New to GST and not sure which registration type applies to you? Start with our GST registration guide.
Why an SEZ unit needs its own registration
Rule 8 of the CGST Rules treats a unit located in a Special Economic Zone as distinct from the same person's units in the Domestic Tariff Area, and requires a separate application for registration. An SEZ developer registers separately too.
That has three practical consequences:
- Separate books and returns. The SEZ unit files its own GSTR-1 and GSTR-3B under its own GSTIN.
- Supplies between your own units are supplies. A movement from your Domestic Tariff Area office to your SEZ unit is a supply between two registered persons, on a tax invoice, and not an internal transfer.
- One registration per zone presence. A unit in a second zone, or a developer role alongside a unit, is registered on its own footing.
Get this structure right at the start. Retrofitting a separate GSTIN after a year of invoicing everything through the Domestic Tariff Area registration is a reconciliation exercise nobody enjoys.
| Term | What it means |
|---|---|
| Letter of Undertaking | Form GST RFD-11: lets you make a zero-rated supply without paying integrated tax, filed online once for each financial year. |
| Refund application | Form GST RFD-01 on the GST portal, used to claim unutilised input tax credit on zero-rated supplies, or a refund of integrated tax already paid on them. |
| Domestic Tariff Area | The rest of India outside the zone. A supply from the Domestic Tariff Area to your unit is zero-rated for the supplier where it is for authorised operations. A clearance from your unit into the Domestic Tariff Area is treated like an import and the buyer pays the duties, including integrated tax. |
Zero rating applies to authorised operations only
Section 16(1)(b) of the IGST Act zero-rates the supply of goods or services to a Special Economic Zone developer or unit for authorised operations. Those last three words were inserted by the Finance Act 2021 and brought into force on 1 October 2023 by Notification 27/2023-Central Tax.
Before that date, suppliers treated a supply to an SEZ as zero-rated because of who the recipient was. Now the test is what the supply is for.
What this changes in practice
- Your Letter of Approval and the list of authorised operations become tax documents, not just SEZ paperwork. Share them with your suppliers.
- A supply outside the authorised operations, such as something for a staff amenity or an activity the zone has not approved, is an ordinary taxable supply. Your supplier should charge tax on it.
- A refund on a supply to an SEZ needs the endorsement of the specified officer of the zone, confirming that the goods were admitted in full into the zone for authorised operations, or that the services were received for authorised operations.
The endorsement is where SEZ refunds stall. Build it into the month-end routine rather than collecting endorsements when a refund is already overdue.
Which supplies are zero-rated, and which are not
Four directions, four answers. Getting these the wrong way round is the commonest SEZ error we see.
| Supply | Treatment | Who carries it |
|---|---|---|
| Domestic Tariff Area supplier to your SEZ unit, for authorised operations | Zero-rated under section 16(1)(b) | The supplier, under a Letter of Undertaking or with a refund of tax paid |
| Domestic Tariff Area supplier to your SEZ unit, not for authorised operations | Ordinary taxable supply | The supplier charges tax in the normal way |
| Your SEZ unit exporting out of India | Zero-rated under section 16(1)(a) | You, under a Letter of Undertaking or with a refund of tax paid |
| Your SEZ unit to another SEZ unit or developer, for authorised operations | Zero-rated under section 16(1)(b) | You, on the same two routes |
| Your SEZ unit clearing goods into the Domestic Tariff Area | Not zero-rated. Treated like an import, with duties including integrated tax paid on clearance | The buyer who files the bill of entry, in the normal case |
A clearance into the Domestic Tariff Area is an inter-state supply whatever the physical distance involved, because the zone is treated as outside the Domestic Tariff Area for this purpose.
The registration process
- Read the approval. Letter of Approval from the Development Commissioner and the list of authorised operations reviewed, because the authorised-operations list is what decides which incoming supplies can be zero-rated.
- File the registration. A separate registration for the unit, distinct from the Domestic Tariff Area office, as Rule 8 requires.
- File the Letter of Undertaking. Form GST RFD-11 filed for the financial year, before the first zero-rated supply of the year.
- Choose the refund route. Supply under the Letter of Undertaking and claim unutilised credit, or pay integrated tax and claim it back.
- Set the filing rhythm. GSTR-1 and GSTR-3B each period with zero-rated supplies reported in the right tables, and refund applications filed for the periods chosen, with the specified officer's endorsement in support.
