SEZ zero-rated supply claims require supporting documents; assessment orders were set aside and remanded for fresh consideration.

SEZ units claiming zero-rated supply under the IGST Act must satisfy the statutory framework under the SEZ Act, SEZ Rules and the relevant IGST provisions, including the documentation basis for such benefit. The dispute turned on the allegation that the Letter of Undertaking and SEZ certificate had not been produced before the adjudicating authority. The record indicated that the orders were passed mainly on that footing, while the SEZ certificate was later produced and the petitioner undertook to produce the Letter of Undertaking. The assessment orders were set aside and the matter was remanded for fresh consideration after allowing the petitioner to file an additional reply and relevant documents.

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Issues: Whether the assessment orders passed under the Tamil Nadu Goods and Services Tax Act, 2017 required interference where the petitioner, an SEZ unit, claimed the benefit of zero-rated supply under the Integrated Goods and Services Tax Act, 2017 and the orders were stated to have been passed for want of the Letter of Undertaking and SEZ certificate.

Analysis: The petitioner relied on the statutory scheme applicable to SEZ units, including the Special Economic Zones Act, 2005, the Special Economic Zones Rules, 2006, Section 7(5)(b) and Section 16 of the Integrated Goods and Services Tax Act, 2017, and the notifications governing reverse charge. The respondent's case was that the petitioner had not produced the Letter of Undertaking and SEZ certificate before the adjudicating authority for verification. The record showed that the impugned orders were passed primarily on that basis, and the SEZ certificate was produced before the Court, with an assurance that the Letter of Undertaking would also be produced.

Outcome: The assessment orders were set aside and the matters were remanded for fresh consideration after the petitioner was given an opportunity to file the additional reply and produce the relevant documents before the adjudicating authority.

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