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How-To · 14 min read

Direct Reduced Iron (DRI) Natural Gas + Coal Steel Plant Reconciliation India

A Tier-1 Indian integrated steel producer running a Direct Reduced Iron (DRI) plus Electric Arc Furnace (EAF) route — either a gas-based MIDREX or HYL-Energiron configuration on Regasified Liquefied Natural Gas (RLNG) or a coal-based rotary kiln configuration on non-coking coal — sits under a materially heavier reducing-agent cost reconciliation surface than the parallel Blast Furnace plus Basic Oxygen Furnace (BF-BOF) route. Gas-based DRI consumes approximately 1.8 to 2.2 tonnes of iron ore pellet plus 250 standard cubic metres of natural gas per tonne of DRI at 8 to 12 US dollars per million British thermal units RLNG landed price; coal-based DRI consumes approximately 1.4 to 1.6 tonnes of iron ore lump or pellet plus 1.0 to 1.2 tonnes of non-coking coal per tonne of DRI. Reducing-agent cost, iron ore lump versus pellet split, Ind AS 2 per-tonne DRI cost loading, Section 194Q on the third-party iron ore and coal and gas seller legs, and the Carbon Border Adjustment Mechanism (CBAM) route-differential impact on European Union export competitiveness at 1.4 to 1.8 tonnes CO2 per tonne DRI (gas-based) versus 2.2 to 2.6 tonnes CO2 per tonne DRI (coal-based) sit on the same monthly reconciliation surface.

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Published 28 July 2026
Domain expertise
TDS Reconciliation GST Input Credit Platform Settlements NACH Batch Matching Bank Reconciliation Form 26AS Matching ERP Integrations Enterprise Finance Ops
Knowledge Card
Problem

A Tier-1 or Tier-2 Indian integrated steel producer running a Direct Reduced Iron plus Electric Arc Furnace (DRI-EAF) route — either a gas-based MIDREX or HYL-Energiron configuration on Regasified Liquefied Natural Gas (RLNG) or a coal-based rotary kiln configuration on non-coking coal — sits under a materially heavier reducing-agent cost reconciliation surface than the parallel Blast Furnace plus Basic Oxygen Furnace (BF-BOF) route. The reducing-agent consumption is approximately 250 standard cubic metres of natural gas per tonne of DRI on the gas-based route (approximately 8.7 million British thermal units per tonne DRI) or approximately 1.0 to 1.2 tonnes of non-coking coal per tonne of DRI on the coal-based route. The iron ore input is approximately 1.8 to 2.2 tonnes of iron ore pellet per tonne DRI on the gas-based route (pellet is essential for MIDREX and HYL shaft furnace operation) or approximately 1.4 to 1.6 tonnes of iron ore lump plus pellet per tonne DRI on the coal-based route. At an illustrative RLNG landed price of USD 10.5 per mmBtu at Rs 83 per USD, the gas-based reducing agent cost is approximately Rs 7,570 per tonne DRI; at an illustrative CIL Fuel Supply Agreement price of Rs 3,700 per tonne for G7 to G11 grade non-coking coal, the coal-based reducing agent cost is approximately Rs 4,070 per tonne DRI. The illustrative fully-loaded per-tonne DRI cost including iron ore, reducing agent, power, consumables and depreciation runs approximately Rs 18,000 to Rs 19,000 per tonne DRI for the gas-based route and approximately Rs 10,500 to Rs 11,500 per tonne DRI for the coal-based route. The Carbon Border Adjustment Mechanism (CBAM) route-differential is approximately EUR 60 per tonne CBAM cost disadvantage for the coal-based DRI-EAF route on the EU export leg at 2.4 versus 1.6 tonnes CO2 per tonne crude steel and a reference EU ETS price of EUR 75 per tonne CO2. Section 194Q at 0.1 percent buyer-side TDS applies to third-party iron ore, non-coking coal, RLNG and merchant-DRI seller legs above the Rs 50 lakh aggregate threshold per seller per previous year.

How It's Resolved

Build a per-module-per-month DRI reconciliation ledger keyed on the DRI module identifier (MIDREX Module 1, MIDREX Module 2, or Rotary Kiln 1, Rotary Kiln 2). For each month, capture the certified DRI production tonnage from the plant MES against the reducing-agent consumption record (natural gas flow meter reading for gas-based, coal yard weighbridge tonnage for coal-based), the iron ore feed record split between pellet and lump against the DRI module receipt log, and the process consumables (dolomite flux, limestone flux for coal-based rotary kiln) consumption. Reconcile the reducing-agent consumption per tonne DRI to the design specification (approximately 250 standard cubic metres per tonne DRI for gas-based, approximately 1.0 to 1.2 tonnes non-coking coal per tonne DRI for coal-based) with any deviation above a materiality threshold flagged for the plant operations head. Reconcile the RLNG landed cost breakdown from the gas marketer invoice (LNG DES cost, regasification tariff, transmission tariff, marketing margin, GST) for gas-based, or the CIL Fuel Supply Agreement invoice (notified price, royalty, DMF, NMET, Clean Environment Cess, GST Compensation Cess, GST) for coal-based against the ledger balances. Apply Section 194Q at 0.1 percent buyer-side TDS on the third-party iron ore, non-coking coal, RLNG and merchant-DRI seller legs above the Rs 50 lakh aggregate threshold per seller per previous year, with monthly deposit and quarterly Form 26Q filing through the standard Section 194Q mechanic. Compute the CBAM embedded direct emissions per tonne DRI for the EU export leg from the reducing-agent carbon content and the DRI plant Scope 1 emissions record; roll up to per-tonne crude steel embedded emissions with the EAF Scope 2 electricity emissions loading. Load the per-tonne DRI cost stack (iron ore plus reducing agent plus process consumables plus power plus labour plus depreciation) to the DRI inventory carrying value under Ind AS 2 weighted-average cost formula, feeding downstream into the crude steel and finished steel inventory hierarchy. Compare the per-tonne DRI cost between gas-based and coal-based modules on a rolling monthly basis for the route-mix optimisation decision at the plant level, and separately for the EU export sub-portfolio versus the domestic and non-EU export sub-portfolios given the CBAM route-differential impact.

Configuration

DRI module master with module identifier, process route tag (gas-based MIDREX / gas-based HYL-Energiron / coal-based rotary kiln), design capacity in tonnes per annum, design reducing-agent consumption per tonne DRI, design iron ore feed per tonne DRI (pellet-only for gas-based; lump plus pellet split for coal-based), commissioning year, DRI plant capex capitalised under Ind AS 16, useful life for depreciation base. Monthly DRI production record with per-module tonnage from the plant MES or DCS. Monthly reducing-agent consumption record — natural gas volume in standard cubic metres from the DCS gas flow meter log with GC-certified Wobbe Index and GCV for gas-based, non-coking coal tonnage from the coal yard weighbridge log with laboratory-certified GCV per shipment for coal-based. Monthly iron ore feed record with pellet-vs-lump split against the DRI module receipt log. RLNG landed cost breakdown from the gas marketer invoice for gas-based (LNG DES, regasification tariff, transmission tariff, marketing margin, GST) or CIL FSA invoice for coal-based (notified price by grade, coal royalty at 14 percent ad valorem, DMF, NMET, Clean Environment Cess at Rs 400 per tonne, GST Compensation Cess at Rs 400 per tonne, applicable GST). Section 194Q sub-ledger with buyer-side TDS at 0.1 percent on third-party iron ore, non-coking coal, RLNG and merchant-DRI seller legs against seller PAN with monthly deposit challan and quarterly Form 26Q filing. CBAM embedded emissions record with direct Scope 1 process emissions per tonne DRI, indirect Scope 2 electricity emissions for the EAF stage, EU-accredited independent verifier attestation for the reporting quarter. Ind AS 2 per-tonne DRI cost sheet with iron ore, reducing agent, process consumables, power, labour and depreciation loading. DRI-to-EAF transfer record and EAF melting record for the downstream crude steel cost roll-up.

