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    GST Refund for SEZ Units in India

    Reviewed by CA & CS Team · Patron Accounting LLP ICAI & ICSI Registered| 15+ Years Experience| Last Updated: 11 May 2026 Verify Credentials →

    Documents: Letter of Approval, LUT, GSTIN, specified-officer endorsement, GSTR-1 Table 6B, BRC for outbound exports.

    Fees: SEZ refund filing starts at Rs 11,999 plus GST per claim cycle (single tax period, up to 25 invoices).

    Eligibility: SEZ unit, SEZ developer, or DTA supplier making zero-rated supplies for authorised operations under Section 16 IGST Act.

    Timeline: Provisional 90 percent refund within 7 days under Section 54(6); final order within 60 days.

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      Join 10,000+ Satisfied Businesses

      From DTA suppliers to IT/ITES, biotech, manufacturing, and service-sector SEZ units, we handle monthly RFD-01 cycles, DSPF endorsement, and refund rejection appeals across India.

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      Overview

      📌 TL;DR - GST Refund for SEZ Units Services at a Glance

      Supplies of goods or services to a SEZ unit or SEZ developer for authorised operations are zero-rated under Section 16 of the IGST Act 2017. Either the DTA supplier or the SEZ unit can claim refund through Form GST RFD-01 - the supplier under LUT (refund of accumulated ITC) or with payment of IGST (refund of tax paid). Endorsement by the specified officer under Rule 30 of SEZ Rules 2006 is mandatory for service supplies from 1 October 2023.

      Quick ReferenceDetails
      Governing ActsIGST Act 2017 (Section 16), CGST Act 2017 (Section 54), SEZ Act 2005 (Section 26), SEZ Rules 2006 (Rule 30)
      Applicable ToSEZ units, SEZ developers, and DTA suppliers making zero-rated supplies for authorised operations
      Refund RoutesLUT route (Rule 89, accumulated ITC) or IGST-paid route (Section 54, tax paid)
      Patron FeesStarting Rs 11,999 per refund cycle plus GST; LUT filing Rs 4,999
      Penalty for Non-EndorsementRefund rejection plus deficiency memo under Rule 90; ITC reversal exposure for supplier
      Form / PortalForm GST RFD-01 on gst.gov.in plus DSPF on SEZ Online (NDML)
      AuthorityJurisdictional GST Refund Officer plus Specified Officer of the SEZ under SEZ Rules 2006

      GST refund for SEZ units is the recovery of accumulated input tax credit or integrated tax paid on transactions that qualify as zero-rated supply under Section 16 of the IGST Act 2017 read with Section 26 of the SEZ Act 2005. The refund flows through Form GST RFD-01 on the GST portal and is filed either by the DTA supplier of goods or services or by the SEZ unit or developer that received them. Two parallel routes apply: zero-rated supply under a Letter of Undertaking with refund of accumulated ITC, or zero-rated supply on payment of IGST with refund of the tax paid.

      Patron Accounting LLP has filed monthly SEZ refund cycles for IT/ITES, biotech, manufacturing, and service-sector SEZ units across Pune, Mumbai, Delhi, and Gurugram since the GST rollout on 1 July 2017. Our CA and CS team handles LUT renewals, specified-officer endorsement via DSPF, monthly RFD-01 cycles, Rule 89(2)(f) declarations, and RFD-06 follow-up.

      Content is reviewed quarterly for accuracy.

      What Is GST Refund for SEZ Units?

      GST refund for SEZ units is the statutory recovery of unutilised input tax credit or integrated tax paid on supplies treated as zero-rated under the GST regime when made to a Special Economic Zone unit or developer. The legal basis is Section 16 of the IGST Act 2017, which classifies any supply of goods or services to an SEZ unit or developer for authorised operations as a zero-rated supply, alongside physical exports out of India.

      Procedural mechanics are anchored in Section 54 of the CGST Act 2017 and Rule 89 of the CGST Rules 2017, while the SEZ-side conditions flow from Section 26 of the SEZ Act 2005 and Rule 30 of the SEZ Rules 2006. Section 16(1)(b) was amended by the Finance Act 2021 to add the qualifier 'for authorised operations', operationalised through Notification 1/2023-Integrated Tax with effect from 1 October 2023.

      The framework applies to two distinct actors. The DTA supplier sells goods or services to a SEZ unit and recovers either accumulated ITC (under LUT) or IGST paid. The SEZ unit itself files refund where it has paid IGST that should have been zero-rated, or where it has accumulated ITC on its own export operations from the Zone.

