Gujarat GST Advance Ruling on SEZ Invoice Endorsement Requirements
The Authority for Advance Ruling declined to decide if SEZ invoice endorsements are mandatory, stating the question falls outside its legal jurisdiction.
- Ruling
- ADVANCE RULING NO. GUJ/GAAR/R/2026/19, dated 08.05.2026
- Dated
- 08 May 2026
- Authority
- Authority for Advance Ruling
This page was written by Patron Accounting’s AI from the official release and reviewed before publishing. It explains the document in plain language. It is not the document itself. Where this page and the original differ, the original governs.
The short version
- Waystar Properties LLP asked if SEZ invoice endorsements are mandatory for zero-rated supplies.
- The Authority for Advance Ruling refused to answer the questions.
- The ruling states these procedural evidence issues are not covered by Section 97(2).
In short
The company asked the Gujarat Authority for Advance Ruling (AAR) if they must get a government official to sign every invoice for services provided to Special Economic Zone (SEZ) units. They wanted to know if other documents, like a Letter of Approval, could prove the services were for authorized operations instead. The AAR did not answer this, deciding that questions about what evidence is sufficient for a tax claim are not the type of questions they are legally allowed to answer.
What has changed
How it worked before
Businesses were uncertain whether they could rely on general approval documents or if they strictly needed a physical endorsement on every invoice to claim zero-rated supply status.
What has changed
Nothing changed because the Authority refused to rule on the matter. This means there is still no official guidance from this forum on whether invoice endorsements are mandatory for SEZ transactions.
Who this affects
Businesses operating in or providing services to Special Economic Zones who are unsure about the documentation required to claim zero-rated GST status.
An example
Imagine a software firm in Bangalore providing services to an SEZ unit. They might wonder if they need an official stamp on every invoice to avoid paying GST. This ruling shows that the AAR will not answer that question, so the firm must rely on their own interpretation of the law or professional advice rather than waiting for an AAR decision.
What you should do
Do not assume this ruling provides an answer to your documentation questions. Because the Authority declined to rule, you must consult your own tax advisor to determine the safest documentation practice for your specific SEZ transactions. Remember that an advance ruling only binds the business that asked it and their specific tax officer, so it cannot be used as a legal shield for your own business.
If you do nothing
If you assume this ruling allows you to skip invoice endorsements, you risk a tax officer rejecting your zero-rated supply claim during an audit. This could lead to demands for unpaid tax, interest, and penalties. Relying on an inapplicable or non-existent ruling does not protect you from these consequences.
The terms explained
- Zero-rated supply
- A supply of goods or services that is taxed at a zero percent GST rate, allowing the business to claim a refund for taxes paid on inputs.
- Special Economic Zone (SEZ)
- A specific area designated by the government where businesses enjoy special tax and trade benefits to encourage exports.
- Advance Ruling
- A formal decision provided by tax authorities to a business regarding the tax treatment of a specific transaction.
The ruling in detail
Authority for Advance Ruling
Waystar Properties LLP
ADVANCE RULING NO. GUJ/GAAR/R/2026/19, dated 08.05.2026 · Gujarat
Questions before the authority
- Whether for availing zero-rated supply treatment u/s 16 of IGST Act, 2017 read with Notification No. 09/2017-Integrated Tax (Rate) dated 28.06.2017, as amended w.e.f. 01.10.2023, for services supplied from Domestic Tariff Area (DTA) to Special Economic Zone (SEZ) units/developers, the phrase 'for authorized operations' can be established through documentary evidence including Letter of Approval (LOA) / Eligibility Certificate issued by SEZ authorities demonstrating that the service relates to authorised operations; or whether endorsement from the Specified Officer of SEZ on each invoice is mandatorily required irrespective of other documentary evidence available (Letter of Approval (LOA) / Eligibility Certificate) to prove that the service is supplied for 'authorized operations'?
- Whether the supply of services, from one SEZ unit to another SEZ unit (both located within SEZ and not in DTA) qualifies as a zero-rated supply u/s 16 of IGST Act, 2017, and if yes, whether endorsement from the Specified Officer of SEZ is mandatory on each invoice for such intra-SEZ transactions, or whether the Letter of Approval (LOA) / Eligibility certificate establishing that both parties are SEZ units engaged in authorized operations would be sufficient as documentary evidence?
- Whether Letter of Approval (LOA) / Eligibility certificate as documentary evidence would be acceptable to establish that such services are supplied for authorized operations and such intra-SEZ supplies would still qualify for zero-rated treatment under GST law in the absence of invoice endorsement?
Facts
The applicant is a Co-Developer in the GIFT SEZ and leases commercial premises to SEZ units. They sought clarity on whether endorsement by the Specified Officer of SEZ on invoices is a mandatory pre-condition for claiming zero-rated supply status under Section 16 of the IGST Act, 2017, for both DTA-to-SEZ and intra-SEZ transactions. The applicant argued that such endorsement is not feasible for intra-SEZ transactions and that alternative documentary evidence like the Letter of Approval should suffice.
Ruling
| Question | What the authority ruled |
|---|---|
| Documentary requirements for DTA to SEZ supplies | Refrained from answering Question deemed outside the scope of Section 97(2) of the CGST Act |
| Zero-rating and endorsement for intra-SEZ supplies | Refrained from answering Question deemed outside the scope of Section 97(2) of the CGST Act |
| Acceptability of alternative evidence for intra-SEZ supplies | Refrained from answering Question deemed outside the scope of Section 97(2) of the CGST Act |
The Authority for Advance Ruling **refrained from answering** all three questions raised by the applicant. It concluded that the questions did not fall within the scope of matters on which an advance ruling can be sought under Section 97(2) of the CGST Act, 2017. Consequently, no substantive ruling was provided on the merits of the documentary requirements.
Reasoning
The Authority examined the questions against the provisions of Section 97(2) of the CGST Act, 2017, which lists the specific matters for which an advance ruling can be sought. It determined that the applicant's queries regarding the sufficiency of documentary evidence for zero-rated supplies did not relate to classification, applicability of notifications, determination of time/value of supply, admissibility of input tax credit, or other specified categories. Therefore, the Authority concluded it lacked the jurisdiction to provide a ruling on these procedural evidentiary issues.
Provisions relied on
- Section 97 of the CGST Act, 2017
- Section 16 of the IGST Act, 2017
- Notification No. 09/2017-Integrated Tax (Rate) dated 28.06.2017
For the practitioner
This order is **not a precedent** on the merits of SEZ invoice endorsement requirements, as the Authority declined to answer the questions. It serves as a reminder that the AAR forum is strictly limited to the specific categories of questions enumerated in Section 97(2) of the CGST Act. Practitioners should note that procedural evidentiary disputes may be considered outside the scope of advance rulings.
Source
This is a summary prepared from the published order, which is a scanned document. It is a reading aid and not the authority: where the two differ, the order governs. Verify every provision against the original before relying on it.
Original order: https://www.gstcouncil.gov.in/sites/default/files/AAR/5-waystar_properties_llp_0001_compressed_1_compressed.pdf
Legibility of the scan, as read: high.
Prepared 11-10-2026.
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