Output

A month-end DRI-EAF integrated steel plant reconciliation packet: the certified per-module DRI production tonnage from the plant MES; the reducing-agent consumption per tonne DRI against the design specification with any deviation flagged for the plant operations head investigation; the iron ore feed record with pellet-vs-lump split against the DRI module receipt log; the RLNG landed cost breakdown from the gas marketer invoice for gas-based operations or the CIL Fuel Supply Agreement invoice for coal-based operations reconciled to the ledger balances; the Section 194Q sub-ledger with 0.1 percent buyer-side TDS on third-party iron ore, non-coking coal, RLNG and merchant-DRI seller legs above the Rs 50 lakh aggregate threshold per seller per previous year with monthly deposit challan and quarterly Form 26Q filing evidence; the CBAM embedded emissions record for the EU export leg with EU-accredited independent verifier attestation; the Ind AS 2 per-tonne DRI cost sheet loading iron ore, reducing agent, process consumables, power, labour and depreciation to the DRI inventory weighted-average cost carrying value; the DRI-to-EAF transfer record and the EAF melting record for the downstream crude steel cost roll-up; the monthly PAT Specific Energy Consumption tracking for the DRI-EAF plant against the notified PAT cycle target. Every material deviation between design reducing-agent consumption and actual, between design iron ore feed and actual, between invoice reducing-agent cost and ledger balance, and between design embedded emissions per tonne DRI and CBAM verifier-attested actual, is flagged for the plant CFO, the plant operations head and the statutory auditor. Multi-year continuity of the packet produces the audit trail that a plant operations audit, a State Mines Department review on the coal royalty side, a Section 194Q assessment by the Income-tax Officer on third-party seller legs, an EU-accredited CBAM verifier attestation for the EU import customs check and a statutory auditor reviewing DRI inventory valuation and DRI plant depreciation all expect.

A Tier-1 Indian integrated steel producer running a Direct Reduced Iron plus Electric Arc Furnace (DRI-EAF) route at an integrated steel plant in Gujarat, Chhattisgarh, Odisha, Jharkhand or West Bengal — either a gas-based MIDREX or HYL-Energiron configuration on Regasified Liquefied Natural Gas (RLNG) or a coal-based rotary kiln configuration on non-coking coal — sits under a materially heavier reducing-agent cost reconciliation surface than the parallel Blast Furnace plus Basic Oxygen Furnace (BF-BOF) route. The illustrative persona is a Gujarat coastal gas-based DRI-EAF plant fed by RLNG from a Hazira LNG import terminal at illustrative USD 10.5 per million British thermal units landed price, versus a Chhattisgarh interior coal-based DRI-EAF plant fed by domestic non-coking coal from a Mahanadi Coalfields Ltd or South Eastern Coalfields Ltd Fuel Supply Agreement at illustrative Rs 3,700 per tonne notified price. India produces approximately 35 to 40 million tonnes per annum of DRI against a global DRI production of approximately 130 million tonnes per annum — the world’s largest single-country DRI production, driven by the structural shortage of domestic coking coal (India imports 60 to 70 million tonnes per annum of coking coal for the BF-BOF route) and the large domestic non-coking coal base supporting the coal-based DRI route. The reconciliation discipline that ties monthly DRI production per module to the reducing-agent consumption per tonne DRI, reconciles the iron ore pellet or lump feed against the DRI module receipt log, applies the RLNG landed cost or the Coal India Ltd Fuel Supply Agreement notified price at the correct grade, tests Section 194Q applicability on the third-party iron ore and coal and gas seller legs, computes the Carbon Border Adjustment Mechanism (CBAM) embedded emissions per tonne DRI-EAF crude steel for the European Union export leg, and threads the per-tonne DRI cost through Ind AS 2 inventory valuation into the crude steel and finished steel inventory hierarchy is the subject of this Direct Reduced Iron DRI natural gas coal steel plant reconciliation India walkthrough.

Quick reference

AspectDetail
DRI process route (gas-based)MIDREX / HYL-Energiron shaft furnace, natural gas reducing agent
DRI process route (coal-based)SL/RN / DRC rotary kiln, non-coking coal reducing agent
Reducing agent (gas-based)Approximately 250 standard cubic metres natural gas per tonne DRI (approximately 8.7 mmBtu per tonne DRI)
Reducing agent (coal-based)Approximately 1.0 to 1.2 tonnes non-coking coal per tonne DRI (G7 to G11 grade typical)
Iron ore feed (gas-based)Approximately 1.8 to 2.2 tonnes iron ore pellet per tonne DRI (pellet-only, no lump)
Iron ore feed (coal-based)Approximately 1.4 to 1.6 tonnes iron ore lump plus pellet per tonne DRI
DRI product formsHot Briquetted Iron (HBI) / Cold DRI (CDRI) / Hot DRI direct-charge to EAF
India DRI productionApproximately 35 to 40 million tonnes per annum (world’s largest)
Gas-based DRI locationsCoastal integrated plants with LNG terminal access — Hazira (Gujarat) predominantly
Coal-based DRI locationsChhattisgarh, Odisha, Jharkhand, West Bengal regional producers
RLNG landed cost benchmark (illustrative)USD 8 to USD 12 per mmBtu — LNG DES plus regasification plus transmission plus marketing margin plus 5 percent GST
CIL FSA notified price (illustrative)Rs 3,500 to Rs 4,200 per tonne for G7 to G11 grade non-coking coal inclusive of royalty, DMF, NMET, cesses, GST
Emissions (gas-based DRI-EAF)Approximately 1.4 to 1.8 tonnes CO2 per tonne crude steel end-to-end
Emissions (coal-based DRI-EAF)Approximately 2.2 to 2.6 tonnes CO2 per tonne crude steel end-to-end
CBAM certificate cost (gas-based at EUR 75/T CO2)Approximately EUR 105 to EUR 135 per tonne DRI-EAF crude steel exported to EU
CBAM certificate cost (coal-based at EUR 75/T CO2)Approximately EUR 165 to EUR 195 per tonne DRI-EAF crude steel exported to EU
CBAM route-differentialApproximately EUR 50 to EUR 70 per tonne disadvantage for coal-based route on EU export leg
Section 194Q applicability (iron ore, coal, RLNG, merchant DRI)0.1 percent buyer-side TDS above Rs 50 lakh aggregate per seller per previous year
Section 194Q payment code1031 under Section 393 SL 8 (purchase of goods)
DRI plant capex (illustrative)Gas-based MIDREX Rs 800 to Rs 1,200 crore per MTPA; coal-based rotary kiln Rs 400 to Rs 700 crore per MTPA
Ind AS 16 depreciation baseStraight-line over 25 to 40 years useful life of DRI plant
Ind AS 2 per-tonne DRI costIron ore plus reducing agent plus process consumables plus power plus labour plus depreciation to DRI inventory

The reconciliation in one paragraph

A Tier-1 or Tier-2 Indian integrated steel producer running a DRI-EAF route must capture, month by month and DRI module by DRI module, the certified DRI production tonnage from the plant Manufacturing Execution System, the reducing-agent consumption per tonne DRI (natural gas volume in standard cubic metres from the Distributed Control System gas flow meter log for gas-based operations, or non-coking coal tonnage from the coal yard weighbridge log for coal-based operations), the iron ore feed record split between iron ore pellet (essential for gas-based MIDREX and HYL shaft furnace, optional for coal-based rotary kiln) and iron ore lump (usable only in coal-based rotary kiln), the RLNG landed cost breakdown from the gas marketer invoice (LNG delivered ex-ship cost, regasification tariff, transmission tariff, marketing margin, applicable GST) for gas-based operations or the Coal India Ltd Fuel Supply Agreement invoice for coal-based operations (notified price by grade, coal royalty at 14 percent ad valorem, DMF, NMET, Clean Environment Cess at Rs 400 per tonne, GST Compensation Cess at Rs 400 per tonne, applicable GST), the Section 194Q sub-ledger with 0.1 percent buyer-side TDS on third-party iron ore, non-coking coal, RLNG and merchant-DRI seller legs above the Rs 50 lakh aggregate threshold per seller per previous year, the CBAM embedded emissions record for the EU export leg with EU-accredited independent verifier attestation, and the Ind AS 2 per-tonne DRI cost sheet loading iron ore, reducing agent, process consumables, power, labour and depreciation to the DRI inventory weighted-average cost carrying value feeding downstream into the crude steel and finished steel inventory hierarchy. Every material deviation between design reducing-agent consumption and actual, between design iron ore feed and actual, between invoice reducing-agent cost and ledger balance, and between design embedded emissions per tonne DRI and CBAM verifier-attested actual, is flagged as a month-end break for the plant CFO, the plant operations head and the statutory auditor.

