What is the treatment of SEZ transactions?

Supplies to SEZ

  • Supplies from DTA to SEZ units or developers are treated as zero-rated
  • Supplier can export under LUT without paying IGST or pay IGST and claim refund
  • Goods or services must be used for authorized operations of SEZ
  • Invoice must clearly mention supply to SEZ and support with endorsement
  • E-way bill is mandatory if applicable based on value and distance

Supplies from SEZ

  • Supplies made by SEZ units to outside India are exported and zero-rated
  • Supplies to DTA from SEZ are treated as imports and taxed accordingly
  • Goods/services moved from SEZ to non-SEZ units attract IGST and customs duties
  • SEZ cannot claim exemption for supplies made to domestic markets
  • DTA buyer must act as importer and pay applicable tax

Input Tax Credit and Refunds

  • SEZ supplier can claim refund of IGST paid on inputs
  • SEZ buyer may also claim refund on IGST charged if applicable
  • Refunds processed through RFD-01 with proof of endorsement
  • Credit notes, invoices, shipping bills are crucial for processing claims
  • No ITC on supplies to SEZ under LUT mode since tax is not paid

Invoicing and Records

  • Invoice must mention recipient’s SEZ registration and nature of supply
  • Proper classification under zero-rated column in GSTR-1 is required
  • Documentation must include SEZ unit’s endorsement and authorization letter
  • Books must clearly separate SEZ supplies from regular domestic sales
  • Internal registers must match return disclosures and refund claims

Compliance Best Practices

  • Maintain LUT/Bond acknowledgments and renewal proof
  • Obtain endorsed copies from SEZ officer for each supply
  • Avoid misuse of SEZ supply category for tax avoidance
  • Conduct regular internal audits for refund tracking
  • Train accounts teams on DTA-SEZ differences and document requirements

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