GST Refund on Supplies to SEZ — Statement 4 & 5, Rule 89, RFD-01

A supply of goods or services to an SEZ unit or developer is a zero-rated supply under Section 16 of the IGST Act, 2017 — the supplier does not bear the GST cost. You can either (a) supply on payment of IGST and claim a refund of that tax using Statement 4, or (b) supply under a LUT (Form RFD-11) without payment and claim refund of accumulated input tax credit using Statement 5. The claim is filed in Form GST RFD-01 under Rule 89, and must be accompanied by an endorsement from the specified officer of the SEZ certifying receipt of the goods/services for authorised operations. File within 2 years of the relevant date.

Rule 89

Refund routeSEZ refunds are claimed in RFD-01 under Rule 89 — Statement 4 when IGST is paid, Statement 5 when supplied under LUT.

Understand It

What Is SEZ Supply GST Refund?

A plain-language explanation of the SEZ refund before the detail.

In simple terms

When you supply goods or services to an SEZ unit or developer, the supply is treated as a zero-rated export — so any GST borne on it can be recovered as a refund. You claim it in Form RFD-01 with the right statement and the SEZ authority's endorsement that it received the supply.

Legally

Under Section 16 of the IGST Act, 2017, supplies to an SEZ unit or developer are zero-rated. Section 16(3) read with Section 54 of the CGST Act, 2017 allows the supplier to either supply on payment of integrated tax and claim its refund, or supply under a bond/LUT and claim refund of unutilised input tax credit. The refund is processed under Rule 89 of the CGST Rules, 2017.

Governing authority

Filed on the GST portal (gst.gov.in) and processed by the jurisdictional Central/State GST refund officer. Receipt of the supply must be endorsed by the specified officer of the SEZ.

Validity

The refund application must be filed within 2 years from the relevant date. A provisional refund of up to 90% may be granted for zero-rated supplies, with the balance after scrutiny.

Service Intelligence

Quick Facts

Refund Form

GST RFD-01

Statement

Statement 4 / Statement 5

Government Fee

Nil

Time Limit

2 years of relevant date

Mode

100% Online (GST portal)

Authority

Jurisdictional GST officer

Governing Law

IGST s.16, CGST s.54, Rule 89

Key requirement

SEZ specified-officer endorsement

Legal & Regulatory Framework

Zero-rating

IGST Act 2017, s.16

Refund

CGST Act 2017, s.54 & s.56

Rule

CGST Rule 89

Statements

Statement 4 / Statement 5

Authority

Jurisdictional GST officer

Last Reviewed

17 Aug 2026

Before You Start

Is This Service Right for You?

Ideal for

Suppliers of goods to an SEZ unit or developer
Service providers rendering services to SEZ units
DTA (Domestic Tariff Area) vendors billing SEZ customers
Businesses with accumulated ITC from zero-rated SEZ supplies
Exporters supplying to SEZ under LUT without paying IGST
Suppliers who paid IGST on SEZ invoices and want it refunded

You may need this if

You supplied to an SEZ and paid IGST you now want refunded
You supplied to an SEZ under LUT and have unutilised ITC
You need the SEZ specified officer's endorsement of receipt assembled
Your refund is stuck on a Statement 4 / Statement 5 mismatch
You are unsure whether Statement 4 or Statement 5 applies to you
You want to file within the 2-year limitation window

Not sure if you need this?

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Why It Matters

Why Claim a Refund on SEZ Supplies?

Because supplies to an SEZ are zero-rated, the GST attached to them is not meant to be a cost. Recovering it protects your margins and working capital.

