SEZ refund entitlement survives procedural non-registration where services were used for authorised operations and tax was duly paid.

Refund of Cenvat credit could not be denied merely because some input service invoices related to premises not separately registered, where the services were received and consumed within the same SEZ unit for authorised operations and tax had been paid. The absence of any express statutory condition making registration a prerequisite for refund was treated as decisive. The omission to include all premises in the registration particulars was held to be only a procedural lapse, not a defect affecting substantive entitlement. Beneficial SEZ provisions were construed liberally, and refund with consequential relief was upheld.

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Issues: Whether refund of Cenvat credit could be denied merely because the relevant input service invoices were linked to premises not separately registered, when the services were received and consumed within the same SEZ unit for authorised operations.

Analysis: The refund claim had been rejected solely on the ground of non-registration of certain units, although it was not disputed that all the units formed part of the same SEZ premises, the input services were received and consumed for authorised operations, and the tax had been paid on the services. The absence of an express statutory requirement making registration a condition precedent for refund was decisive. The decision also relied on the settled principle that SEZ-related services enjoy exemption under the statutory scheme and that beneficial provisions must receive liberal interpretation. A mere omission to mention all premises in the registration particulars was treated as a procedural lapse, not a defect going to the root of entitlement.

Conclusion: Refund could not be denied on the ground of non-registration, and the assessee was entitled to the refund with consequential relief.

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