      Key Terms for GST Refund for SEZ Units:

      • SEZ Unit / Developer: An entity holding a Letter of Approval under the SEZ Act 2005 to operate within or to develop a notified Special Economic Zone.
      • Authorised Operations: Operations approved under Section 4(2) and Section 15(9) of the SEZ Act 2005 - added to Section 16 IGST Act with effect from 1 October 2023.
      • Zero-Rated Supply: Supply on which GST is charged at 0 percent but full ITC remains available, defined under Section 16(1) IGST Act.
      • LUT (Form RFD-11): Letter of Undertaking under Rule 96A allowing zero-rated supply without IGST payment; valid for one financial year.
      • Rule 89(2)(e): Statement requirement under CGST Rules - invoice statement plus evidence of endorsement by specified officer for SEZ goods or services supplies.
      • Rule 89(2)(f): Declaration that the SEZ unit or SEZ developer has not availed input tax credit of the tax paid by the supplier.
      • Specified Officer / Authorised Officer: Officer defined under Rule 2 of SEZ Rules 2006 who endorses receipt of goods or services for authorised operations.
      • DSPF: DTA Service Procurement Form - online module on SEZ Online (NDML) operational from October 2019 for service-invoice endorsement.
      APL-05 GST Refund for SEZ Units
      Zero-Rated Supply Section 16 IGST Act

      Who Needs SEZ GST Refund Services?

      The service applies to two distinct actors under the same zero-rated framework. The DTA supplier sells goods or services to a SEZ unit and recovers either accumulated ITC (under LUT) or IGST paid. The SEZ unit itself files refund where it has paid IGST that should have been zero-rated, or where it has accumulated ITC on its own export operations.

      • DTA suppliers of goods or services to any SEZ unit or developer for authorised operations.
      • SEZ units exporting finished goods or services and accumulating ITC on inputs and input services.
      • SEZ developers procuring construction materials, plant, and services from DTA suppliers under Section 26 SEZ Act.
      • IT and ITES SEZ units with high input service ITC (telecom, software licences, professional services).
      • Biotech, pharma, and engineering SEZ units with high input goods ITC and capital-goods purchases.
      • Free Trade Warehousing Zone (FTWZ) operators where the FTWZ is located within a notified SEZ.

      Threshold and pre-condition: separate GSTIN registration is mandatory for the SEZ unit even if the same legal entity also operates in DTA in the same state, as required by Rule 8 of the CGST Rules 2017 read with the proviso to Section 25(2) of the CGST Act. If the unit has not yet registered, complete GST registration before the first inward or outward supply. The unit must also maintain LUT validity in Form GST RFD-11 for every financial year to avoid IGST cash outflow on outward supplies.

      Patron Accounting Services for SEZ Stakeholders

      ServiceWhat We Do
      LUT Filing (Form RFD-11)Annual LUT preparation for DTA suppliers and SEZ units, witness arrangement, online furnishing on gst.gov.in. Included
      DTA-Supplier Refund (LUT Route)RFD-01 filing under Rule 89 with Statement 4 reconciliation; specified-officer endorsement coordination through DSPF. Included
      DTA-Supplier Refund (IGST Paid)Refund of IGST paid on SEZ supplies under Section 54; reconciliation with GSTR-1 Table 6B and GSTR-3B Table 3.1(b). Included
      SEZ Unit Outbound RefundRefund of accumulated ITC where the SEZ unit exports goods or services from the Zone under LUT. Included
      Specified-Officer EndorsementEnd-to-end DSPF coordination, LoA mapping, authorised-operations matching, follow-ups with DC office. Included
      Monthly Refund Cycle SetupProcess map, ERP tagging, internal SLA between operations and finance, quarterly retainer with deficiency-memo handling. Add-on
      Rule 89(2)(f) DeclarationAnnexure I declaration drafted and routed to SEZ unit director or authorised signatory for sign-off. Included
      Deficiency Memo (RFD-03) HandlingDrafting of replies to deficiency memos with document re-submission and officer co-ordination. Included
      Our Process

      Step-by-Step SEZ Refund Procedure (8 Steps)

      The SEZ refund pipeline runs through eight sequential steps. Each step is anchored to a specific section, rule, or notification under Indian law.