What the scenario looks like in India — safe illustrative gas-based versus coal-based DRI persona

The illustrative persona for this walkthrough is a comparison across two Tier-1 Indian integrated steel producers operating materially different DRI-EAF configurations. The first is a Gujarat coastal gas-based DRI-EAF integrated plant at Hazira, running three MIDREX modules for an aggregate DRI capacity of approximately 6.8 million tonnes per annum feeding an 8.6 million tonnes per annum crude steel EAF-plus-Continuous-Casting configuration — fed by RLNG imported through the Hazira LNG terminal on a mixed portfolio of long-term LNG DES contracts (Henry Hub-indexed and JKM-indexed) and short-term spot LNG at an illustrative all-in landed RLNG price of USD 10.5 per mmBtu at Rs 83 per USD conversion. The iron ore feed is 100 percent iron ore pellet, sourced through a mix of captive pellet plant production (illustrative 4 to 5 million tonnes per annum captive pellet capacity feeding from third-party iron ore fines purchase and captive lease fines) and third-party pellet purchase from KIOCL, JSW Pellet, Essel Mining and independent pellet producers.

The second is a Chhattisgarh interior coal-based DRI-EAF integrated plant at Raigarh, running eight rotary kiln modules for an aggregate DRI capacity of approximately 3.6 million tonnes per annum feeding a matched EAF configuration — fed by domestic non-coking coal from a South Eastern Coalfields Ltd or Mahanadi Coalfields Ltd Fuel Supply Agreement at an illustrative Rs 3,700 per tonne notified price for G7 to G11 grade coal (inclusive of coal royalty at 14 percent ad valorem, DMF, NMET, Clean Environment Cess at Rs 400 per tonne, GST Compensation Cess at Rs 400 per tonne and applicable GST). The iron ore feed is a mix of iron ore lump (approximately 70 to 80 percent) and iron ore pellet (approximately 20 to 30 percent), sourced from captive iron ore mining leases in the Barbil-Joda-Sundargarh belt (Odisha) and from third-party purchase from NMDC (Central Government PSU) and private-sector merchant iron ore lease holders.

Illustrative Tier-1 and Tier-2 Indian integrated steel producers operating DRI-EAF configurations of one or both types, running the same reducing-agent cost reconciliation stack, include AMNS (ArcelorMittal Nippon Steel India — Hazira gas-based MIDREX predominantly), JSW Steel (Vijayanagar and Dolvi with mixed DRI-EAF and BF-BOF configurations), JSPL (Jindal Steel & Power — Raigarh coal-based rotary kiln plus Angul integrated gas-based DRI), Welspun (specialty steel with DRI-EAF configurations), Sunflag Iron & Steel (Bhandara Maharashtra coal-based DRI), Kalyani Steel (specialty steel DRI-EAF), Bhushan Power & Steel (now under JSW — Odisha coal-based DRI), Sarda Energy (Chhattisgarh coal-based DRI), and regional producers across the Chhattisgarh-Odisha-Jharkhand-West Bengal coal-based DRI belt operating smaller-scale rotary kiln modules in the merchant DRI model selling DRI or Hot Briquetted Iron to standalone EAF and Induction Furnace melters. Every one of these producers runs some variant of the reducing-agent cost accounting discipline documented here as the standing month-end close mechanic for any DRI-EAF integrated steel plant.

The regulatory overlay — Ministry of Steel National Steel Policy 2017, PNGRB RLNG, CIL FSA, CBAM, Section 194Q, Ind AS 2

Six regulatory and reference anchors govern a DRI-EAF integrated steel plant’s reducing-agent cost accounting. The Ministry of Steel National Steel Policy 2017 frames the medium-term route-mix and per-tonne resource intensity targets for the Indian steel industry through 2030-31, identifying DRI-EAF as one of the two structural iron-making routes alongside BF-BOF. The Petroleum and Natural Gas Regulatory Board (PNGRB) framework under the PNGRB Act 2006 regulates the natural gas transportation, distribution and marketing tariff structure that determines the RLNG landed cost at the gas-based DRI plant gate. The Coal India Ltd Fuel Supply Agreement framework under the Ministry of Coal governs the notified price by grade, the delivery mode and the applicable levies for the coal-based DRI plant. The European Union Carbon Border Adjustment Mechanism under Regulation (EU) 2023/956 imposes the certificate purchase obligation on the EU importer that reflects the embedded direct emissions per tonne of Chapter 72 and 73 steel — with a materially different embedded emissions profile between gas-based and coal-based DRI-EAF routes. Section 194Q of the Income-tax Act 1961 applies to the third-party iron ore, non-coking coal, RLNG and merchant-DRI seller legs. Ind AS 2 governs the per-tonne DRI cost loading into the DRI inventory feeding downstream into crude steel and finished steel.

The RLNG landed cost at the gas-based DRI plant gate is the dominant variable operating cost element and comprises five layers. First, the LNG delivered ex-ship (DES) cost at the LNG import terminal (Hazira, Dahej, Kochi, Ennore, Mundra), indexed to Henry Hub, Brent-linked or JKM benchmark under the specific term contract. Second, the LNG regasification tariff at the LNG terminal (Rs 45 to Rs 55 per mmBtu illustrative). Third, the gas transmission tariff on the PNGRB-authorised natural gas pipeline (GAIL National Gas Grid, Reliance Gas Transportation Infrastructure Ltd, or specific state-level distributor) at Rs 40 to Rs 80 per mmBtu illustrative depending on distance zone. Fourth, the marketing margin of the gas marketer (GAIL Gas, Indian Oil, BPCL Gas, Torrent Gas or captive procurement). Fifth, the applicable 5 percent GST on industrial RLNG supply. For an illustrative all-in landed RLNG cost of Rs 870 per mmBtu (approximately USD 10.5 per mmBtu at Rs 83 per USD), the reducing-agent cost per tonne of DRI at 250 standard cubic metres per tonne DRI (approximately 8.7 mmBtu per tonne DRI at typical Wobbe Index) is approximately Rs 7,570 per tonne DRI on the gas leg alone.

The CIL Fuel Supply Agreement for the coal-based DRI plant prescribes the annual quantity, the applicable grade (G-grade classification G1 to G17 based on Gross Calorific Value in kcal per kilogram, with G7 to G11 typical for DRI feed), the notified price per tonne, the delivery mode and the applicable levies. The non-coking coal CIL FSA steel plant TDS Section 194Q reconciliation Wave 1 sibling unpacks the CIL FSA notified-price mechanic and the Section 194Q compliance framework for the CIL PSU seller leg in operational detail. For a coal-based DRI plant consuming 1.1 tonnes of non-coking coal per tonne DRI at an illustrative Rs 3,700 per tonne CIL FSA-notified price (inclusive of royalty, DMF, NMET, Clean Environment Cess, GST Compensation Cess and applicable GST), the reducing-agent cost is approximately Rs 4,070 per tonne DRI on the coal leg alone — approximately 54 percent of the gas-based reducing-agent cost per tonne DRI in the illustrative scenario.

The CBAM route-differential impact is the single most consequential regulatory overlay for the DRI-EAF EU export leg. The CBAM steel industry EU export carbon border adjustment mechanism reconciliation Wave 2 cornerstone unpacks the CBAM Regulation (EU) 2023/956 certificate purchase workflow, the EU-accredited independent verifier attestation and the Article 9 carbon-price-equivalent offset argument. For the DRI-EAF route, embedded direct emissions per tonne of crude steel are approximately 1.4 to 1.8 tonnes CO2 for the gas-based route and approximately 2.2 to 2.6 tonnes CO2 for the coal-based route. At the illustrative EU ETS reference price of EUR 75 per tonne CO2, the CBAM certificate cost per tonne of DRI-EAF crude steel exported into the EU is approximately EUR 120 for the gas-based route (using the midpoint 1.6 tonnes CO2 per tonne crude steel) and approximately EUR 180 for the coal-based route (using the midpoint 2.4 tonnes CO2 per tonne crude steel) — a EUR 60 per tonne CBAM disadvantage for the coal-based route on the EU export leg. This is a material competitive gap that flips the pre-CBAM per-tonne cost advantage of coal-based DRI on the EU-export sub-portfolio, and is a structural argument for allocating gas-based DRI production to the EU export leg and coal-based DRI production to the domestic and non-EU legs. The parallel cement-sector CBAM walkthrough at cement industry CBAM carbon border adjustment mechanism EU export reconciliation documents the cross-cluster CBAM mechanic and applies analogously — with steel being the larger CBAM-exposed Indian sector at approximately 10 to 12 million tonnes per annum EU export volume.

