SEZ refund cannot be denied for invoice address mismatch when services were actually supplied to and used in the unit.

Refund of service tax on input services used for authorised operations in an SEZ unit could not be denied merely because invoices showed the respondent's registered office address instead of the SEZ unit address. The authority treated the address mismatch as a procedural defect, especially since the registered office carried no commercial activity, functioned only as a liaison office, and the service providers confirmed that the services were supplied to and consumed in the SEZ unit. On that basis, the substantive invoice requirement was held satisfied in substance, and the refund was allowed despite the technical lapse.

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Issues: Whether refund of service tax paid on input services used for authorized operations in an SEZ unit could be denied merely because the invoices mentioned the respondent's registered office address instead of the SEZ unit address.

Analysis: The refund was rejected only on the ground that the invoices bore the wrong address and on the view that the input services were not consumed in the SEZ unit. The record showed that the registered office did not undertake any commercial activity, was only a liaison office, and that no GST registration was taken for that office. The respondent also produced declarations from the service providers stating that the services were supplied to and consumed in the SEZ unit. In these circumstances, the address mentioned on the invoices was only a procedural defect. The invoice requirement under Rule 4A of the Service Tax Rules, 1994 was satisfied in substance, and the benefit could not be denied for a technical lapse when receipt and use of the services were not disputed.

Conclusion: Refund could not be denied merely because the invoices were addressed to the registered office, and the respondent was entitled to the refund claimed.

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