      Step 1

      Confirm LoA and LUT Validity

      Confirm SEZ unit Letter of Approval and LUT validity: LoA from the Development Commissioner under Section 15 SEZ Act 2005, and LUT in Form GST RFD-11 valid for the current financial year per Rule 96A CGST Rules.

      LoA under Section 15 SEZ Act 2005LUT validity under Rule 96A
      LoA + LUT Active 01
      Step 2

      Choose Route - LUT vs IGST-Paid

      Choose route: zero-rated supply under LUT (no IGST upfront, refund accumulated ITC) or zero-rated supply with payment of IGST (claim refund of tax paid). Both options flow from Section 16(3) IGST Act.

      Section 16(3) IGST Act dual routeWorking capital optimisation
      LUTIGSTRFD-01
      Route Selected 02
      Step 3

      Issue Invoice with SEZ Declaration

      Issue tax invoice with SEZ declaration: 'SUPPLY MEANT FOR SEZ UNIT OR SEZ DEVELOPER FOR AUTHORISED OPERATIONS UNDER LUT WITHOUT PAYMENT OF IGST' or the 'with payment' equivalent, per Rule 46 CGST Rules.

      Rule 46 SEZ invoice declarationAuthorised operations tagged
      SEZ AUTHORISED OPS
      Invoice Issued 03
      Step 4

      Obtain Specified-Officer Endorsement

      For goods, the SEZ Online entry plus Bill of Entry endorsement; for services, the DSPF flow on SEZ Online from 1 October 2023 onwards under Rule 30(4) SEZ Rules 2006 read with the second proviso to Rule 89(1) CGST Rules.

      Rule 30(4) SEZ Rules endorsementDSPF service approval
      DSPF
      DSPF Endorsed 04
      Step 5

      File GSTR-1 Table 6B and GSTR-3B

      File GSTR-1 reflecting SEZ supplies in Table 6B (NOT Table 6A which is for exports outside India); file GSTR-3B with Table 3.1(b) for zero-rated outward supplies per Rule 89(2)(g) CGST Rules.

      GSTR-1 Table 6B reportingGSTR-3B Table 3.1(b) match
      Table 6B
      Returns Filed 05
      Step 6

      Submit Form GST RFD-01

      Submit Form GST RFD-01 on gst.gov.in selecting the correct refund category: 'on account of supplies made to SEZ unit or SEZ developer (without payment of tax)' for the LUT route, or 'with payment of tax' for the IGST-paid route.

      RFD-01 portal submissionCorrect refund category selected
      RFD-01
      RFD-01 Filed 06
      Step 7

      Attach Route-Specific Statements

      Attach the route-specific statements and declarations: Statement 4 with invoice details for the LUT route; Statement 5 plus shipping bill or BoE for the IGST-paid route. Furnish the Rule 89(2)(f) declaration that the SEZ unit has not availed ITC of the tax paid.

      Statement 4 or Statement 5Rule 89(2)(f) declaration
      Stmt 4Stmt 5
      Statements Attached 07
      Step 8

      Receive Provisional 90 Percent Refund

      Receive provisional 90 percent refund within 7 days of Acknowledgement RFD-02 and the balance after document scrutiny. From October 2025, CBIC Instruction 6/2025 extended the 90 percent provisional refund mechanism to all eligible refund categories per Section 54(6) CGST Act and Rule 91 CGST Rules.

      Section 54(6) provisional refundCBIC Instruction 6/2025 coverage
      ₹90% in 7 days
      Refund Received 08

      Document Checklist for SEZ GST Refund

      Keep the following documents ready before filing each RFD-01 cycle. Patron Accounting maintains a digital document vault per client to ensure nothing slips between refund cycles.

      • Separate GSTIN certificate for the SEZ unit (or DTA-side GSTIN of the supplier).
      • Letter of Approval from Development Commissioner with current validity.
      • Active LUT acknowledgement in Form GST RFD-11 for the financial year.
      • Tax invoice carrying SEZ declaration as required by Rule 46 CGST Rules.
      • Specified-officer endorsement - SEZ Online goods entry or DSPF service approval.
      • Bill of Entry or shipping bill where applicable.
      • BRC or e-BRC for outbound exports from the SEZ realised within the FEMA window.
      • Importer-Exporter Code certificate where the SEZ unit imports directly. New units can complete IEC registration before the first import.
      • GSTR-1 (Table 6B for SEZ supplies) plus GSTR-3B (Table 3.1(b)) for the refund period.
      • Rule 89(2)(f) declaration that the SEZ unit has not availed ITC of the tax paid.
      • CA certificate in Annexure 2 of RFD-01 where the refund amount exceeds Rs 2 lakh.