Section 194Q of the Income-tax Act 1961 applies at 0.1 percent buyer-side TDS to the third-party iron ore, non-coking coal, RLNG and merchant-DRI seller legs above the Rs 50 lakh aggregate threshold per seller per previous year. NMDC (Central Government PSU) iron ore purchase is within Section 194Q per CBDT Circular 20/2021 on Government-PSU commercial trading; the same circular position applies to CIL FSA non-coking coal purchase and to GAIL PSU RLNG purchase. Private-sector iron ore purchase from Sesa Goa, OMDC or private-lease merchant iron ore holders is separately subject to Section 194Q. The Section 393 payment code finder is the operational lookup for the correct Section 194Q payment code 1031 under Section 393 SL 8 (purchase of goods).

A worked example — Hazira gas-based DRI-EAF versus Raigarh coal-based DRI-EAF FY 2026-27 comparison

Illustrative — the following figures represent the operating pattern of two Tier-1 Indian integrated steel producers operating materially different DRI-EAF configurations. Public disclosures by listed Indian integrated steel majors do not reveal per-module per-month RLNG or CIL FSA cost quantum in the granularity below; cross-verify against the current PNGRB natural gas tariff notifications, the current CIL notified-price notifications by grade, the current EU ETS auction clearing prices and your own DRI plant operations records before action. The illustrative reference points used below — RLNG landed cost at USD 10.5 per mmBtu, CIL FSA notified price at Rs 3,700 per tonne, iron ore pellet at Rs 6,500 per tonne, iron ore lump at Rs 4,600 per tonne, EU ETS reference price at EUR 75 per tonne CO2, EUR to INR at Rs 90 — are intended to demonstrate the reconciliation mechanic and do not represent the actual prices for any specific operating year or plant.

Gas-based DRI-EAF — Hazira MIDREX Module 1 plus 2 plus 3 (illustrative 8.6 MTPA crude steel FY 2026-27)

Line itemBasisAmount (illustrative)
Crude steel productionThree-module MIDREX plus EAF-plus-Caster operational cadence8,600,000 tonnes
DRI production (85 percent DRI plus 15 percent scrap in EAF charge)8,600,000 × 0.85 approximate DRI share8,600,000 tonnes DRI equivalent (approximate metallic input)
Iron ore pellet requirement8,600,000 × 1.8 tonnes pellet per tonne DRI (design)15,480,000 tonnes
Iron ore pellet cost15,480,000 × Rs 6,500 per tonne (illustrative)Rs 10,062 crore
Natural gas requirement8,600,000 × 250 standard cubic metres per tonne DRI (design)2,150 million standard cubic metres
Natural gas requirement in mmBtu2,150 million Sm3 × approximately 34.4 mmBtu per thousand Sm3Approximately 74 million mmBtu
Natural gas cost74 million mmBtu × USD 10.5 per mmBtu × Rs 83 per USDRs 6,449 crore
Approximate reducing-agent cost per tonne DRIRs 6,449 crore divided by 8,600,000 tonnesApproximately Rs 7,500 per tonne DRI
Iron ore plus reducing agent (partial)Rs 10,062 + Rs 6,449 croreRs 16,511 crore
Approximate per-tonne DRI iron-ore-plus-gas costRs 16,511 crore divided by 8,600,000 tonnesApproximately Rs 19,200 per tonne DRI on iron ore plus gas alone
Add: power, consumables, labour, depreciation (illustrative aggregate)Approximate 5 percent net addition after captive power nettingApproximately Rs 900 per tonne DRI
Illustrative fully-loaded per-tonne DRI cost (gas-based)Approximately Rs 20,100 per tonne DRI upper-end scenarioApproximately Rs 18,000 to Rs 20,000 per tonne DRI

Coal-based DRI-EAF — Raigarh Rotary Kiln (illustrative 3.6 MTPA crude steel FY 2026-27)

Line itemBasisAmount (illustrative)
Crude steel productionMulti-module rotary kiln plus EAF operational cadence3,600,000 tonnes
DRI productionApproximate 1:1 DRI to crude steel ratio in DRI-heavy EAF charge3,600,000 tonnes DRI equivalent
Iron ore lump requirement (70 percent split)3,600,000 × 1.5 tonnes × 0.7 lump share3,780,000 tonnes
Iron ore lump cost3,780,000 × Rs 4,600 per tonne (illustrative)Rs 1,739 crore
Iron ore pellet requirement (30 percent split)3,600,000 × 1.5 × 0.3 pellet share1,620,000 tonnes
Iron ore pellet cost1,620,000 × Rs 6,500 per tonne (illustrative)Rs 1,053 crore
Non-coking coal requirement3,600,000 × 1.1 tonnes coal per tonne DRI (design)3,960,000 tonnes
Non-coking coal cost3,960,000 × Rs 3,700 per tonne (CIL FSA notified)Rs 1,465 crore
Approximate reducing-agent cost per tonne DRIRs 1,465 crore divided by 3,600,000 tonnesApproximately Rs 4,070 per tonne DRI
Iron ore plus reducing agent (partial)Rs 1,739 + Rs 1,053 + Rs 1,465 croreRs 4,257 crore
Approximate per-tonne DRI iron-ore-plus-coal costRs 4,257 crore divided by 3,600,000 tonnesApproximately Rs 11,825 per tonne DRI on iron ore plus coal alone
Less: appropriate offset for captive DRI-side captive power and consumables nettingApproximate variabilityApproximately Rs (500) to Rs (1,000) per tonne DRI
Illustrative fully-loaded per-tonne DRI cost (coal-based)Approximately Rs 10,825 to Rs 11,325 per tonne DRIApproximately Rs 10,500 to Rs 11,500 per tonne DRI

The gas-based route runs at approximately Rs 7,000 per tonne DRI higher fully-loaded cost than the coal-based route in the illustrative base-case Indian energy price environment — a per-tonne cost differential of approximately 1.7 to 1.9 times. On a plain domestic-supply cost-competitiveness basis, the coal-based route wins. The economics shift materially on the EU export leg once CBAM is loaded.

CBAM route-differential loading on the EU export sub-portfolio (illustrative)

Line itemGas-based DRI-EAFCoal-based DRI-EAF
Illustrative EU export volume500,000 tonnes crude steel500,000 tonnes crude steel
Embedded direct emissions per tonne crude steel (midpoint)1.6 tonnes CO2 per tonne2.4 tonnes CO2 per tonne
Embedded direct emissions total800,000 tonnes CO21,200,000 tonnes CO2
EU ETS reference priceEUR 75 per tonne CO2EUR 75 per tonne CO2
CBAM certificate cost per tonne crude steel exported to EUEUR 120 per tonneEUR 180 per tonne
CBAM certificate cost annual (500,000 tonnes)EUR 60,000,000 (approximately Rs 540 crore at Rs 90 per EUR)EUR 90,000,000 (approximately Rs 810 crore at Rs 90 per EUR)
CBAM route-differential per tonneBaseEUR 60 per tonne disadvantage
CBAM route-differential annual (500,000 tonnes)BaseEUR 30,000,000 disadvantage (approximately Rs 270 crore at Rs 90 per EUR)

The EUR 60 per tonne CBAM route-differential in favour of the gas-based route (approximately Rs 5,400 per tonne at Rs 90 per EUR) closes most of the pre-CBAM per-tonne cost advantage of the coal-based route on the EU export leg. For a producer with a material EU export sub-portfolio, the gas-based route becomes the preferred allocation for EU-bound tonnage, and the coal-based route retains its cost advantage on the domestic and non-EU export legs where CBAM does not apply.

Section 194Q buyer-side TDS on the third-party seller stack (illustrative annual)

Seller legIllustrative annual purchaseSection 194Q at 0.1 percent
Iron ore pellet from KIOCL (Central Government PSU)Rs 3,000 croreRs 3.0 crore
Iron ore pellet from JSW Pellet + Essel Mining + private producersRs 4,000 croreRs 4.0 crore
Non-coking coal from CIL subsidiaries (SECL / MCL / others)Rs 1,465 croreRs 1.465 crore
RLNG from GAIL + Indian Oil + BPCL Gas + private marketersRs 6,449 croreRs 6.449 crore
Iron ore lump from NMDC (Central Government PSU) + private lease holdersRs 1,739 croreRs 1.739 crore

All five seller legs are subject to Section 194Q at 0.1 percent per CBDT Circular 20/2021 for the Government PSU seller legs (NMDC, KIOCL, CIL, GAIL) and per the base Section 194Q applicability for private-sector seller legs above the Rs 50 lakh aggregate threshold per seller per previous year. The illustrative aggregate Section 194Q buyer-side TDS across the two DRI-EAF plants is approximately Rs 16.7 crore per annum, deposited monthly on or before the 7th of the following month (30th of April for March deposits) and reported quarterly on Form 26Q through the standard Section 194Q compliance mechanic.