01

Recover Blocked Tax

IGST you paid on SEZ invoices, or input tax credit accumulated on zero-rated SEZ supplies under LUT, is refundable — leaving that money in the ledger blocks working capital.
02

Zero-Rated by Law

Section 16 of the IGST Act treats supplies to an SEZ unit or developer as zero-rated, on par with physical exports — the tax burden is designed to be nil.
03

Correct Statement Selection

Statement 4 applies where IGST was paid; Statement 5 applies where you supplied under LUT and claim accumulated ITC. Picking the wrong one is a common reason claims are held.
04

Endorsement Compliance

A refund on SEZ supplies must carry an endorsement from the SEZ specified officer confirming receipt of the goods/services for authorised operations. Missing this stalls the claim.
05

Provisional Refund

For zero-rated supplies the officer may sanction a provisional refund of up to 90% (Form RFD-04), improving cash flow while the balance is verified.
06

Protect the Time Limit

The claim must be filed within 2 years of the relevant date. Filing correctly the first time avoids losing the refund to limitation.

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Eligibility

Who Can Apply?

DTA suppliers to SEZ units / developers

Suppliers of goods to SEZs

Service providers to SEZ units

Suppliers who paid IGST on SEZ supplies

Suppliers under LUT with accumulated ITC

Registered persons making zero-rated supplies

Eligibility checklist

The recipient is an SEZ unit or SEZ developer and the supply is for authorised operations
You are a registered person who made the supply (GSTR-1 and GSTR-3B filed for the period)
For Statement 4: IGST was actually paid on the SEZ supply and reflected in returns
For Statement 5: the supply was made under a valid LUT (RFD-11) and ITC is unutilised
You hold the SEZ specified officer's endorsement of receipt of the goods/services
The claim is filed within 2 years from the relevant date

End-to-End

Everything You Need. One Professional Team.

01

Eligibility & Route Check

Confirm the SEZ supply qualifies and whether Statement 4 (IGST paid) or Statement 5 (under LUT) applies.

02

Data Reconciliation

Match your SEZ invoices against GSTR-1, GSTR-3B and the electronic credit/cash ledger.

03

Statement Preparation

Prepare Statement 4 or Statement 5 with invoice-level detail in the prescribed format.

04

Endorsement Assembly

Compile the SEZ specified-officer endorsement of receipt and supporting proof for the file.

05

RFD-01 Filing

File the refund application in Form GST RFD-01 on the portal with all annexures.

06

ARN & Deficiency Tracking

Track the ARN, and respond to any RFD-03 deficiency memo by re-filing correctly.

07

Query & SCN Handling

Draft replies to officer queries and any show-cause notice (RFD-08) on your behalf.

08

Sanction Follow-up

Follow the claim through provisional (RFD-04) and final sanction (RFD-06) and payment order (RFD-05).

No Ambiguity

What You’ll Receive

Refund eligibility & route (Statement 4 vs 5) assessment

Reconciliation of SEZ supplies with GSTR-1 & GSTR-3B

Prepared Statement 4 / Statement 5 (invoice-level)

Assembled SEZ specified-officer endorsement pack

Filed Form GST RFD-01 with ARN acknowledgement

Replies to any RFD-03 deficiency memo or officer query

Show-cause (RFD-08) reply where required

Refund sanction (RFD-06) & credit tracking

Checklist

Documents Required for an SEZ Supply Refund

Requirements depend on whether you supplied on payment of IGST (Statement 4) or under LUT (Statement 5). Keep clear scans ready; the SEZ endorsement is central to every SEZ claim.

01

Common (both routes)

GST registration certificate (REG-06) and login
Tax invoices for the supplies made to the SEZ unit / developer
Endorsement of receipt by the specified officer of the SEZ for authorised operations
GSTR-1 and GSTR-3B for the relevant tax period(s)
Undertaking / declaration that tax incidence has not been passed on (unjust-enrichment declaration)
CA / cost-accountant certificate where the refund exceeds ₹2,00,000 (Rule 89(2)(m), where applicable)

02

With payment of IGST — Statement 4

Proof of payment of IGST on the SEZ supplies (reflected in GSTR-3B)
Statement 4 (invoice-wise detail of SEZ supplies on which IGST was paid)
Declaration that the SEZ unit / developer has not availed input tax credit of the tax paid by the supplier

03

Under LUT (accumulated ITC) — Statement 5

Valid Letter of Undertaking (Form RFD-11) for the financial year
Statement 5 (invoice-wise detail of zero-rated SEZ supplies made without payment of tax)
Computation of Net ITC and the Rule 89(4) refund formula (turnover of zero-rated supply × Net ITC / Adjusted Total Turnover)
For services: bank realisation certificate (BRC) / FIRC evidencing receipt of consideration, where applicable

Important before you file

SEZ endorsement is mandatory

A refund on SEZ supplies must be supported by an endorsement from the specified officer of the SEZ certifying that the goods/services were received for authorised operations. Without it, the claim will not proceed.