      Common Challenges and How We Solve Them

      ChallengeImpactHow Patron Accounting Solves It
      Specified-officer endorsement delay on DSPFWe pre-fill DSPF with LUT number, invoice payment trail, and authorised-operations mapping; coordinate weekly with DC office and chase queries within 24 hours.
      Refund rejected because GSTR-1 used Table 6A instead of Table 6BWe reconcile every SEZ invoice and shift the reporting to Table 6B via GSTR-1 amendment in the next return period; refile RFD-01 within the 2-year Section 54(1) window.
      Authorised-operations mismatch flagged by SEZ officerWe map every service line to the SEZ unit's approved list of services in the LoA and obtain a one-time clarification letter from the DC office if needed.
      Rule 89(2)(f) declaration rejected as not signed by SEZ unitWe arrange a fresh declaration on the SEZ unit's letterhead with director or authorised signatory sign-off, attached as Annexure I to RFD-01.
      SEZ unit and DTA unit treated as one GSTINWe split the registration under Rule 8 CGST Rules with the proviso to Section 25(2); the SEZ vertical becomes a distinct GSTIN, separate returns, separate LUT, separate refund applications.

      Fees for SEZ GST Refund Services

      Fee ComponentAmount
      Government Fee (RFD-01 filing)Nil (no statutory portal fee)
      Patron Accounting Professional Fees - GST RefundStarting from INR 4,999 (Exl GST and Govt. Charges)
      LUT Filing (Form RFD-11)Rs 4,999 plus GST (annual, valid for one financial year)
      Single SEZ Refund Cycle (RFD-01)Rs 11,999 plus GST (up to 25 invoices, single tax period)
      Bulk SEZ Refund (multi-month)Rs 27,999 plus GST (up to 100 invoices, three-month window)
      Monthly RetainerRs 24,999 plus GST per month (unlimited invoices, deficiency memo handling, DSPF coordination)
      Annual SEZ Refund RetainerRs 1,99,999 plus GST (12-month coverage, both routes, full DSPF coordination)
      DSPF Endorsement Standalone SupportRs 9,999 plus GST per quarter (endorsement-only mandate without refund filing)
      All fees and charges listed are indicative only and do not constitute a binding offer. Final amounts may vary depending on the volume of work and the complexity involved. Government fees are payable separately at actuals.

      All fees and charges listed are indicative only and do not constitute a binding offer. Final amounts may vary depending on the volume of work and the complexity involved.

      Professional service charges for drafting, filing, and representation are separate from the statutory fees. The exact fee depends on the complexity of the case, disputed amount, and number of hearings required. Contact us for a detailed quote.

      Get a free GST Refund for SEZ Units consultation - Call +91 945 945 6700 or WhatsApp us. No-obligation assessment.

      How Long the SEZ Refund Takes

      StageEstimated Timeline
      Provisional refund (90%)7 days from RFD-02 acknowledgementSection 54(6) plus Rule 91
      Document scrutiny by officer15 to 30 daysSection 54(7)
      Final order in RFD-0660 days from RFD-01 filingSection 54(7) statutory ceiling
      Interest on delay6 percent per annum from 61st daySection 56 CGST Act
      Specified-officer DSPF endorsement5 to 15 days post-submissionSEZ Rule 30 read with DSPF SOP
      Monthly cycle steady-state30 to 45 days end-to-endOnce process is stabilised
      Working capital tip: Once your monthly refund cycle is stabilised, Section 54(6) provisional refund of 90 percent lands within 7 days of RFD-02 acknowledgement - usually under 10 days from filing. The remaining 10 percent follows the final RFD-06 order within 60 days. This is the single biggest cash-flow benefit DTA suppliers and SEZ units get from professional refund management.
      Key Benefits

      Benefits of Engaging Patron Accounting

      Working Capital in 7 Days

      Working capital recovered within 7 days through provisional 90 percent refund mechanism under Section 54(6) and Rule 91 CGST Rules. CBIC Instruction 6/2025 makes this standard for SEZ refunds from October 2025.

      DSPF Endorsement Compressed

      Specified-officer endorsement turnaround compressed by 30 to 60 percent through DSPF pre-fill and follow-up SOPs. We chase DC office queries within 24 hours and keep the LoA-to-invoice mapping current.