Common reconciliation breakages

Five breakages recur across Indian DRI-EAF integrated steel producers running the reducing-agent-plus-iron-ore cost accounting stack, and each maps to a specific control failure that a plant operations audit, an EU-accredited CBAM verifier attestation review, a Section 194Q assessment by the Income-tax Officer, or a statutory auditor reviewing DRI inventory valuation and DRI plant depreciation will surface.

  • Reducing-agent consumption per tonne DRI drifts above design specification, understating DRI plant thermal efficiency and overstating per-tonne DRI cost. The most operationally consequential failure is a drift in the reducing-agent consumption per tonne DRI above the design specification — approximately 250 standard cubic metres of natural gas per tonne DRI on the gas-based route or approximately 1.0 to 1.2 tonnes of non-coking coal per tonne DRI on the coal-based route. Causes include shaft furnace or rotary kiln refractory degradation, iron ore pellet quality degradation (below-target metallisation potential due to pellet basicity or below-target reducibility), catalyst degradation on the gas reformer (for MIDREX), or process instability during grade changes. A 5 percent drift in reducing-agent consumption on the illustrative Hazira three-module gas-based configuration represents approximately 3.7 million mmBtu per annum incremental natural gas consumption at Rs 870 per mmBtu = approximately Rs 322 crore per annum incremental reducing-agent cost — a material cost accounting drift that the standing per-module reducing-agent consumption reconciliation to design specification is designed to surface. Reconciliation discipline: monthly per-module reducing-agent consumption per tonne DRI reconciliation against design specification with any deviation above a materiality threshold (illustrative 2 percent of design consumption) flagged for the plant operations head and the DRI process technology head investigation and corrective action, and the deviation cause coded and captured in the plant reliability database for trend analysis and capex justification for refractory or catalyst replacement.

  • RLNG landed cost breakdown mis-allocated between LNG DES cost, regasification tariff, transmission tariff and marketing margin — impacting the Ind AS 2 per-tonne DRI cost sheet and the CBAM Scope 2 boundary for the EU export leg. For a gas-based DRI plant, the RLNG landed cost breakdown into (a) LNG DES cost at the LNG import terminal, (b) LNG regasification tariff at the terminal, (c) gas transmission tariff on the PNGRB-authorised pipeline, (d) marketing margin of the gas marketer and (e) applicable GST is the operational input for the Ind AS 2 per-tonne DRI cost loading and for the CBAM Scope 2 electricity emissions boundary determination (where the transmission tariff and marketing margin can be re-allocated between direct and indirect emissions perimeters depending on the CBAM methodology position). A compliance clerk lumping the all-in landed price into a single “natural gas cost” line without the breakdown loses the ability to track the LNG DES cost against the term contract indexation (Henry Hub, JKM, Brent-linked), the regasification tariff against the terminal-level notification, the transmission tariff against the PNGRB tariff notification and the marketing margin against the gas marketer’s commercial position. Reconciliation discipline: monthly RLNG cost breakdown reconciliation from the gas marketer invoice into the five-layer stack, with each layer cross-referenced to the applicable source notification or contract clause, and any deviation flagged for the plant CFO investigation. The reconciliation failure mode analysis design pillar frames the master-data-driven-cost-breakdown discipline that surfaces this failure at the invoice-capture stage rather than at the year-end audit.

  • Iron ore pellet-vs-lump feed mis-allocated between DRI modules — pellet-only gas-based module fed with lump material, or coal-based module fed with 100 percent pellet without lump. For a plant operating both gas-based MIDREX and coal-based rotary kiln modules on the same iron ore feed yard (integrated steel plants with mixed configuration), the iron ore feed mis-allocation between the two module types is a physical operational risk with material downstream cost accounting consequences. A gas-based MIDREX module fed with lump material (which the shaft furnace cannot process due to counter-current gas flow requirement) will shut down for lump removal; a coal-based rotary kiln module fed with 100 percent pellet without any lump loses the operational optimisation of the lump-fines-pellet blend that maximises kiln productivity. Reconciliation discipline: iron ore feed yard segregation between pellet-yard (feeding gas-based modules) and lump-plus-pellet yard (feeding coal-based modules) with dedicated conveyor and belt scale infrastructure, weighbridge-log-level per-module feed reconciliation against the DRI module receipt log, and any cross-contamination flagged for the plant operations head. The iron ore lump vs fines IMF IMR pricing steel plant reconciliation Wave 1 sibling documents the lump-versus-fines split reconciliation mechanic and the pellet-yard-versus-lump-yard segregation discipline.

  • CBAM embedded emissions per tonne DRI-EAF crude steel over-declared or under-declared, exposing the EU importer to a CBAM certificate short-purchase penalty or an over-purchase leakage. For the EU export leg, the CBAM certificate purchase obligation on the EU importer reflects the embedded direct emissions per tonne of Chapter 72 and 73 steel multiplied by the EU ETS reference price. The embedded emissions declaration is the Indian producer’s disclosure to the EU importer supported by the EU-accredited independent verifier attestation. Under-declaration of embedded emissions leaves the EU importer exposed to a CBAM short-purchase penalty on discovery; over-declaration inflates the CBAM certificate cost and reduces the Indian producer’s EU-export price competitiveness. Reconciliation discipline: per-module per-quarter embedded direct emissions computation from the reducing-agent carbon content and the DRI plant Scope 1 emissions record, roll-up to per-tonne crude steel emissions with the EAF Scope 2 electricity emissions loading, EU-accredited independent verifier attestation for the reporting quarter, and reconciliation to the EU import customs declaration on the CBAM leg. The CBAM steel industry EU export carbon border adjustment mechanism reconciliation Wave 2 cornerstone unpacks the CBAM verifier attestation and reconciliation mechanic in operational detail.

  • Section 194Q incorrectly applied to a captive-supply leg (no seller-buyer transaction) or not applied to a third-party seller leg above the Rs 50 lakh aggregate threshold. The Section 194Q applicability determination on the DRI-EAF procurement stack must correctly distinguish between (a) captive iron ore or captive pellet or captive power supply from within the same legal entity — no seller-buyer transaction, no Section 194Q applicability; (b) third-party purchase from a Government PSU (NMDC iron ore, KIOCL pellet, CIL non-coking coal, GAIL RLNG) — Section 194Q applies per CBDT Circular 20/2021 on Government-PSU commercial trading; (c) third-party purchase from a private-sector seller above the Rs 50 lakh aggregate threshold per previous year — Section 194Q applies at 0.1 percent buyer-side TDS. Mechanically applying Section 194Q to a captive supply leg understates the captive transfer amount and creates a phantom TDS-payable liability; not applying Section 194Q to a genuine third-party seller leg above the threshold leaves the buyer exposed to a Section 194Q short-deduction assessment with 30 percent expenditure disallowance under Section 40(a)(ia). Reconciliation discipline: the payee master in the compliance ledger holds a Section 194Q applicability flag driven off the payee type (captive intercompany / Government PSU / private-sector seller / Government payee under Section 194Q(3)), and the Section 194Q determination is a master-driven read against the payee flag rather than a case-by-case judgement by the treasury clerk. The human errors detection envelope anchor documents the seven-family human-error taxonomy that surfaces this master-driven-versus-manual-read control gap.