Statement 4 vs Statement 5

Use Statement 4 if you paid IGST on the SEZ supply; use Statement 5 if you supplied under LUT and are claiming accumulated ITC. Mixing them up is a frequent cause of deficiency memos.

CA certificate above ₹2 lakh

Where the refund claimed exceeds ₹2,00,000, a certificate from a Chartered Accountant or Cost Accountant on non-passing of tax incidence is generally required (Rule 89(2)(m)).

File within two years

The application must be filed within 2 years of the relevant date. Compute the relevant date carefully for goods versus services.

Match your returns

The SEZ invoices in your statement must reconcile with GSTR-1 (zero-rated table) and GSTR-3B. Mismatches are the most common reason claims are held.

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Step by Step

How the SEZ Refund Is Claimed (Step by Step)

The entire claim is filed online on gst.gov.in under Rule 89.

01

Confirm eligibility & route

Verify the recipient is an SEZ unit/developer and that the supply is for authorised operations, then decide Statement 4 (IGST paid) or Statement 5 (under LUT).

02

Reconcile invoices & returns

Match SEZ invoices to GSTR-1 and GSTR-3B, and verify the electronic cash/credit ledger balances that back the claim.

03

Obtain the SEZ endorsement

Collect the specified officer's endorsement of receipt of goods/services for authorised operations.

04

Prepare the statement & annexures

Build Statement 4 or Statement 5 at invoice level, the Rule 89(4) computation (for ITC), and the unjust-enrichment declaration.

05

File RFD-01 on the portal

Submit Form GST RFD-01 selecting the SEZ refund category, upload annexures, and debit the claimed amount from the ledger.

06

ARN & provisional refund

Receive the ARN; for zero-rated supplies the officer may sanction up to 90% provisionally via RFD-04.

07

Respond & receive sanction

Answer any RFD-03 deficiency memo or RFD-08 notice; on approval the officer issues RFD-06 and the payment order RFD-05.

How Long It Takes

How the SEZ Refund Moves Through Processing

Stage	Expected Time
Acknowledgement (RFD-02) after filing RFD-01	Within 15 days if the application is complete
Deficiency memo (RFD-03), if any — re-file afresh	On scrutiny of the application
Provisional refund up to 90% (RFD-04) — zero-rated	Within 7 days of acknowledgement
Final sanction (RFD-06) & payment order (RFD-05)	Statutory outer limit 60 days from complete application

These are the statutory processing steps under Section 54 and Rule 89–91. If the refund is not paid within 60 days of a complete application, interest under Section 56 (6%, or 9% in certain appeal cases) applies. Officer queries and deficiency memos pause the clock.

Why Outsource

Doing It Yourself vs TaxClue

Doing It Yourself

Determine whether Statement 4 or Statement 5 applies to each supply
Compute Net ITC and the Rule 89(4) formula for LUT supplies
Chase the SEZ specified officer for the receipt endorsement
Reconcile SEZ invoices with GSTR-1 and GSTR-3B
Prepare invoice-level statements in the prescribed format
Respond to RFD-03 deficiency memos within the window
Draft replies to RFD-08 show-cause notices

With TaxClue

Expert confirms the correct statement for each supply
Rule 89(4) computation prepared and checked
SEZ endorsement pack assembled for the file
Invoices reconciled with your returns before filing
Statements prepared accurately at invoice level
Deficiency memos answered and re-filed correctly
Show-cause replies drafted by our team

Skip the guesswork.

