17th August 2023 The Member Export Policy, Federal Board of Revenue, Islamabad. SUBJECT: APPLICATION FOR INTERIM DE-BLOCKING AND EXTENSION IN TIME LIMIT UNDER SECTION 224 OF THE CUSTOMS ACT, 1969TO TO FACILITATE EXPORTS UNDER EFS SCHEME Humbly Scheweth: Under instructions from our client M/s. Gadoon Textile Mills Limited, it is submitted that our client is one of the largest exporters of premium quality of textile products under the umbrella of YB Group (Yunus Brothers Group) and earning precious foreign exchange for the country through export facilitation scheme in vogue. They have imported the following input goods for re-export as per following GD`s and have cleared the goods in terms of SRO 450(I)/2001 dated 18.06.2001 however unfortunately due to worldwide pandemic of Covid-19 & worldwide economic recession, they have not been able to re-export the input goods within the stipulated period of two years. Although the period of two years have been statutory replaced by four years in EFS Scheme. It will be appreciated by the Board that a situation of force majeure has arisen in the country which is associated with exceptional circumstances as well. As such it is the need of the time that Board may sympathetically consider this application and in the best national interest an extension of time limit up to one Year may graciously be granted to us by Board and we assure that my client is ready to export the input raw materials once the extention of time limit is granted under Section 224 ibid. 2. Our client has applied to the Board through various applications and reminders which are on record but failed to get response nor the extension in time limit is granted failing to which our client is facing enormous hardships and unable to file export G.Ds under EFS to export the input raw materials in Weboc/PSW due and became victim of system check. The imported raw materials under the following Goods Declarations are as follows:- S.N o GD No 1 KPPI-MB-70606-02-04-2020 2 3 4 5 6 7 8 Qtty received Qtty consume d Balance Qtty Bond/Process In Bond Date Expiry Date 266426.00 168910.4 4 97515.56 02.04.202 0 01.04.202 3 100040.00 93184.64 6855.36 01-042020 31.03 .2023 100302.00 90829.95 9472.05 01-042020 31.03 .2023 294362.00 228097.2 7 66264.73 30-032020 29.03.202 3 756998.78 0 756998.78 08-042020 07.04.202 3 18529.00 0 18529.00 28-032020 29.03.202 3 123495.00 0 123495.00 17-042020 16.04.202 3 39415.40 0 39415.40 17-042020 16.04.202 3 KPPI-MB-70109-01-04-2020 KPPI-MB-70123-01-04-2020 KPPI-MB-69554-30-03-2020 KAPW-MB-113855-08-042020 KPPI-MB-69437-28-03-2020 KPPI-MB-74058-17-04-2020 KPPI-MB-74061-17-04-2020 9 10 11 12 13 14 KPPI-MB-70131-01-04-2020 38667.30 7960.98 30706.32 01-042020 31.03.202 3 1168947.6 5 203470.6 9 965476.96 23-042020 22.04.202 3 KAPE-MB-165678-23-042020 59457.00 4135.29 55321.71 23-042020 22.04.202 3 KAPE-MB-165683-23-042020 19819.00 0 19819.00 23-042020 22.04.202 3 KAPE-MB-166657-27-042020 78942.00 0 78942.00 27-042020 26.04.202 3 319294.00 27-042020 26.04.202 3 72011.85 29-042020 28.04.202 3 KPPI-MB-75625-23-04-2020 KPPI-MB-76224-27-04-2020 319294.00 15 0 KPPI-MB-76823-29-04-2020 138296.35 66284.50 3. In view of the above, we by this SOS application request you to kindly allow a temporary de-blocking for 90 days as an interim arrangement pending application for extension in time limit and/or allow extension in time limit for One Year so that our client may continue to exports and do not lose export orders. Kindly note that in case if the Collectorate will not allow deblocking for 90 days as interim arrangement, it would be a national loss to the country by way of losing precious foreign exchange desperately needed by the country. IMRAN IQBAL KHAN ADVOCATE SUPREME COURT FOR & ON BEHALF OF M/S. GADOON TEXTILE MILLS LIMITED