      Table 6B Reconciliation

      Risk of refund rejection cut sharply by reconciling GSTR-1 Table 6B with GSTR-3B Table 3.1(b) at invoice level. Common Table 6A error eliminated. Every SEZ invoice tagged at the source.

      Section 16(1)(b) Compliance

      Direct access to a CA-led team experienced in handling the Section 16(1)(b) amendment effective 1 October 2023 - the authorised-operations gate that now governs every SEZ supply refund.

      CA-Certified Annexure 2

      Refunds above Rs 2 lakh require CA certificate in Annexure 2 of RFD-01. Our in-house CA team signs the certificate at no additional cost on retainer arrangements - eliminating a common bottleneck.

      Deficiency Memo Handling

      RFD-03 deficiency memos handled within 7 days of receipt - drafting replies, gathering documents, co-ordinating with the refund officer, and preventing rejection orders that block working capital indefinitely.

      Why Indian SEZ Units Trust Us

      10,000+ Businesses Served | 4.9 Google Rating | 50,000+ Documents Filed | 15+ Years Experience

      Outcome proof: A Bengaluru-based IT/ITES SEZ unit recovered Rs 5.7 crore across 14 monthly refund cycles between FY 2024-25 and FY 2025-26 through the LUT route, with provisional 90 percent refund hitting within 8 days each cycle. Total deficiency memos in 14 cycles - one (resolved within 5 days).

      Trusted by Hyundai, Asian Paints, Bridgestone, and growing SEZ units across India. With offices in Pune, Mumbai, Delhi, and Gurugram, Patron Accounting serves businesses across India both in-person and remotely.

      Comparison - LUT Route vs IGST-Paid Route for SEZ Supplies

      ParameterRoute A - LUT (without IGST)Route B - IGST-Paid
      Trigger EventDTA supplier or SEZ unit makes zero-rated supply under LUT without paying IGSTDTA supplier or SEZ unit makes zero-rated supply on payment of IGST
      Working Capital ImpactBest - no IGST outflow upfrontHigher - IGST funded for 7 to 60 days until refund
      Statement FiledStatement 4 (LUT-based supplies)Statement 5 (with payment of tax)
      RFD-01 CategoryRefund on account of supplies made to SEZ unit or developer (without payment of tax)Refund on account of supplies made to SEZ unit or developer (with payment of tax)
      Refund QuantumAccumulated unutilised ITC computed under Rule 89(4) formulaFull IGST paid on the SEZ invoice
      Provisional 90 percentWithin 7 days under Section 54(6)Within 7 days under Section 54(6)
      Endorsement RequiredYes - specified officer under Rule 30 SEZ Rules and second proviso to Rule 89(1)Yes - specified officer under Rule 30 SEZ Rules and second proviso to Rule 89(1)
      Best ForSteady-state DTA suppliers with high input ITC accumulationSuppliers with low ITC accumulation or cash-flow tolerance

      Partner Services for SEZ Stakeholders

      SEZ refund work rarely sits in isolation. Most SEZ units and DTA suppliers need adjacent compliance running in parallel:

      Legal and Compliance Framework (India)

      Under Section 16 of the IGST Act 2017, supply of goods or services to a SEZ unit or developer for authorised operations is a zero-rated supply, with refund available either as IGST paid on outward supply or as accumulated ITC under LUT in line with Section 16(3). Section 16(1)(b) was amended by the Finance Act 2021 to add the qualifier 'for authorised operations', operationalised through Notification 1/2023-Integrated Tax dated 31 July 2023 with effect from 1 October 2023.

      Section 26 of the SEZ Act 2005 grants SEZ units and developers exemption from any duties or taxes on goods or services procured from DTA for authorised operations. Rule 30 of the SEZ Rules 2006 prescribes the procedural framework for such procurement and the endorsement obligation. Rule 30(4) requires the specified officer to endorse the receipt of goods or services for authorised operations, which becomes documentary proof for the refund applicant.

      Section 54 of the CGST Act 2017 read with Rule 89 of the CGST Rules 2017 prescribes the refund machinery, including the 2-year limitation period from the relevant date. The second proviso to Rule 89(1) names the supplier of goods (after admission to SEZ) and the supplier of services (with endorsement evidence) as the persons who file the refund. Rule 89(2)(e) prescribes the invoice statement and endorsement evidence to be enclosed; Rule 89(2)(f) prescribes the declaration that the SEZ unit has not availed ITC of the tax paid by the supplier.