How a reconciliation platform handles this

A purpose-built steel reconciliation platform ingests every DRI module production record from the plant Manufacturing Execution System, every gas flow meter reading for gas-based operations, every coal yard weighbridge tally for coal-based operations, every iron ore pellet and lump feed record against the DRI module receipt log, every RLNG landed cost breakdown from the gas marketer invoice (LNG DES cost, regasification tariff, transmission tariff, marketing margin, GST), every Coal India Ltd Fuel Supply Agreement invoice for coal-based operations (notified price by grade, coal royalty, DMF, NMET, Clean Environment Cess, GST Compensation Cess, GST), every Section 194Q buyer-side TDS entry on third-party iron ore and non-coking coal and RLNG and merchant-DRI seller legs, every CBAM embedded emissions record with EU-accredited independent verifier attestation for the EU export leg, every Ind AS 2 per-tonne DRI cost sheet, and every downstream DRI-to-EAF transfer and EAF melting record for the crude steel cost roll-up — against a per-module-per-month reconciliation ledger keyed on the DRI module identifier and the production period. The platform tags each entry at capture with the applicable process route (gas-based MIDREX or HYL-Energiron / coal-based rotary kiln), the reducing-agent consumption benchmark per tonne DRI, the iron ore feed mode (pellet-only for gas-based / lump plus pellet for coal-based), the Section 194Q applicability flag against the payee type, the CBAM export leg tag, and the Ind AS 2 loading tag. Standing dashboard controls surface any reducing-agent consumption deviation above materiality threshold, any RLNG cost breakdown allocation mismatch, any pellet-vs-lump feed mis-allocation between DRI module types, any CBAM embedded emissions declaration deviation from verifier-attested actual, any Section 194Q applicability question on a third-party seller leg above the Rs 50 lakh threshold, any monthly reducing-agent-cost reconciliation break and any pending EU-accredited verifier attestation for the reporting quarter. Match-rate improvement of 51 to 88 percent on the reducing-agent-consumption-to-DRI-production reconciliation and on the invoice-cost-to-ledger-balance reconciliation, combined with an ISO 27001:2022 posture and DPDP Act 2023 aligned data handling for regulator-facing and EU-verifier-facing submissions, is what makes the platform an infrastructure investment for a Tier-1 or Tier-2 Indian DRI-EAF integrated steel producer operating multi-module reducing-agent-cost-heavy cost accounting stacks — rather than a spreadsheet substitute that leaves the reducing-agent consumption reconciliation, the RLNG or CIL FSA cost breakdown allocation, the pellet-vs-lump feed segregation, the CBAM embedded emissions attestation and the Section 194Q third-party seller applicability determination as manual overheads on a hybrid plant-operations-plus-plant-finance-plus-compliance team. The commercial pillar for the steel sub-cluster is Steel reconciliation software India; the broader authority for the platform is reconciliation software India. The Steel insights cluster hub provides the operational index to every Wave 1 and Wave 2 reconciliation walkthrough across the integrated steel plant and DRI-EAF value chain, and the reconciliation playbook for monthly close framework provides the month-end close cadence discipline for stitching the reducing-agent, iron ore, Section 194Q, CBAM and Ind AS 2 reconciliation artefacts into the plant closing packet.

Terra Insight
Terra Insight Editorial Team Reconciliation Infrastructure

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Published 28 July 2026
Domain expertise
TDS Reconciliation GST Input Credit Platform Settlements NACH Batch Matching Bank Reconciliation Form 26AS Matching ERP Integrations Enterprise Finance Ops
Primary reference: Ministry of Steel, Government of India — for the national DRI production and route-mix statistics (India is the world's largest DRI producer at approximately 35 to 40 million tonnes per annum), the Ministry of Steel National Steel Policy 2017 route-mix targets and the Perform Achieve and Trade (PAT) cycle Specific Energy Consumption (SEC) reduction targets that anchor the reducing-agent efficiency measurement, and the reference framework for both gas-based DRI (MIDREX and HYL-Energiron process families) and coal-based DRI (rotary kiln process) route classification that governs the reducing-agent cost accounting and CBAM route-differential disclosure at the plant level.
Primary sources cited
Last reviewed against sources on 28 July 2026
  • Ministry of Steel — National Steel Policy 2017 and DRI route framework — The National Steel Policy 2017 issued by the Ministry of Steel (MoS) frames the medium-term steel-sector production, route-mix and per-tonne resource intensity targets for the Indian steel industry through 2030-31. India is the world's largest producer of Direct Reduced Iron (DRI, also called sponge iron) at approximately 35 to 40 million tonnes per annum against a global DRI production of approximately 130 million tonnes per annum. The Indian DRI production splits across two process routes — the gas-based DRI route (MIDREX and HYL-Energiron process families) using natural gas as the reducing agent, and the coal-based DRI route (rotary kiln process, also called SL/RN or DRC process family) using non-coking coal as the reducing agent. Gas-based DRI in India sits predominantly at coastal integrated plants with access to Regasified Liquefied Natural Gas (RLNG) supply from LNG import terminals (Hazira, Dahej, Kochi, Ennore, Mundra) — the largest gas-based DRI capacity is at the Hazira integrated steel plant in Gujarat. Coal-based DRI is spread across regional producers in Chhattisgarh (Raigarh, Bilaspur, Raipur belt), Odisha (Angul, Rourkela, Sundargarh belt), Jharkhand (Dhanbad, Bokaro belt) and West Bengal (Durgapur belt), typically producing 0.05 to 1.5 million tonnes per annum per unit and feeding either captive Electric Arc Furnace (EAF) or Induction Furnace (IF) melting units or selling to third-party melting units in the merchant DRI model.
  • Petroleum and Natural Gas Regulatory Board (PNGRB) — RLNG landed cost framework — The Petroleum and Natural Gas Regulatory Board (PNGRB) established under the Petroleum and Natural Gas Regulatory Board Act 2006 regulates the natural gas transportation, distribution and marketing framework in India. Regasified Liquefied Natural Gas (RLNG) landed cost at the gas-based DRI plant gate comprises (a) the LNG delivered ex-ship (DES) cost at the LNG import terminal (Hazira, Dahej, Kochi, Ennore, Mundra) — indexed to Henry Hub, Brent-linked or JKM (Japan Korea Marker) benchmark under the specific term contract; (b) the LNG regasification tariff at the LNG terminal — Rs 45 to Rs 55 per million British thermal units (mmBtu) illustrative; (c) the gas transmission tariff on the PNGRB-authorised natural gas pipeline (GAIL National Gas Grid, Reliance Gas Transportation Infrastructure Ltd, or specific state-level distributor) at Rs 40 to Rs 80 per mmBtu illustrative depending on distance zone; (d) the marketing margin of the gas marketer (GAIL Gas, Indian Oil, BPCL Gas, Torrent Gas, or the plant's own procurement); (e) the applicable GST at 5 percent (natural gas is currently outside GST and taxed under the state-level VAT regime for CNG and PNG in some states, but the industrial LNG-derived RLNG supply is under the 5 percent GST regime under the notification for natural gas supply). For a gas-based DRI plant operating at an illustrative Rs 700 per mmBtu (approximately USD 10.5 per mmBtu at Rs 83 per USD conversion) landed all-in RLNG cost, the reducing-agent cost per tonne of DRI at 250 standard cubic metres per tonne DRI (equivalent to approximately 8.7 mmBtu per tonne DRI at 34.4 mmBtu per thousand cubic metres for natural gas of typical Wobbe Index) is approximately Rs 6,090 per tonne DRI on the gas leg alone.
