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Advance Ruling Rejected as Warehousing Scheme Issue Falls Outside CAAR Jurisdiction

Case Law Details

TaxGuru Citation
2026 taxguru.in 4863
Case Name
In re Royal Glitz jewel Tech Private Limited (CAAR Mumbai)
Date of Judgement/Order
Only available for paid members
Courts
CAAR
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In re Royal Glitz jewel Tech Private Limited (CAAR Mumbai)

The Customs Authority for Advance Ruling (CAAR), Mumbai, received an application from the applicant under Section 28H(1) of the Customs Act, 1962 seeking an advance ruling on the applicability of Notification No. 69/2019-Customs and Notification No. 75/2020-Customs. The application was filed on 27.10.2025.

The applicant is a jewellery manufacturer operating in India and proposed to import advanced machinery from Italy and Germany for manufacturing gold jewellery. These machines included refinery units, furnaces, and other specialised equipment. The applicant stated that it manufactures jewellery using domestically procured gold sourced from authorised dealers and agencies, with all duties and taxes paid. The manufacturing process, from melting and alloying to finishing, is carried out within its facility, and the finished goods are sold domestically without any exports.

The applicant clarified that it does not import gold or avail any duty exemption schemes for inputs. The imports under consideration relate only to capital machinery required for manufacturing operations. Based on this, the applicant sought a ruling on whether it should operate under the Manufacture and Other Operations in Warehouse Regulations, 2019 (MOOWR) with a private warehouse licence under Section 58, or under the Manufacture and Other Operations in Special Warehouse Regulations, 2020 (MOOSWR) requiring a special warehouse licence under Section 58A.

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