      Penalty exposure: refund rejection plus deficiency memo under Rule 90 where endorsement, declaration, or reconciliation is incomplete. Where IGST has wrongly been collected on a supply that should have been zero-rated, the supplier may be exposed to ITC reversal under Section 17 read with Rule 42, plus interest under Section 50 CGST Act. Recipient SEZ unit's failure to use procured goods or services for authorised operations may invite enforcement under Section 11 SEZ Act 2005 plus refund recovery under Section 73 or Section 74 CGST Act.

      Government references: CBIC GST portal, indiacode.nic.in (IGST Act, CGST Act, SEZ Act), SEZ Online (NDML) DSPF portal, and GST portal SEZ refund user guide.

      What is zero-rated supply to a SEZ unit?

      Under Section 16 of the IGST Act 2017, supply of goods or services to a Special Economic Zone unit or developer for authorised operations is treated as a zero-rated supply alongside physical exports out of India. The supplier charges no GST when exporting under a Letter of Undertaking, or pays IGST and claims refund. From 1 October 2023, Section 16(1)(b) requires that the supply be for authorised operations as defined under Section 2(c) of the SEZ Act 2005.

      Who can claim GST refund - the SEZ unit or the DTA supplier?

      Either party can claim under Form GST RFD-01, but never both for the same invoice. Where the supplier files, the second proviso to Rule 89(1) requires endorsement by the specified officer of the SEZ confirming receipt of goods or services for authorised operations. The SEZ unit must also furnish a declaration under Rule 89(2)(f) that it has not availed ITC of the tax paid by the supplier.

      SEZ ka GST refund kaise milega? (Hinglish)

      Do raaste hain: pehla, LUT file karke bina IGST diye SEZ ko supply karna aur Rule 89 ke under accumulated ITC ka refund Form RFD-01 me Statement 4 ke saath claim karna; doosra, IGST pay karke SEZ ko supply karna aur tax paid ka refund Statement 5 ke saath claim karna. Specified officer ka endorsement aur Rule 89(2)(f) ki declaration dono cases me zaroori hai. GSTR-1 Table 6B me reporting karna hai, Table 6A me nahi.

      Is endorsement by the specified officer mandatory?

      Yes - the second proviso to Rule 89(1) read with Rule 30 of the SEZ Rules 2006 requires endorsement evidence from the specified officer for both goods and services supplies to a SEZ. For services, the endorsement is operationalised through the DTA Service Procurement Form on the SEZ Online portal from October 2019. Per the Madras High Court ruling, endorsement was not mandated under GST law for goods supplies up to 30 September 2023; it is mandatory thereafter.

      What is Rule 89(2)(f) of the CGST Rules?

      Rule 89(2)(f) of the CGST Rules 2017 requires the refund applicant who supplies to a SEZ unit or developer to furnish a declaration that the SEZ unit or developer has not availed input tax credit of the tax paid by the supplier. Without this declaration in the prescribed form, the refund application is liable to deficiency memo under Rule 90 of the CGST Rules. The declaration is filed as part of Annexure I of Form GST RFD-01.

      Can a SEZ supplier file refund every month?

      Yes. Form GST RFD-01 can be filed monthly so long as the supplier has filed GSTR-1 and GSTR-3B for the relevant period and possesses specified-officer endorsement and the Rule 89(2)(f) declaration. A monthly cycle is the working-capital optimal route for IT, pharma, and engineering DTA suppliers with high ITC accumulation. From October 2025, CBIC Instruction 6/2025 makes 90 percent provisional refund available within 7 days for eligible SEZ refund claims.

      Where in GSTR-1 are SEZ supplies reported?

      SEZ supplies are reported in Table 6B of GSTR-1, separately for 'with payment of IGST' and 'without payment of tax (LUT)' categories. Reporting in Table 6A is reserved for exports outside India and is a common error that causes refund rejection. The amount in Table 6B must match the zero-rated outward supply figure in Table 3.1(b) of GSTR-3B for the same period.

      Does an SEZ unit need separate GST registration from its DTA operations?

      Yes. Rule 8 of the CGST Rules 2017 read with the proviso to Section 25(2) of the CGST Act mandates that an SEZ unit be treated as a distinct vertical from any DTA unit of the same legal entity in the same state. Two separate GSTINs are therefore required, with separate returns, separate LUTs, and separate refund applications. Failure to register separately causes registration cancellation risk under Section 29 CGST Act.