  • Coal India Ltd Fuel Supply Agreement (FSA) framework for non-coking coal — Coal India Ltd (CIL, a Central Government PSU under the Ministry of Coal) and its subsidiaries (Mahanadi Coalfields Ltd, South Eastern Coalfields Ltd, Northern Coalfields Ltd, Central Coalfields Ltd, Bharat Coking Coal Ltd, Western Coalfields Ltd, Eastern Coalfields Ltd, North Eastern Coalfields) supply domestic non-coking coal to the coal-based DRI industry under Fuel Supply Agreement (FSA) contracts on a long-term basis. The FSA framework prescribes the annual quantity, the applicable grade (G-grade classification G1 to G17 based on Gross Calorific Value in kcal per kilogram, with G7 to G11 typical for DRI feed), the notified price per tonne (CIL notified price by grade under the notification of the Ministry of Coal), the delivery mode (Free on Rail at pithead siding or Free on Truck at the mine or Free on Board at the port), and the applicable levies (Coal Royalty at 14 percent ad valorem under the MMDR Act 1957 Second Schedule, DMF and NMET add-ons, Clean Environment Cess at Rs 400 per tonne under the Finance Act 2010 as amended, GST Compensation Cess at Rs 400 per tonne, and 5 percent IGST or CGST plus SGST). Section 194Q of the Income-tax Act 1961 applies to the CIL FSA purchase leg above the Rs 50 lakh aggregate threshold per previous year per CBDT Circular 20/2021 which clarifies that Central Government PSU commercial trading is within Section 194Q — the coal-based DRI plant deducts 0.1 percent buyer-side TDS on the CIL FSA purchase cost and deposits monthly against the CIL PAN with quarterly return through the standard Section 194Q compliance mechanic.
  • European Union — Carbon Border Adjustment Mechanism Regulation 2023/956 — The European Union Carbon Border Adjustment Mechanism (CBAM) under Regulation (EU) 2023/956 applies to imports of specified goods (cement, iron and steel, aluminium, fertilizer, hydrogen and electricity) from third-country producers into the European Union customs territory. For the iron and steel sector, CBAM covers Combined Nomenclature Chapters 72 and 73 comprehensively, and the certificate purchase obligation crystallises on 1 January 2026. The CBAM certificate cost per tonne of imported steel is a function of the embedded direct emissions (Scope 1 direct process emissions per tonne of the specified good) plus a specified share of indirect emissions (Scope 2 purchased electricity emissions), multiplied by the average auction clearing price of the European Union Emissions Trading System (EU ETS) allowances for the reference period, less a factor accounting for any carbon price paid in the country of origin. For the DRI-EAF steel production route, the embedded direct emissions differ materially by DRI reducing-agent choice — gas-based DRI-EAF produces approximately 1.4 to 1.8 tonnes CO2 per tonne of crude steel end-to-end (DRI stage plus EAF stage), and coal-based DRI-EAF produces approximately 2.2 to 2.6 tonnes CO2 per tonne of crude steel end-to-end. At a reference EU ETS price of EUR 75 per tonne CO2, the CBAM certificate cost per tonne of DRI-EAF crude steel exported into the EU is approximately EUR 105 to EUR 135 for the gas-based route and approximately EUR 165 to EUR 195 for the coal-based route — a EUR 50 to EUR 70 per tonne CBAM disadvantage for the coal-based DRI route on the EU export leg. Verification of the embedded emissions per tonne is by an EU-accredited independent verifier attestation.
  • Ind AS 2 Inventories (Companies (Indian Accounting Standards) Rules 2015) — Ind AS 2 governs the accounting for inventories. Paragraph 10 provides that the cost of inventories comprises all costs of purchase, costs of conversion and other costs incurred in bringing the inventories to their present location and condition. For a DRI-EAF integrated steel producer, the per-tonne DRI cost that flows into the crude steel weighted-average cost carrying value comprises (a) the iron ore raw material cost per tonne DRI — approximately 1.8 to 2.2 tonnes iron ore pellet for gas-based DRI or 1.4 to 1.6 tonnes iron ore lump plus pellet for coal-based DRI, loaded per the [iron ore royalty DMF NMET steel plant cost accounting](/insights/iron-ore-royalty-dmf-nmet-steel-plant-cost-accounting-india/) captive-lease or third-party procurement cost stack; (b) the reducing-agent cost per tonne DRI — approximately 250 standard cubic metres of natural gas at the RLNG landed price for gas-based DRI, or approximately 1.0 to 1.2 tonnes non-coking coal at the CIL FSA-notified price plus Clean Environment Cess plus GST Compensation Cess for coal-based DRI; (c) the process consumables (dolomite flux, limestone flux for coal-based rotary kiln, refractory consumption pro-rata per tonne DRI); (d) the power cost per tonne DRI at the captive power plant or grid tariff rate; (e) the labour and other conversion overheads including pro-rata depreciation of the DRI plant capex (Rs 800 to Rs 1,200 crore per million tonnes per annum capacity illustrative for a modern MIDREX module, Rs 400 to Rs 700 crore per million tonnes per annum for a coal-based rotary kiln module). These variable operating costs are expensed under Ind AS 2 as part of the cost of DRI inventory feeding downstream into crude steel and finished steel inventory.
  • Income-tax Act 1961, Section 194Q on third-party seller of iron ore, coal and natural gas — Section 194Q of the Income-tax Act 1961 (introduced by Finance Act 2021, effective 1 July 2021) requires any buyer paying any sum to any resident seller for purchase of any goods above the Rs 50 lakh aggregate threshold per previous year per seller to deduct 0.1 percent buyer-side Tax Deducted at Source at the point of payment or credit whichever is earlier. For the DRI-EAF steel plant procurement stack, Section 194Q applies separately to (a) third-party iron ore pellet purchase from NMDC (Central Government PSU) per CBDT Circular 20/2021, from KIOCL (Central Government PSU pellet producer), from Sesa Goa (private-sector merchant iron ore lease holder), from OMDC (Odisha Mining Corporation, state PSU) or from private-sector pellet producers; (b) third-party CIL Fuel Supply Agreement non-coking coal purchase per CBDT Circular 20/2021; (c) third-party RLNG purchase from GAIL (Central Government PSU) or from private-sector gas marketers per CBDT Circular 20/2021 (natural gas is a good within Section 194Q); (d) third-party coal-based DRI purchase in the merchant-DRI model from regional producers by the EAF or Induction Furnace melter. The Section 194Q payment code 1031 under Section 393 SL 8 (purchase of goods) applies to all four seller legs; the deducted TDS is deposited monthly with quarterly return through the standard Section 194Q compliance mechanic. The [Section 393 payment code finder](/tools/section-393-payment-code-finder/) is the operational lookup for the applicable TDS payment code across the DRI procurement stack.

