Pre Budget Consultation With Union Finance Minister On January 6, 2016

Submission By President FIEO Mr S C Ralhan
“At the outset, I would like thank you for giving us an opportunity to make submissions for Union Budget 2016-17. Based on the feedback from trade & industry, we have already submitted the proposals for kind consideration and the same have already been deliberated with the Chairman CBEC and his team.
Sir, as you are aware that exports have been witnessing a downward trend for a couple of months. Though, the Govt.  has introduced various measures in the recent past to arrest the fall, yet something more is required to be done.
1. I would request that inverted duty structure in respect of various items may be given due consideration in the Union Budget as it not only effects exports but also the manufacturing sector and adversely hit at Make in India. 
2. Sir, the actual refund mechanism for service tax is cumbersome and time taking which blocks the working capital of exporters. Hence, the demand of exporting community is that Service tax should be exempted for exports. At least exemption from Service Tax may be provided to the following services:
ECGC Premium, C.F.S. services, C.H.A. charges, T.H.C. Charges for exports
Bank Charges on collection of Bill, Foreign Currency related to Export
Service Charges for conversion of inward remittances
Courier Charges for exports documents and Commercial shipments
Service tax exemption under reverse charge mechanism as it is not rebated under All industry rate of service tax.
3       Terminal Excise Duty (TED) on purchase of Capital Goods from indigenous manufacturers under EPCG Scheme may also be exempted as the current refund process leads to blockage of working capital for a considerable period of time and increase transaction cost.
4      The biggest challenge affecting MSME exports is on the marketing front as most of MSME lack financial resources to meet the cost. Government needs to chip in with liberal funding. The total marketing support extended by DoC under MAI and MDA is insufficient to meet the demand of MSME for export marketing. Government may create an Export Development Fund (EDF) so as to support them on this front. The corpus of the fund should be 0.5% to 1% of export value so that sizable money is available to promote MSME exports.
5        MSMEs play a pivotal role in India’s exports as well as in ‘Make in India’ Programme. In view of current down fall in exports, encouragement to MSME Sector by way of fiscal incentives on their year-on-year export growth would motivate them for aggressive export marketing, which in turn could help in restoring export momentum. Hence, MSME exporters may be provided additional exports benefits.  Currently, no additional fiscal benefit is available to MSME sector under FTP. 
6         In view of current global trend which portrays a gloomy scenario for our exports in 2016, Government may consider to encourage the Status Holder category of exporters by restoring the benefit available to them under the earlier Policies in the form of SHIS.  
7          Withholding tax to be deducted from non-residents for exports commission payments made during course of business which is 10% if PAN details of non-resident are available, If not a penal deduction of 20% is to be made which has to be paid by the exporter adding to business costs/overheads. It is, therefore, requested that non-residents, may be kept out of the ambit of section 206AA.
8         Merchant Exporters may be given Interest Equalization Benefit (IES): Merchant exporters in specified sectors were eligible for interest subvention but they have been excluded under the current IES. In sectors such as handicrafts, carpets, agro sectors etc., exports is largely done by merchant who may be included in the Scheme as well.”
Wednesday, January 6, 2016