      What is the difference between SEZ refund and EOU refund?

      An SEZ is deemed outside customs territory; supplies into an SEZ from DTA are zero-rated under Section 16 IGST Act. An EOU operates within Indian customs territory; supplies from DTA to an EOU are deemed exports under Section 147 CGST Act and Notification 48/2017-CT. SEZ refunds use Statement 4 or Statement 5; EOU deemed-export refunds use Statement 5B with supplier-or-recipient option.

      Specified officer endorsement DSPF kya hai aur kaise milta hai? (Hinglish)

      DSPF matlab DTA Service Procurement Form, jo October 2019 se SEZ Online (NDML) portal par activate hai. SEZ unit isme service invoices upload karta hai, payment proof aur LUT number lagata hai. Phir Authorised Officer ya Specified Officer review karke approve karta hai aur DTA supplier ko email me acknowledgement bhejta hai jo refund claim ke liye proof ban jaata hai.

      Quick Answers

      • Which Section makes SEZ supplies zero-rated? Section 16(1)(b) of the IGST Act 2017.
      • Which form is used for SEZ refund? Form GST RFD-01 filed online on gst.gov.in.
      • Where do I report SEZ supplies in GSTR-1? Table 6B (NOT Table 6A which is for exports outside India).
      • What is the time limit for SEZ refund? 2 years from the relevant date under Section 54(1) CGST Act.
      • Who endorses SEZ supplies? The Specified Officer or Authorised Officer of the SEZ under Rule 30 of SEZ Rules 2006.
      • From which date is endorsement mandatory for services? 1 October 2023 (Notification 1/2023-IT dated 31 July 2023).
      • Can refund be filed monthly? Yes - monthly is the optimal cycle for steady-state SEZ suppliers.
      • Provisional refund percentage? 90 percent under Section 54(6) within 7 days of RFD-02 acknowledgement.

      Three Clocks Are Running - Do Not Miss Them

      Three statutory clocks run together for every SEZ supply:

      1. 2-year refund limitation under Section 54(1) of the CGST Act 2017, counted from the relevant date. Once the window closes, your accumulated ITC or IGST paid is gone.
      2. Annual LUT validity under Rule 96A - every financial year. Miss the renewal and the next supply attracts upfront IGST, blocking working capital until the Section 54 route refund processes.
      3. 45-day endorsement window under SEZ Rules 2006 read with the second proviso to Rule 89(1). Without specified-officer endorsement, the refund is liable to deficiency memo under Rule 90 and may be rejected outright.

      Past these points, refund eligibility lapses or processing stalls indefinitely. Patron Accounting tracks all three clocks for every retainer client.

      Get your SEZ refund cycle set up today - Call +91 945 945 6700 or WhatsApp us. Free 15-minute eligibility call.

      Recover Every Rupee of SEZ Supply ITC

      GST refund for SEZ units is the difference between recovering working capital monthly and watching it pile up across quarters. Section 16 of the IGST Act, Section 26 of the SEZ Act 2005, and Rule 89 of the CGST Rules together set up a zero-rated framework that rewards meticulous reconciliation across GSTR-1 Table 6B, GSTR-3B Table 3.1(b), specified-officer endorsement, and the Rule 89(2)(f) declaration.

      Patron Accounting LLP's CA and CS team handles the end-to-end SEZ refund stack - LUT renewal, DSPF coordination, monthly RFD-01 filing, and RFD-06 follow-up. With offices in Pune, Mumbai, Delhi, and Gurugram and a national client base of 10,000-plus businesses, we are equipped to manage refund cycles for SEZ units and DTA suppliers of every size from single-GSTIN operators to multi-zone enterprises.

      Book a Free Consultation - No Obligation.

      Adjacent Services You May Need

      Most SEZ units and DTA suppliers run these services in parallel with the monthly refund cycle. End-to-end CA support across all of them.

      Content Created: 8 May 2026  |  Last Updated: 11 May 2026  |  Next Review: 8 August 2026  |  Reviewed By: CA & CS Team · Patron Accounting LLP

      This page is reviewed every quarter (Tier 1 freshness - GST keyword class). Review triggers include GST Council decisions, CBIC notifications affecting Rule 89 and Section 54, SEZ Act or SEZ Rules amendments, DSPF workflow changes on SEZ Online, and new High Court rulings on endorsement requirement.