Separate registration for SEZ units

[Archna Gupta]

Dear Experts,

One of my client providing software services has three different offices in UP. Two premises are located in Noida SEZ and the third unit is located outside SEZ area. How many registrations are required to be taken?

Till now they have taken single registration in which both SEZ units are shown as additional places of business and the premises located outside SEZ is taken as Principal place of business. What is the repercussion in such a situation?

Please reply

[ANITA BHADRA]

Rule 8 of the CGST Rule, 2017 require each unit in a Special Economic Zone (SEZ) to seek a separate registration under the new tax regime, for each of the States where a business operation is carried on and where GST liability arises. Accordingly, a SEZ unit or SEZ developer shall make a separate application for registration as a business vertical, distinct from its other units located outside the SEZ zone.

Accordingly , your client need to take 3 registration .

[Archna Gupta]

Thanks for your reply.

Still one more query that two offices in same SEZ i.e., Noida SEZ would also require two registrations.

[KASTURI SETHI]

In my view, one registration is required for two offices in same SEZ premises. Nature of business of both offices is same SEZ is same. Thus overall two registrations are required by you. Go through the definition of 'Business Vertical". You have not concealed the fact of number of units owned.

[Archna Gupta]

Thank you Kasturi ji

[YAGAY and SUN]

Nice discussion and we endorse the views of experts.

AI Summary

Separate GST registration for SEZ units: each SEZ unit must register as a distinct business vertical, affecting in-zone and out-of-zone units.
SEZ units are treated as requiring separate registration under the GST framework, with an SEZ unit or SEZ developer expected to apply for registration as a distinct business vertical separate from units outside the SEZ where GST liability arises. A contrary operational view appears for multiple offices within the same SEZ premises carrying the same business, which may be consolidated under a single registration.