Query on buyers credit facility ecb 2

Tridha Thakur (Finance Executive & Company Secretary)   (57 Points)

20 January 2012  

Dear Friends,

My Company has availed Buyers Credit facility from an International Bank within a period of 3 years.

 

Please clarify me whether 'ECB Return 2' must be filed to RBI via AD as per availing of BC/LC facilities by the company.
 
"ECB 2 - Return should be filled in for all categories of ECB. It should be submitted within 7 working days from the close of the month through the designated Authorised Dealer to the Director, Department of Statistical Analysis and Computer Services (DESACS), Balance of Payments Statistics Division, Reserve Bank of India, C-8/9, Bandra-Kurla Complex, Bandra (East), Mumbai-400 051."  If there is no transaction during a particular period, a Nil return should be submitted.
 
My company bankers are arguing that ECB 2 need not be filed with RBI (as per availment of BC Facilities) i.e ECB 2 not applicable.
 
Kindly clarify me whether they are right in their perception?
 
Regards
Tridha Thakur