GSTR explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
Two deductions that look mechanical and are not. Whether an SEZ-to-DTA sale comes out of turnover depends entirely on who filed the bill of entry — and a composition turnover deduction has to be reconciled against a return the taxpayer can no longer revise.
Table 5K deducts "Adjustments on account of supply of goods by SEZ units to DTA Units" — "Aggregate value of all goods supplied by SEZs to DTA units for which the DTA units have filed bill of entry." Table 5L deducts "Turnover for the period under composition scheme", since "Their turnover as per the audited Annual Financial Statement would include turnover both as composition taxpayer as well as normal taxpayer." Both were optional for FY 2017-18 to FY 2021-22, reportable in Table 5O.
Table 5K: the bill-of-entry test
The Guide's two illustrations set out the whole rule:
(a) DTA unit files the bill of entry. "This transaction would be an outward supply or 'sale' for the purpose of financial statements of the SEZ unit but would not be considered as supply for GST purposes and hence needs to be deducted from the turnovers of financial statements for the purpose of arriving at the turnover as per FORM GSTR-9. In respect of the inward supply in the hands of the DTA, this transaction would be treated as import of goods."
(b) SEZ unit files the bill of entry on the DTA unit's authorisation. "This transaction would be outward supply or 'sale' for the purpose of financial statements of the SEZ unit and inward supply for GST purposes. Accordingly, it would not require any disclosure in the aforementioned Table."
The distinction turns on which party is the importer. Where the DTA files the bill of entry, the DTA is the importer and the transaction leaves the SEZ's GST turnover — hence the deduction. Where the SEZ files it as the DTA's authorised agent, the character changes and no adjustment arises.
Where the SEZ figure comes from
"Such outward supplies are not required to be reported by SEZ units in their GST Returns and hence the data cannot be retrieved from the returns filed by such SEZ units."
So the sources are physical records: "SEZ units are required to maintain records of the assets/goods admitted into the SEZ unit and also the details of disposal of such goods. Such records can assist in identifying the outward supply made by the SEZ unit. Additionally, disposal of capital goods would be disclosed as deletion in the fixed asset registers."
Two control checks:
- "Whether the SEZ unit also has units outside the SEZ area, and whether the entity was required to obtain two registrations — one for SEZ and other for non-SEZ";
- "Check the treatment of transactions which involve transfer of goods from SEZ to non-SEZ. It has to be treated as transaction with the third party."
The second is the more common error. An entity with both an SEZ unit and a DTA unit under the same PAN must treat movements between them as third-party transactions, not internal transfers.
Table 5L: composition turnover
"There may be cases where registered persons might have opted out of the composition scheme during the year. Their turnover… would include turnover both as composition taxpayer as well as normal taxpayer. Therefore, the turnover for which GST was paid under the composition scheme shall be declared under this Table."
And two filings result: "A person registered under the composition scheme who has opted out of the scheme should file both FORM GSTR-9 and FORM GSTR-9A."
Exit can be involuntary. "even a person violating the conditions stipulated in section 10 of the CGST Act or rule 5 or Notification No. 8/2017-CT dated 27.06.2017 would stand to exit the scheme. In such cases, the composition person should file FORM GST COMP-4 and opt out."
The source is GSTR-4:
| Category of supply | GSTR-4 table |
|---|---|
| Taxable outward | Table 6 |
| Advances received | Table 6 |
| Returns | Table 6 |
| Exempted supplies of manufacturers and service providers | Table 6 |
| Amendments to turnover in subsequent GSTR-4 | Table 7 |
| Exempted supplies of traders | "To be extracted from the books of accounts" |
And the tie-out: "Table 5L of FORM GSTR-9C should match with the turnover declared in Table 6C of FORM GSTR-9A, which is the sum of Table 6 and 7 of FORM GSTR-4 of the relevant period."
Two problems specific to composition
Revision is impossible through the normal route. "if any outward supply is omitted in any FORM GSTR-4 pertaining to the financial year… a revision is warranted. Revision in the information cannot be passed through FORM GSTR-4 as the taxable person has opted out of the composition scheme. Besides, revisions are related to the composition turnover hence should not be reported in FORM GSTR-1 and FORM GSTR-3B. However, the same has to be communicated by filing FORM GST DRC-03, where the tax is paid along with interest."
A composition-era advance is taxed differently from a regular one. "Time of supply for the composition scheme includes advance received on supply of goods but under the regular scheme advance received is excluded from time of supply."
The Guide's worked example: advance of ₹50,000 received under composition with tax paid at 1% = ₹500; the supply, of ₹1,00,000, is made after exit. "In terms of section 12… to the extent of the advance of ₹50,000 supply is deemed to have been already effected. Hence, tax under the composition scheme is required to be paid only on ₹50,000 and the balance of ₹50,000 would be subject to tax at the applicable rates of a normal supply."
Six further control checks for 5L: use the outward supplies register to validate; document valuation differences; include only composition-period turnover net of returns and refunds, including advances and exempt supplies; verify outward supply of assets separately under section 18(6), since it is a balance sheet item; check all advances received during the migration period; and verify the cut-off date and transactions on it.
Key takeaways
- Table 5K deducts SEZ-to-DTA supplies only where the DTA unit filed the bill of entry — those are imports in the DTA's hands and outside the SEZ's GST turnover.
- Where the SEZ filed the bill of entry on the DTA's authorisation, no adjustment arises.
- SEZ outward supplies are not in the GST returns — take them from admission and disposal records and fixed asset deletions.
- An entity with both SEZ and non-SEZ units must treat inter-unit movement as a third-party transaction.
- Table 5L deducts composition-period turnover, and an exiting taxpayer files both GSTR-9 and GSTR-9A.
- 5L must equal Table 6C of GSTR-9A, which is Tables 6 and 7 of GSTR-4 combined.
- Traders' exempt supplies are not in GSTR-4 and must come from the books.
- Omissions in GSTR-4 cannot be revised after exit — pay through DRC-03 with interest.
- Under composition, advances on goods are taxable; on exit, only the unadvanced balance bears the regular rate.
Read next
- GSTR-9C Table 5M: Valuation Adjustments Under Section 15
- GSTR-9C Table 5O: The Residual Adjustment Row
- GSTR-9C Table 5A: Turnover From the Audited Financial Statements
Disclaimer: Positions stated as on 5 September 2026, based on Form GSTR-9C and its instructions, sections 10, 12 and 18(6) of the CGST Act, 2017, rule 5 of the CGST Rules, 2017, Notification No. 8/2017-Central Tax and Forms GSTR-4, GSTR-9A and GST COMP-4, as reproduced in the ICAI Technical Guide on GST Reconciliation Statement (Form GSTR-9C).