Let an expert handle it →

Avoid Delays

Common Mistakes That Delay Your Application

Filing without the SEZ specified-officer endorsement of receipt

Choosing Statement 5 when IGST was actually paid (should be Statement 4)

SEZ invoices not reported in the zero-rated table of GSTR-1

GSTR-1 vs GSTR-3B mismatch on the zero-rated turnover

Wrong Net ITC or Adjusted Total Turnover in the Rule 89(4) formula

Missing CA / cost-accountant certificate where refund exceeds ₹2,00,000

No declaration on non-passing of tax incidence (unjust enrichment)

Claiming refund of ITC that is blocked or ineligible

Filing after the 2-year relevant-date limitation

Recipient SEZ unit having availed ITC of the tax the supplier now claims

TaxClue reviews your documents before filing to reduce avoidable errors.

What If

What Happens If Your Application Is Rejected?

SEZ endorsement of receipt missing or not for authorised operations
Refund amount mismatched with returns / ledger balances
Deficiency memo (RFD-03) not corrected and re-filed
Ineligible or blocked ITC included in the accumulated-credit claim

If a deficiency memo (RFD-03) is issued, the application is treated as not filed and must be submitted afresh within the limitation period. We correct the flagged issues and re-file, and reply to any RFD-08 show-cause notice to protect the claim.

Risk Assessment

Penalties & Consequences

What is at stake if you do not comply

Filing without the SEZ specified-officer endorsement of receipt stalls the claim
Choosing Statement 5 when IGST was actually paid (should be Statement 4) invites rejection
GSTR-1 vs GSTR-3B mismatch on zero-rated turnover holds up the refund
Missing the CA certificate where the refund exceeds ₹2,00,000 makes the claim incomplete
Filing after the 2-year relevant-date limit forfeits the refund

Latest Updates

Regulatory Updates 2025–26

2025: GST refund applications are filed in Form RFD-01 within 2 years of the relevant date under Section 54.
2025: For zero-rated supplies, 90% of the claimed refund can be sanctioned provisionally in Form RFD-04.
2025: Interest at 6% is payable under Section 56 if a sanctioned refund is not paid within 60 days of a complete application.

The Difference

Why Businesses Choose TaxClue

01

GST Refund Focus

Zero-rated and SEZ refunds handled by a team that files them regularly.

02

File-Ready Endorsements

We assemble the SEZ endorsement and annexures so the claim holds up.

03

Right Statement, First Time

Correct choice between Statement 4 and Statement 5 for each supply.

04

Transparent Fees

A clear, itemised quote upfront — no surprises, government fee is nil.

05

Status Visibility

ARN, provisional and final sanction tracked and reported to you.

06

End-to-End Support

From reconciliation to sanction — including query and notice handling.

Data Care

Your Documents Deserve Professional Care

Documents handled by professionals under confidentiality
Access limited to the team working on your refund file
Communication over secure digital channels
Records retained only as long as needed for compliance

Answers

Frequently Asked Questions

Is a supply to an SEZ unit or developer taxable?

It is a zero-rated supply under Section 16 of the IGST Act, 2017 — treated on par with an export. The supplier can either pay IGST and claim it back, or supply under a LUT without paying tax and claim a refund of accumulated input tax credit. Either way, the tax is not intended to be a cost to the supplier.

What is the difference between Statement 4 and Statement 5 for SEZ refunds?

Statement 4 is used when you supplied to the SEZ on payment of IGST and want a refund of that tax. Statement 5 is used when you supplied under a LUT (Form RFD-11) without paying tax and want a refund of accumulated input tax credit. You pick the statement based on how you made the supply.

Is the SEZ officer endorsement really required?

Yes. A refund on supplies to an SEZ must be accompanied by an endorsement from the specified officer of the SEZ certifying that the goods or services were received in the SEZ for authorised operations. This endorsement is one of the core documents for an SEZ refund and its absence stalls the claim.

Which form is used to claim the refund?

The refund is claimed in Form GST RFD-01, filed online on the GST portal, under Rule 89 of the CGST Rules, 2017. The relevant statement (4 or 5) is attached along with the SEZ endorsement and other annexures.

What is the time limit to claim an SEZ refund?

