Annual RoDTEP Return (ARR) - Appendix-4RR

The RoDTEP stands for Remission of Duties and Taxes on Export Products, is a new scheme that came into effect on 1st January 2021, replacing the existing MEIS (Merchandise Exports from India Scheme). The exporters who are availing the benefits of RoDTEP are now required to file a return on an annual basis. The said return is called Annual RoDTEP Return i.e., Appendix-4RR. In this article we will discuss in detail about this Annual RoDTEP Return like who is required to file this return? What is the time period to file said return? and what are the consequences for non filing of this annual RoDTEP return?

The DGFT has issued a Public Notice No. 27/2024-25 detailing the new procedures for filing the Annual RODTEP Return (ARR) on 23rd Oct 2024 through which a new para 4.94 was added under Chapter 4 of HBP 2023, this paragraph outlines the requirements for filing the ARR.

Requirement to file Annual RoDTEP Return:
Exporters claiming RODTEP benefits must file this return as per the format provided in Appendix-4RR of the Handbook of Procedures 2023. This requirement for filing the annual return begins with the exporters (IECs) whose total RoDTEP claim exceeds Rs. 1 crore in a financial year across all 8-digit HS Codes.

What is the time period to file said return:
The Annual RODTEP Return (ARR) for RODTEP claims filed in a particular financial year must be submitted on the DGFT portal by March 31 of the following financial year. RODTEP claims for the financial year 2023-24 must be filed by March 31, 2025.

Extension of the last date for filing Annual RoDTEP Return (ARR) for Financial Year 2023-24:
Vide Public Notice No. 51/2024-2025 dated 19.03.2025 the last date for filing Annual RoDTEP Return (ARR) for financial year 2023-24 is extended from 31st March 2025 to 30th June 2025.

Consequences for non filing of this annual RoDTEP return:

Introduction of online module for filing Annual RoDTEP Return (ARR):
 The DGFT vide Trade Notice No. 27/2024-25 on dated 29th January, 2025 has intimated to the members of trade and industry that a module for filing Annual RoDTEP Return (ARR) has been introduced on the DGFT Website. It can be accessed on the DGFT Portal- www.dgft.gov.in under the link 'Regulations>RoDTEP'. A user guideline is also being uploaded for the benefit of the exporters under the same link.

RoDTEP User_Guide:
As per DGFT user guide for ARR, if the total RoDTEP claim for a given IEC exceeds Rs. 1 crore in a financial year, filing the Annual RoDTEP Return (ARR) is mandatory. Once an exporter qualifies under the rule above, and yet none of the individual 8-digit ITC-HS codes crosses Rs. 50 lakh in RoDTEP claims, exporter may file the ARR only for the 8 digit code under which he claimed the highest amount.

For example, if your total RoDTEP claim in a year amounts to Rs. 1.2 crore" where the distribution is
ITC-HS1: Rs. 20 lakh,
ITC-HS2: Rs. 30 lakh,
ITC-HS3: Rs. 40 lakh, and
ITC-HS4: Rs. 30 lakh,
you need to file an ARR only for ITC-HS3, since it represents the highest claim.

However, after qualifying under the 1 cr rule, if any individual 8-digit ITC-HS code exceeds Rs. 50 lakh in RoDTEP, an ARR must be filed for each of those codes. For instance, if your total RoDTEP claim is Rs. 1.2 crore, where the distribution is
ITC-HS1 at Rs. 60 lakh,
ITC-HS2 at Rs. 51 lakh,
ITC-HS3 at Rs. 3 lakh, and
ITC-HS4 at Rs 6 lakh,
you are required to file ARRs for ITC-HS1 and ITC-HS2, while you may ignore the remaining codes whose claims are below the Rs. 50 lakh threshold.

In addition to the above, the filing instructions for Annual RoDTEP Return (ARR) are also given in the said user guide.

Requirement for merchant exporters to file ARR:
The merchant exporters who have availed over Rs 1 Cr. of RoDTEP in the given financial year are also expected to file ARR by tying up with the manufacturer supplier of the goods for providing the information.

Disclaimer: The information given in this article is solely for purpose of understanding the law. It is completely based on the interpretation of the author and cannot be constituted as a legal advise, the author of this article and Lawcrux team is not responsible for any legal issues if arises on the basis of the interpretation given above.