AAR Rules Intra-SEZ Supplies, GST Zero-Rating and Endorsement Issues Outside Its Jurisdiction [Read Order]
The dispute arose after the applicant claimed that SEZ authorities were refusing to endorse invoices for supplies made from one SEZ entity to another SEZ entity
![AAR Rules Intra-SEZ Supplies, GST Zero-Rating and Endorsement Issues Outside Its Jurisdiction [Read Order]](https://images.taxscan.in/h-upload/2026/05/20/2137537-aar-rules-intra-sez-supplies-gst-zero-rating-endorsement-issues-jurisdiction-taxscan.webp "AAR Rules Intra-SEZ Supplies, GST Zero-Rating and Endorsement Issues Outside Its Jurisdiction [Read Order]")
The Gujarat Authority for Advance Ruling (AAR) recently declined to adjudicate questions relating to zero-rated treatment of supplies between Special Economic Zones (SEZ) and invoice endorsement requirements for the same under the Goods andServices Tax (GST) regime. The AAR held that such issues fall outside the scope of its jurisdiction under Section 97 of the Central Goods and...
The Gujarat Authority for Advance Ruling (AAR) recently declined to adjudicate questions relating to zero-rated treatment of supplies between Special Economic Zones (SEZ) and invoice endorsement requirements for the same under the Goods andServices Tax (GST) regime. The AAR held that such issues fall outside the scope of its jurisdiction under Section 97 of the Central Goods and Services Tax (CGST) Act, 2017.
The applicant M/s Waystar Properties LLP (Waystar), is a co-developer of infrastructure for the Gujarat International Finance Tec-City Special Economic Zone (GIFT SEZ), Gandhinagar.
Waystar stated that it leases commercial premises situated within the processing area of GIFT SEZ to other SEZ units for carrying out authorized operations approved under the Special Economic Zones Act, 2005. It was the case of the applicant that such intra-SEZ supplies are treated as inter-State supplies under Section 7(5)(b) of the IGST Act and thus qualify as zero-rated supplies under Section 16(1)(b) of the IGST Act.
The applicant contended before the AAR that SEZ authorities were refusing to endorse invoices for supplies made from one SEZ entity to another SEZ entity, stating that endorsement procedures under Rule 30 of the SEZ Rules, 2006 were applicable only for Domestic Tariff Area (DTA) to SEZ supplies and not for intra-SEZ transactions.
Accordingly, the applicant sought advance rulings on whether Letter of Approval (LOA), eligibility certificates, contracts and declarations would constitute sufficient documentary evidence to establish that supplies were made “for authorized operations” or whether endorsement from the Specified Officer on each invoice was mandatory for availing zero-rated GST treatment.
The applicant also queried whether intra-SEZ supplies themselves actually qualified as zero-rated supplies under Section 16 of the IGST Act.
The applicant's submissions were reiterated by Chartered Accountant Meet Jadawala during the personal hearing.
The AAR Bench of Sushma Vyas, Member (SGST) and Vishal Malani, Member (CGST), at the outset examined whether the instant application could be considered by the Authority. Reference was made to Section 97(2) of the CGST Act which specifies the categories of questions on which advance rulings may be sought.
The Authority observed that the applicant’s queries primarily pertained to documentary and evidentiary requirements for proving “authorized operations” and did not pertain to the classification of service, tax liability, admissibility of input tax credit, applicability of notifications or any other category as under Section 97(2) of the CGST Act.
The Authority accordingly held that the questions raised did not fall within the statutory ambit of advance rulings, and refrained from answering all the questions posed by the applicant.
Support our journalism by subscribing to Taxscan premium. Follow us on Telegram for quick updates