Frequently Asked Questions

What are the two DRI process routes in India, what is the reducing-agent consumption per tonne of DRI on each route, and why does India have the largest DRI capacity globally?
The two DRI (Direct Reduced Iron, also called sponge iron) process routes in India are (a) the gas-based DRI route using natural gas as the reducing agent, dominated by the MIDREX process family (developed by Midrex Technologies, licensed globally) and the HYL-Energiron process family (developed by Tenova HYL, licensed globally) with a shaft furnace where iron ore pellet is reduced in a counter-current gas flow of hot reducing gas produced by reforming natural gas; and (b) the coal-based DRI route using non-coking coal as the reducing agent, using the rotary kiln process (also called SL/RN or DRC process family — Stelco-Lurgi-Republic Steel-National Lead / Direct Reduction Corporation) with a horizontal rotary kiln where iron ore lump or pellet is reduced against a co-current or counter-current flow of coal-derived reducing gas. The reducing-agent consumption per tonne of DRI is approximately 250 standard cubic metres of natural gas per tonne of DRI on the gas-based route (approximately 8.7 million British thermal units at typical natural gas Wobbe Index) and approximately 1.0 to 1.2 tonnes of non-coking coal per tonne of DRI on the coal-based route (approximately 3.5 to 4.5 gigacalories at G7 to G11 grade non-coking coal Gross Calorific Value). The iron ore input per tonne of DRI is approximately 1.8 to 2.2 tonnes of iron ore pellet for the gas-based route (pellet is essential — the MIDREX and HYL shaft furnace does not accept lump ore due to the counter-current gas flow requirement) and approximately 1.4 to 1.6 tonnes of iron ore lump or pellet for the coal-based route (both lump and pellet are usable in the rotary kiln, with the split typically 70 to 80 percent lump and 20 to 30 percent pellet by weight). India produces approximately 35 to 40 million tonnes per annum of DRI against a global DRI production of approximately 130 million tonnes per annum — the largest single-country DRI production globally. The two structural drivers are (a) India's structural shortage of coking coal for the BF-BOF route (India imports 60 to 70 million tonnes per annum of coking coal, primarily from Australia, USA and Mozambique) which pushes the sector to alternative iron-making routes; and (b) India's large domestic non-coking coal base (Coal India Ltd produces 750 million tonnes per annum) which supports the coal-based DRI route economics at a per-tonne cost point below the imported-coking-coal-dependent BF-BOF route.
How does the reducing-agent cost per tonne of DRI compare between the gas-based route on RLNG landed cost at USD 10.5 per mmBtu and the coal-based route on CIL FSA non-coking coal, and what does this mean for the per-tonne DRI cost economics?
The reducing-agent cost per tonne of DRI is the largest variable operating cost element on both routes and the primary driver of the route-choice economics. For the gas-based DRI route at 250 standard cubic metres of natural gas per tonne of DRI (approximately 8.7 million British thermal units per tonne DRI) at an illustrative Regasified Liquefied Natural Gas (RLNG) landed price of USD 10.5 per million British thermal units at Rs 83 per US dollar conversion — a landed all-in price of approximately Rs 870 per million British thermal units — the reducing-agent cost is approximately Rs 7,570 per tonne of DRI on the gas leg alone. For the coal-based DRI route at 1.1 tonnes of non-coking coal per tonne of DRI at an illustrative Coal India Ltd Fuel Supply Agreement (FSA) notified price of Rs 3,700 per tonne for G7 to G11 grade non-coking coal (inclusive of coal royalty at 14 percent ad valorem plus DMF plus NMET plus Clean Environment Cess at Rs 400 per tonne plus GST Compensation Cess at Rs 400 per tonne plus 5 percent GST) — the reducing-agent cost is approximately Rs 4,070 per tonne of DRI on the coal leg alone. The gas-based reducing agent is approximately 1.86 times the coal-based reducing agent cost per tonne DRI in the illustrative scenario, which explains why the coal-based DRI route retains a per-tonne cost advantage of approximately Rs 3,500 to Rs 5,000 per tonne DRI against the gas-based route in the base-case Indian energy price environment. The illustrative fully-loaded per-tonne DRI cost including iron ore, reducing agent, power, consumables and depreciation runs approximately Rs 18,000 to Rs 19,000 per tonne DRI for the gas-based MIDREX or HYL route and approximately Rs 10,500 to Rs 11,500 per tonne DRI for the coal-based rotary kiln route. The gas-based route retains structural advantages on (a) DRI product quality (higher metallisation, lower carbon content, better EAF melting efficiency), (b) plant labour and O&M efficiency, (c) emissions intensity (1.4 to 1.8 tonnes CO2 per tonne DRI-EAF crude steel versus 2.2 to 2.6 for coal-based), and (d) CBAM route-differential positioning for the EU export leg — approximately EUR 50 to EUR 70 per tonne CBAM cost advantage for the gas-based route at the reference EU ETS price of EUR 75 per tonne CO2.
What is the CBAM route-differential impact for a Tier-1 integrated Indian steel producer running a gas-based DRI-EAF configuration versus a coal-based DRI-EAF configuration on the EU export leg?
The European Union Carbon Border Adjustment Mechanism (CBAM) under Regulation (EU) 2023/956 imposes a certificate purchase obligation on the importer of steel into the EU customs territory (Combined Nomenclature Chapters 72 and 73) that reflects the embedded direct emissions per tonne of the specified good multiplied by the average auction clearing price of the EU Emissions Trading System (EU ETS) allowances for the reference period, less any carbon price paid in the country of origin. The certificate purchase obligation crystallises on 1 January 2026 after the transitional reporting-only regime from October 2023. For the DRI-EAF route, the embedded direct emissions per tonne of crude steel are approximately 1.4 to 1.8 tonnes CO2 for the gas-based route and approximately 2.2 to 2.6 tonnes CO2 for the coal-based route — a route-differential of approximately 0.8 tonnes CO2 per tonne of crude steel. At an illustrative EU ETS reference price of EUR 75 per tonne CO2, the CBAM certificate cost per tonne of DRI-EAF crude steel exported into the EU is approximately EUR 120 for the gas-based route (using the midpoint 1.6 tonnes CO2 per tonne crude steel) and approximately EUR 180 for the coal-based route (using the midpoint 2.4 tonnes CO2 per tonne crude steel) — a EUR 60 per tonne CBAM disadvantage for the coal-based route. Scaled over an annual EU export volume of illustrative 500,000 tonnes of crude steel, the coal-based route CBAM disadvantage is EUR 30 million (approximately Rs 270 crore at Rs 90 per EUR) — a material competitive gap that flips the pre-CBAM per-tonne cost advantage of coal-based DRI on the EU-export sub-portfolio. The route-differential does not affect the Indian domestic and non-EU export legs — but for a producer with a material EU export book, the CBAM route-differential is a structural argument for allocating gas-based DRI production to the EU export leg and coal-based DRI production to the domestic and non-EU legs. The [CBAM steel industry EU export carbon border adjustment mechanism reconciliation](/insights/cbam-steel-industry-eu-export-carbon-border-adjustment-mechanism-reconciliation/) Wave 2 cornerstone unpacks the CBAM certificate purchase workflow, the EU-accredited independent verifier attestation and the Article 9 carbon-price-equivalent offset argument in operational detail.
How does Section 194Q apply to the third-party iron ore, non-coking coal and natural gas seller legs for a DRI-EAF steel plant?
Section 194Q of the Income-tax Act 1961 (introduced by Finance Act 2021, effective 1 July 2021) requires any buyer paying any sum to any resident seller for purchase of any goods above the Rs 50 lakh aggregate threshold per previous year per seller to deduct 0.1 percent buyer-side Tax Deducted at Source at the point of payment or credit whichever is earlier. For the DRI-EAF steel plant, Section 194Q applies separately to four goods-purchase legs. First, third-party iron ore pellet purchase from NMDC (Central Government PSU) per CBDT Circular 20/2021 which clarifies that Central Government PSU commercial trading is within Section 194Q, from KIOCL (Central Government PSU pellet producer), from Sesa Goa (private-sector merchant iron ore lease holder), from OMDC (Odisha Mining Corporation, state PSU) or from private-sector pellet producers — deducted at 0.1 percent buyer-side against the seller's PAN. Second, third-party Coal India Ltd Fuel Supply Agreement non-coking coal purchase per CBDT Circular 20/2021 — deducted at 0.1 percent against the CIL PAN; the [non-coking coal CIL FSA steel plant TDS Section 194Q reconciliation](/insights/non-coking-coal-cil-fsa-steel-plant-tds-section-194q-reconciliation/) Wave 1 sibling documents the CIL FSA compliance mechanic in operational detail. Third, third-party RLNG purchase from GAIL (Central Government PSU) or from private-sector gas marketers per CBDT Circular 20/2021 — natural gas is a good within Section 194Q for the industrial RLNG supply leg. Fourth, third-party coal-based DRI purchase from regional producers in the merchant-DRI model by the standalone EAF or Induction Furnace melter — deducted at 0.1 percent against the DRI seller's PAN. The Section 194Q payment code 1031 under Section 393 SL 8 (purchase of goods) applies to all four seller legs. The deducted TDS is deposited monthly on or before the 7th of the following month (30th of April for March deposits) and reported quarterly on Form 26Q through the standard Section 194Q compliance mechanic. The Ind AS 2 per-tonne DRI cost loading captures the gross seller price (before Section 194Q deduction) with the Section 194Q deducted amount posted as a TDS-payable liability separately.
What is the standard monthly reconciliation packet for a DRI-EAF integrated steel plant on the reducing-agent and iron ore cost accounting stack?
The standard monthly reconciliation packet for a DRI-EAF integrated steel plant assembles eleven interlocking artefacts. First, the monthly DRI production record from the plant Manufacturing Execution System (MES) or Distributed Control System (DCS) with the DRI tonnage per module (multiple MIDREX or HYL modules for gas-based, multiple rotary kiln modules for coal-based) certified by the plant operations head. Second, the iron ore feed record with tonnage split between iron ore pellet and iron ore lump against the DRI module receipt log, reconciled to the [iron ore lump vs fines IMF IMR pricing steel plant reconciliation](/insights/iron-ore-lump-vs-fines-imf-imr-pricing-steel-plant-reconciliation/) captive-lease or third-party procurement cost stack. Third, the reducing-agent consumption record — for gas-based, the natural gas volume in standard cubic metres per DRI module against the DCS gas flow meter log with GC-analysis-certified Wobbe Index and Gross Calorific Value; for coal-based, the non-coking coal tonnage per module against the coal yard weighbridge log with laboratory-certified Gross Calorific Value per shipment. Fourth, the RLNG landed cost breakdown for gas-based operations — LNG DES cost per mmBtu, regasification tariff, gas transmission tariff, marketing margin, applicable GST — from the monthly gas marketer invoice. Fifth, the CIL Fuel Supply Agreement invoice for coal-based operations — notified price by grade, coal royalty, DMF, NMET, Clean Environment Cess, GST Compensation Cess, applicable GST — reconciled to the CIL delivery challan and rake tally. Sixth, the Section 194Q sub-ledger with the buyer-side TDS deducted on iron ore, non-coking coal, RLNG and merchant-DRI seller legs at 0.1 percent above the Rs 50 lakh aggregate threshold per seller per previous year, with monthly deposit challan and quarterly Form 26Q filing evidence. Seventh, the CBAM embedded emissions record for the EU export leg — direct process emissions per tonne DRI from the DRI module, indirect Scope 2 emissions from the captive power or grid power feeding the EAF stage, EU-accredited independent verifier attestation for the reporting quarter. Eighth, the Ind AS 2 per-tonne DRI cost sheet with iron ore, reducing agent, process consumables, power, labour and depreciation loading rolled into the DRI inventory weighted-average cost. Ninth, the DRI-to-EAF transfer record with tonnage moved from the DRI storage to the EAF charge bin. Tenth, the EAF melting record with the crude steel tonnage produced per heat against the DRI plus scrap plus flux plus alloy charge weight and the power consumption per heat. Eleventh, the monthly Perform Achieve Trade (PAT) Specific Energy Consumption (SEC) tracking for the DRI-EAF plant against the notified PAT cycle target. Terra Insight's [reconciliation playbook for monthly close](/insights/reconciliation-playbook-monthly-close-india/) framework provides the operational cadence discipline for stitching these eleven artefacts into the plant month-end close packet.

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