SEZ Endorsement and AO Questions Outside Section 97 Jurisdiction

The Gujarat Authority for Advance Ruling declined to answer a series of important questions concerning zero-rated supplies to Special Economic Zone units, documentary requirements for establishing “authorized operations,” and the necessity of Specified Officer endorsements on invoices for intra-SEZ transactions.

The Authority held that the questions raised by the applicant did not fall within the permissible scope of Section 97(2) of the CGST Act, 2017 governing maintainability of advance ruling applications. 

The ruling is significant because although the Authority refrained from answering the substantive GST and SEZ law controversies, the case reflects the growing uncertainty after the amendment to Section 16 of the IGST Act restricting zero-rating benefits only to supplies made “for authorized operations” of SEZ units and developers.