We check every scan for name, address and signature mismatches before the application goes in.
Documents you will need
- Letter of Approval from the Development Commissioner, with the list of authorised operations
- Entity PAN, certificate of incorporation or partnership deed
- PAN and Aadhaar of the authorised signatory, with the board resolution or authorisation letter
- Proof of the premises allotted inside the zone
- Bank account proof
- The existing Domestic Tariff Area GSTIN, where one is held under the same PAN
SEZ GST registration fee
Our professional fee is ₹1,499 for the SEZ unit or developer registration. There is no government fee for the registration or for the Letter of Undertaking.
| Item | Amount |
|---|---|
| Regikart professional fee, SEZ unit or developer GST registration | ₹1,499 |
| Government fee for the registration application | No government fee |
| Government fee for the Letter of Undertaking, Form GST RFD-11 | No government fee |
| Government fee for a refund application, Form GST RFD-01 | No government fee |
| Authorised-operations mapping and refund filing | On quote |
Professional fees exclude GST at 18%. Government fees, where they apply, are paid at actuals to the department and are shown separately. Fees verified on 22 September 2026.
Interest and late fees are separate and are paid to the government. Tax paid late carries interest at 18% a year under section 50(1).
What is included: a review of the Letter of Approval and the authorised-operations list, the registration application for the unit or the developer, the Letter of Undertaking for the current financial year, a note on how zero-rated supplies are reported in GSTR-1 and GSTR-3B, and the endorsement checklist your suppliers will ask for.
Forms, returns and dates
| Form or return | What it is for | When |
|---|---|---|
| Registration application | A separate GSTIN for the SEZ unit or the developer | Before supplies begin |
| GST RFD-11 | Letter of Undertaking, so a zero-rated supply can be made without paying integrated tax | Once for each financial year, before the first zero-rated supply of the year |
| GSTR-1 | Outward supplies, with zero-rated supplies reported in the right tables | 11th of the next month, or 13th after the quarter under QRMP |
| GSTR-3B | Summary return and tax payment | 20th of the next month, or 22nd or 24th after the quarter under QRMP |
| GST RFD-01 | Refund of unutilised credit on zero-rated supplies, or of integrated tax paid on them | For the periods you choose to claim, with the specified officer's endorsement in support |
| GSTR-9 | Annual return, mandatory above ₹2 crore aggregate turnover, with self-certified GSTR-9C above ₹5 crore | 31 December after the financial year |
The LUT is the one people forget. It is per financial year, and a zero-rated supply made before the year's LUT is on file is awkward to regularise. For the LUT itself, see LUT filing; for the refund mechanics, see GST refund; every date is in the compliance calendar.
Refunds: the two routes and what officers ask for
Zero rating gives you a choice under section 16(3), and the right choice depends on your cash position.
- Supply under the Letter of Undertaking and claim a refund of unutilised input tax credit. No tax leaves your bank account, but credit builds up until the refund arrives.
- Pay integrated tax and claim it back. Faster in some cases, but the cash goes out first. Where the government has notified a class of persons for this route, it applies to them.
What a refund file usually needs
- The endorsement of the specified officer that the goods were admitted in full into the zone for authorised operations, or that the services were received for authorised operations.
- Invoices matching the zero-rated figures in GSTR-1 and GSTR-3B.
- Proof of receipt of payment, where the refund relates to services.
- A declaration that the recipient has not claimed input tax credit on the supply, where the supplier is claiming.
No refund of unutilised credit, or of integrated tax paid, is allowed on a zero-rated supply of goods that is subject to export duty.
Why Regikart for SEZ GST registration
Regikart is a CA and CS firm serving 250+ clients from offices in Kolkata (head office), Delhi and Bengaluru. Every SEZ registration starts with a Chartered Accountant reading the Letter of Approval.
- The authorised-operations list drives everything. We map it to your procurement so suppliers know what they can zero-rate and you are not arguing about it after the invoice.
- The endorsement routine set up from month one, because that is what decides whether refunds arrive.
- Fixed fee of ₹1,499 for the registration, with no government fee to add.
- One team afterwards: the annual LUT, the refund claims, the monthly GST returns, the books and any GST notice.
Not sure which of your incoming supplies count as authorised operations? Send us your Letter of Approval and the authorised-operations list, and a CA will map them to your procurement.