GST registration - SEZ Unit

[Mohideen A]

Dear Experts,

We have a SEZ Co-developer license and have obtained a SEZ GST in the status of SEZ Developer.

Currently we have developed and finished the constructions in the Co-developer space and plan to occupy the space in the capacity of SEZ Unit additionally. We require insights on the below two points:

1. Can the SEZ Co-developer and SEZ Unit have the same GST Registration - by adding the SEZ Unit as additional branch in the existing GST registration for the Co-developer?

2. In case, the answer to the first question is affirmative, we have a doubt on the e-invoicing requirement. We will have export billings only from the SEZ Unit and Units are exempted from e-invoicing requirement. Will the SEZ Unit be required to e-invoice, if it shares its GST with the Co-developer.

Awaiting your thoughts.

Thanks

AI Summary

Separate GST registration for SEZ units required, determining whether e invoicing rules apply to unit export transactions.
The second proviso to Section 25(1) of the CGST Act requires a person who is a unit in a Special Economic Zone or an SEZ developer to obtain a separate registration distinct from any place of business located outside the SEZ; the SEZ Act's definition treats a co developer as included within the term developer, which brings co developers within the scope of that separate registration requirement and affects whether the unit's export transactions are subject to e invoicing obligations.