CORAA

GST Compliance Checklist for SEZ Units / Developers

Zero-rated-supply treatment for SEZ units and developers, the LUT-vs-bond choice for exports without payment of tax, and which refund route actually applies to an SEZ-facing supply.

Free · CORAA original — SA-aligned
Updated 28 Jul 2026
Basis
Sec 16, IGST Act — zero-rated supply
Routes
LUT (ITC refund) or IGST-paid (tax refund)
Gatekeeper
SEZ endorsement for authorised operations
Format
Microsoft Word (.docx)
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GST COMPLIANCE CHECKLIST FOR SEZ UNITS / DEVELOPERS

Entity: ___ · GSTIN: ___ · Financial year ended: ___

A. Zero-rated supply position

Supply of goods or services to an SEZ unit or SEZ developer, for authorised operations, is a zero-rated supply under Sec 16 of the IGST Act — treated on par with an export, regardless of whether the supplier is inside or outside the SEZ. The supplier (if outside the SEZ, supplying TO the SEZ) can either supply under LUT/bond without payment of tax and claim refund of accumulated ITC, or pay IGST and claim refund of the tax paid.

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Common questions

FAQs.

Is every supply to an SEZ unit automatically zero-rated?
Only if it is for the SEZ unit's or developer's authorised operations. A supply to an SEZ entity for a purpose outside its authorised operations does not qualify for zero-rated treatment, which is why the SEZ officer's endorsement confirming receipt for authorised operations is central to supporting the claim.
Should a supplier to SEZ use LUT or pay IGST and claim refund?
Both are valid; the choice is largely a cash-flow decision. LUT avoids upfront tax outlay but ties up ITC until refunded; paying IGST and claiming refund is often processed faster but requires funding the tax upfront. There is no default "correct" choice — document which route the entity has adopted and why.
Can the SEZ unit itself claim a GST refund, or is it always the supplier?
In specified circumstances the SEZ unit/developer, as recipient, can claim the refund of tax paid on its inward supplies rather than the supplier claiming it — confirm which party is actually filing in the specific arrangement rather than assuming the supplier always does, since duplicate or conflicting claims from both sides are a real risk if this isn't clearly established upfront.
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