Exporters can claim significant benefits like Customs Duty Drawback, RoDTEP (Remission of Duties and Taxes on Exported Products), and RoSCTL (Rebate of State and Central Taxes and Levies) to reduce export costs. However, these benefits are contingent upon fulfilling key compliance requirements, such as receiving payment in foreign currency and obtaining a Bank Realisation Certificate (BRC). To monitor the realization of export proceeds and ensure compliance, Jawaharlal Nehru Customs House (JNCH) has implemented the DRISHTI module, which plays a critical role in the smooth processing of shipping bills.
This professional guidance outlines the practical aspects of the DRISHTI module, its importance, and how exporters can ensure compliance to avoid penalties or notices.
Background: Challenges with the Earlier RBI-BRC Module
Prior to DRISHTI, JNCH introduced the RBI-BRC Module in January 2017 (via Public Notice No. 1/2017) to track foreign currency realization for shipping bills where the Let Export Order (LEO) was issued on or after 01.04.2014. However, this system faced several operational issues:
- Partial Payments Not Accounted For: Remittances received in multiple installments were not fully captured, causing discrepancies in tracking.
- Minor Forex Differences Ignored: Differences due to bank charges, commissions, or other deductions were often flagged as errors.
- No Closure Mechanism for Refunds: The module lacked the ability to close cases where exporters had returned a portion of the benefits claimed.
These limitations resulted in unnecessary inquiries, show-cause notices, and additional compliance burdens for exporters, especially at JNCH, which handles around 1.5 million shipping bills annually.
Introduction of DRISHTI: A Comprehensive Monitoring Solution
To address these challenges, JNCH introduced the DRISHTI module, a more robust and comprehensive solution for monitoring export proceeds. This new module is applicable to all shipping bills where the LEO was issued on or after 01.04.2014 and resolves several issues that exporters faced under the previous system.
Key Features of DRISHTI:
- Tracks Partial Payments Accurately: The DRISHTI module captures remittances received in multiple parts, ensuring a complete record of forex realization.
- Accounts for Forex Differences: Adjustments are made for minor differences in realized amounts due to bank charges, commissions, or similar deductions, reducing false discrepancies.
- Provisions for Proportionate Refunds: DRISHTI includes a closure mechanism for cases where exporters have refunded a portion of their Customs Duty Drawback, RoDTEP, or RoSCTL claims.
- Automated Data Reconciliation: The module automates BRC reconciliation, reducing manual intervention and accelerating the process.
Steps for Exporters to Ensure Compliance and Avoid Penalties
To avoid penalties or show-cause notices, exporters should take the following steps when dealing with shipping bills and foreign currency realizations under the DRISHTI system:
Check for Pending Shipping Bills: JNCH has published a list of IEC (Importer Exporter Code) holders whose shipping bills are pending realization for the period 01.04.2014 to 31.03.2023. Exporters should verify if their IEC is listed in the annexure and take prompt action.
Submit Outstanding BRCs: If you have received payment but have not yet submitted the BRC for any shipping bill, do so immediately. Delayed submission could result in your details being flagged for non-compliance.
Clarify Minor Forex Discrepancies: If minor differences exist due to bank charges, commissions, or other deductions, submit the necessary supporting documents (e.g., bank statements) to clarify the discrepancy with JNCH.
Repay Benefits for Unrealized Amounts: If the export proceeds have not been realized in full, exporters are required to repay the proportionate Drawback, RoDTEP, or RoSCTL claimed. Prompt repayment avoids further penalties and enforcement action.
Use the Standard Communication Format: JNCH has provided a specific format for correspondence regarding pending BRCs or repayment of benefits. Following this format will ensure faster processing and reduce the risk of delays.
Contact the JNCH Recovery Cell: If your IEC is listed, contact the Recovery Cell at JNCH via email at dbkre-jnch@gov.in to request a detailed list of pending shipping bills and take necessary steps to resolve the issue.
Distinguishing DRISHTI from the RBI-BRC Module
The DRISHTI module addresses several operational deficiencies in the earlier RBI-BRC module, offering exporters a more streamlined and efficient system for tracking export proceeds. Below is a comparative overview of the two modules:
| Feature | RBI-BRC Module | DRISHTI Module |
|---|---|---|
| Partial Payment Tracking | Ineffective in tracking multiple payments. | Tracks partial payments accurately, ensuring proper forex realization. |
| Forex Discrepancies | Failed to account for minor differences like bank charges. | Adjusts for minor differences, improving accuracy. |
| Refund Mechanism | Lacked provision for closing cases with partial refunds. | Allows for closure of cases where exporters return proportionate benefits. |
| Data Reconciliation | Manual reconciliation required for mismatches. | Fully automated reconciliation of BRC data with shipping bills. |
Best Practices for Exporters
Exporters should follow these best practices to ensure smooth processing of claims and avoid potential notices from customs:
Regularly Review Pending Shipping Bills: Stay updated on any outstanding shipping bills and submit BRCs promptly to avoid compliance flags.
Maintain Accurate Records: Keep detailed records of BRCs, bank statements, and other relevant documents to support your claims and address any inquiries swiftly.
Be Proactive in Resolving Discrepancies: If discrepancies arise, such as partial forex realization or differences due to bank fees, address these proactively by submitting the appropriate supporting documentation.
Stay Informed on JNCH Updates: Keep track of updates from JNCH regarding the DRISHTI module and other customs procedures to remain compliant with current requirements.
Conclusion
The DRISHTI module is a vital improvement for exporters, helping streamline the reconciliation of export proceeds and reduce compliance-related challenges. By offering better tracking, forex adjustments, and an automated reconciliation process, DRISHTI minimizes the risk of inquiries or penalties for exporters, ensuring a smoother claims process.
