Annual RoDTEP Return (ARR): who must file Appendix 4RR

RoDTEP pays you back the embedded taxes buried in your export costs, as transferable duty-credit scrips. The Annual RoDTEP Return (ARR) is DGFT's reconciliation of that bargain: once your claims get large enough, you have to show what those embedded taxes actually were, in the format prescribed as Appendix 4RR.

It was introduced by DGFT Public Notice 27/2024-25 dated 23 October 2024, which inserted Para 4.94 into the Handbook of Procedures 2023. Two things about it catch exporters out. The first is that the penalty is not a fine, it is a tap being turned off. The second is that "do I file?" and "how many do I file?" are two different questions with two different thresholds, and most write-ups only answer the first.

Where this stands as of 16 July 2026

This is the part worth checking before anything else, because there is a live default running right now.

FY 2024-25 is the return you should be worried about. Here is the reasoning, so you can check it yourself rather than take our word for it: every DGFT public notice ever issued on the ARR addresses FY 2023-24 only. There were four of them (PN 27/2024-25, PN 51/2024-25, PN 24/2025-26, and PN 46/2025-26 dated 05.02.2026, which set the final 31.03.2026 date). Not one mentions FY 2024-25.

That silence is the point. With no bespoke notice, FY 2024-25 runs on the standing rule in Para 4.94: due 31 March of the following financial year, with a three-month grace period. So it fell due on 31.03.2026 and its grace lapsed on 30.06.2026. If your FY 2024-25 RoDTEP claims crossed ₹1 crore and you have not filed, you are past the grace window, and customs has already stopped scrolling your RoDTEP claims.

The overlap confused a lot of exporters, and understandably: extended FY 2023-24 and natural FY 2024-25 both landed on 31 March 2026. Trade bodies ran them as a single event. If you filed "the ARR" in March, check which year you actually filed for.

Who has to file

The gate is ₹1 crore of RoDTEP claim per IEC, per financial year, aggregated across all 8-digit HS codes. Below that, you file nothing.

Three details that decide borderline cases:

• It is measured on what you claimed, not what you received. DGFT's own worked example in the RoDTEP User Guide: claim value ₹1,00,00,000, actual amount received ₹95,00,000, and the return is still required. The gate reads your claim, not your credit.
• The ₹1 crore mark itself is drafted inconsistently. Para 4.94 says the claim must "exceed" ₹1 crore. The User Guide FAQ says "₹1 Cr or more" and its example treats exactly ₹1,00,00,000 as caught. At precisely ₹1 crore the two primary texts disagree, so treat exactly ₹1 crore as covered and file.
• Merchant exporters are in scope. DGFT expects you to get the data by tying up with the manufacturer who supplied the goods. The obligation is yours; the tax figures are theirs.

How many returns you file: the ₹50 lakh rule

This is where the real complexity sits, and where most guides stop short. The ₹1 crore gate decides whether you file. A separate ₹50 lakh threshold decides how many returns you file, and for which HS codes.

Once you are through the gate, the rule is:

• File one ARR for each 8-digit ITC-HS code whose RoDTEP claim exceeds ₹50 lakh.
• If no single HS code crosses ₹50 lakh, file one ARR, for the HS code with the highest claim.

DGFT's own two examples make it concrete. Take ₹1.2 crore of claims spread across four codes at ₹20L, ₹30L, ₹40L and ₹30L: nothing crosses ₹50 lakh, so you file one return, for the ₹40 lakh code. Now take the same ₹1.2 crore spread as ₹60L, ₹51L, ₹3L and ₹6L: two codes clear ₹50 lakh, so you file two returns, one each for the ₹60 lakh and ₹51 lakh codes.

Same total claim. Different number of returns. The split of your claim across HS codes is what drives it, not the size of your business.

On top of that, DTA exports and AA/EOU/SEZ exports need separate return applications. Field 2 of Appendix 4RR asks for your type of unit precisely because it routes to a different rate schedule: Appendix 4R for DTA, Appendix 4RE for AA/EOU/SEZ. An exporter running both will file at least two returns before the ₹50 lakh rule is even applied.

What actually happens if you don't file

Not a penalty notice. Para 4.94(2), verbatim:

Non-reporting of the ARR shall lead to denial of benefits under the RODTEP scheme and no further scroll out of RODTEP claims for the SBs will be permitted at the Customs Port of Export after the grace period of three (3) months i.e. after 30th June.

Read that carefully, because the shape of it matters. Your existing scrips are not cancelled. What stops is scroll-out at the port for future claims. Every shipping bill you file from that point earns RoDTEP on paper and delivers nothing, because customs will not scroll it. The money does not vanish, it queues, indefinitely, behind a return you have not filed. Exporters usually notice this as "our RoDTEP has stopped coming through" weeks before anyone connects it to the ARR.

The cure is mechanical. Pay the composition fee, and per Para 4.94(3) the scrolls resume within 45 days, and the resumption covers the shipping bills that were not scrolled out earlier. Nothing is lost, it is deferred. But 45 days is 45 days of working capital sitting still.