The application must be filed within 2 years from the relevant date, as prescribed under Section 54 of the CGST Act. The relevant date is computed differently for goods and services, so it is important to identify it correctly for each claim.

Can I get a provisional refund on SEZ supplies?

Yes. Because supplies to an SEZ are zero-rated, the officer may sanction a provisional refund of up to 90% of the claimed amount through Form RFD-04, with the balance released after verification and final sanction in RFD-06.

How is the ITC refund amount calculated under Statement 5?

For refund of accumulated input tax credit on zero-rated supplies, Rule 89(4) applies the formula: (Turnover of zero-rated supply of goods and services × Net ITC) ÷ Adjusted Total Turnover. Net ITC is the input tax credit availed on inputs and input services during the relevant period, subject to the rule's conditions.

Do I need a CA certificate for an SEZ refund?

Where the refund claimed exceeds ₹2,00,000, a certificate from a Chartered Accountant or a Cost Accountant certifying that the incidence of tax has not been passed on to any other person is generally required under Rule 89(2)(m). Smaller claims can rely on a self-declaration.

What if the SEZ unit has claimed input tax credit on my invoice?

For a Statement 4 refund (IGST paid by the supplier), a declaration is required that the SEZ unit or developer has not availed input tax credit of the tax paid by the supplier. If the recipient has taken that credit, the supplier's refund on the same tax cannot stand.

What happens if a deficiency memo (RFD-03) is issued?

A deficiency memo means the application is treated as if it was never filed. The claim must be corrected and submitted afresh — within the 2-year limitation period. We identify the flagged issue, fix it, and re-file so the claim is not lost.

Is interest payable if the refund is delayed?

Yes. If a complete refund application is not sanctioned within 60 days, interest under Section 56 of the CGST Act is payable — 6% per annum in the normal case, and 9% per annum in certain cases where the refund arises from an order in appeal or other proceedings.

Can the SEZ unit claim the refund instead of the supplier?

For zero-rated SEZ supplies, the refund is ordinarily claimed by the supplier who made the supply. This differs from deemed exports, where either the supplier or the recipient may claim subject to declarations. We confirm the correct claimant for your facts before filing.

How are SEZ supplies treated under GST?

A supply of goods or services to an SEZ unit or developer for authorised operations is a zero-rated supply under Section 16 of the IGST Act — treated on par with a physical export. The supplier bears no net GST cost: they either pay IGST and claim it back (Statement 4) or supply under LUT and claim accumulated ITC (Statement 5), both via RFD-01 under Rule 89.

How do I claim a GST refund on SEZ supplies step by step?

Confirm the recipient is an SEZ unit/developer and the supply is for authorised operations, then choose Statement 4 (IGST paid) or Statement 5 (under LUT). Obtain the SEZ specified officer's endorsement of receipt, reconcile invoices with GSTR-1 and GSTR-3B, prepare the statement and the unjust-enrichment declaration, and file RFD-01 within 2 years of the relevant date.

What is the difference between SEZ supplies and deemed exports?

SEZ supplies are zero-rated under Section 16 of the IGST Act — you can supply without tax under LUT or on payment and claim it back. Deemed exports under Section 147 are taxable domestic supplies (e.g. to an EOU or against Advance Authorisation) where GST is paid and then refunded. SEZ refunds use Statement 4 or 5; deemed-export refunds use Statement 5B.

Why is the SEZ specified-officer endorsement so important?

A refund on SEZ supplies must be supported by an endorsement from the specified officer of the SEZ certifying that the goods or services were actually received in the SEZ for authorised operations. It is a core document for the claim — without it, the refund will not be sanctioned and the application is liable to a deficiency memo.

What is the relevant date for an SEZ supply refund?

Under Section 54, the relevant date is computed differently for goods and services — broadly linked to the date the goods are supplied to the SEZ or, for services, the date of receipt of payment or invoice as prescribed. The 2-year limit to file RFD-01 runs from this relevant date, so it should be identified carefully for each claim.

Verify Everything

Official Sources & Legal References

Every regulatory figure on this page — sections, statements, forms and timelines — is drawn from primary law and official government sources. Verify them directly:

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