the above
issue.

Thanking you,

Yours faithfully,

For Agarwal Shraff & Co.

Chartered Accountants

Vinay Kumar Shraff

Partner
 AGARWAL SHRAFF & CO.
CHARTERED ACCOUNTANTS
52 Weston Street, 5th Floor
KOLKATA – 700 012
PHONE: 22259194 (O), 98300 61359 (M)
e-mail: vshraff@hotmail.com

Annexure A

1. Sr. no.
2. Date
3. Description of goods received.
4. Quantity received.
5. Particulars of invoice
6. Name & address of manufacturer / importer / dealer from whom inputs are
received.
7. Issued for removal to factory.
(a) Challan No. & Date
(b) Quantity
8. Balance

Annexure B
1. Address of the place of storage.
2. Description of goods issued under the challan.
3. Particulars of invoice under which goods were received at the place of storage
4. Quantity removed
5. Date and time of removal
6. Mode of transportation along with vehicle registration no.