On the fee: the standing structure in Para 4.94(3) is ₹10,000 within the three-month grace window, ₹20,000 after 30 June. One caveat worth stating plainly. That paragraph was written with FY 2023-24 in front of it, and DGFT has not restated the fee for FY 2024-25 in any notice. ₹20,000 is the only reading consistent with the standing rule, but confirm the figure on the portal before you pay. If you are filing a FY 2023-24 return now, after its 31.03.2026 window closed, the position is genuinely unsettled and you should approach DGFT rather than assume a number.

Two more obligations that outlive the filing itself. Records must be kept for five years (Para 4.94(4)). And under Para 4.94(6), returns picked up by DGFT's risk-based scrutiny can force you to refund or surrender excess claims, with continued failure to regularise leading to benefits being stopped altogether. The ARR is not a formality you clear and forget; it is the document your claim gets audited against.

What Appendix 4RR actually asks for

Twenty-seven numbered fields, filed export-product-wise with a separate sheet per product, not shipping-bill-wise. Grouped, it is:

• Identity and export (1-9): name, type of unit (DTA / AA / SEZ / EOU), IEC and PAN, 8-digit HS code, UQC, manufacturing unit address, the exact product description as it appears on the shipping bill, quantity and FOB exported, period of export.
• The embedded taxes you are actually reporting (10-17): VAT and excise on inbound and outbound transport, split by road and by rail; electricity duty; stamp duty on export documents; VAT and excise on fuel for captive power; embedded CGST and SGST on purchases from unregistered dealers; and any other taxes, with justification.
• Input-level detail (18-21): per input, the input's own 8-digit HS code, technical description, value and quantity per unit of export product, UQC, and total taxes borne. Plus farm-sector-only fields (mandi tax, fuel VAT, CGST/SGST on pesticides and fertilizers) and any exemptions or concessions availed, which are subtracted.
• The reconciliation (22-27): a system-calculated total, your total accrued RoDTEP, the rate, the total as a percentage of FOB, and then the field the whole return exists for: a comparison of RoDTEP accrued against taxes actually borne.

That last field is the point of the exercise. DGFT is checking whether the scheme paid you more than the embedded taxes you actually carried.

Usefully, the figures need not be exact. The instructions ask for a "reasonably justified estimate", entered pro-rata across the export products covered. What that means in practice is that your basis has to survive the Risk Management System, not that your arithmetic has to be perfect to the rupee.

Where the numbers go wrong

The failure modes are consistent, and almost all of them overstate the claim, which is the direction that attracts scrutiny.

• The wrong universe of taxes. Your duties and taxes split three ways: non-export, exports without a RoDTEP claim, and exports with a RoDTEP claim. Only the third goes in the ARR. Reporting your whole tax burden is the single most common error.
• Fuel VAT computed on the pump price. VAT sits on top of a price that already includes excise, so it needs a cum-tax back-calculation. Diesel at ₹100 a litre with ₹17 excise and 20% VAT gives ₹16.67, not ₹20. That is a ₹3.33 per litre overstatement, repeated across every litre you burned.
• Excise on fuel understated the other way, by forgetting AIDC and the Road and Infrastructure Cess. Excise on petrol and diesel is a fixed per-litre amount, not a percentage.
• Fuel in the wrong table. Fuel for your own trucks belongs in the transport table, not the captive-power table. Fuel for company cars is not claimable at all.
• Electricity duty on the whole premises. Production and warehousing only. Office electricity is out.
• Unregistered-dealer GST on the wrong purchases. Goods directly used in manufacture only. Not stationery, water cans or office furniture, and generally not services, which carry no embedded tax to remit.

Where automation earns its keep

Everything above is a data problem wearing a compliance costume. The return asks for your RoDTEP claim broken down by 8-digit HS code, the taxes you bore per unit of export product, and a reconciliation between the two. Every one of those numbers already exists somewhere in your shipping bills, your ledger and your purchase records. The work is not knowing them, it is assembling them across a year, per HS code, in a shape DGFT accepts, and noticing that you crossed ₹1 crore in the first place.

That last part is what quietly does the damage. The threshold does not announce itself. You cross ₹1 crore mid-year, without a portal alert, without a letter, and eleven months later the scrolls stop. FDP Connect watches the ₹1 crore gate against your live RoDTEP position, applies the ₹50 lakh rule to tell you how many returns you owe and for which HS codes, and counts down to 31 March before it becomes a ₹20,000 problem and a 45-day wait.

If you are new to the scheme itself, start with what RoDTEP is and how to claim it. If you are working out what stacks with what on the same shipment, Duty Drawback vs RoDTEP covers that.

This post reflects DGFT Public Notices 27/2024-25, 51/2024-25, 24/2025-26 and 46/2025-26, and the DGFT RoDTEP User Guide, as at 16 July 2026. Deadlines here have been extended repeatedly and may move again. Verify against the DGFT portal before you file.