SEZ.
Special Economic Zone units and developers
SEZ Act 2005 · SEZ Rules 2006 · DC → UAC → Board of Approval
Engagement models: Annual retainership · Project-based mandates · One-time representations & opinions

Structure
Positions settled before the transaction
<1 day
Senior advisor first response
01 / 03 · BEFORE THE TRANSACTION
Structure — getting in, on the right terms
Regime choice on your numbers — SEZ vs EOU / MOOWR / DTA
Whether an SEZ beats EOU, MOOWR or FTWZ on your numbers — location lock-in, NFE, DTA-sale economics and the exit bill are modelled before you sign for space.
Form F proposal, UAC hearing → Letter of Approval (Form G)
Projected exports, NFE, employment, investment and the exact authorised operations, drafted the way the Committee reads them. We prepare you for the questions the UAC actually asks rather than the ones the form lists.
Bond-cum-LUT (Form H); Specified Officer onboarding
Executed under Rule 22 before the unit can procure duty-free. Its terms bind the unit for the life of the LoA, so they are negotiated for the operating model you will actually run.
Developer / co-developer route before the BoA
Proposals to the Board of Approval under Rules 3–7 (Form A / Form C), notification of the zone, and the co-developer agreements that decide who holds which authorised operations and who carries which obligation.
IT/ITES and GCC unit set-up
Space allocation and sub-lease terms inside a sector-specific IT SEZ, the developer's authorised operations you depend on, and the SOFTEX and services-export trail the unit will later need for NFE.
02 / 03 · DURING OPERATIONS
Operate — keeping the benefit
NFE ledger tracked every year (r.53), not at year five
NFE tracked by financial year against the Rule 53 formula so a shortfall shows in year two, while there is time to fix the mix.
Annual Performance Report (Form I) that reconciles
Prepared to tie to your bills of export, SOFTEX forms, DTA-sale invoices and GST returns — the same records the Specified Officer and the Approval Committee already have through SEZ Online.
Duty-free procurement (rr.27, 30) and SEZ Online
Duty-free imports and zero-rated DTA supplies for authorised operations, the endorsement and tax-invoice flow with your suppliers, and their LUT position under the IGST Act.
DTA sales, sub-contracting, job-work permissions
Rule 47 sales into the Domestic Tariff Area on payment of applicable duty, Rule 41 sub-contracting permissions, and the documentation trail that survives a Specified Officer's audit.
LoA renewal (Form F1) and a compliance calendar
Applied for two months before each five-year term expires (Rule 19(6A)). Late applications are examined on merits, which is a risk you should not run — calendar it.
03 / 03 · WHEN CHALLENGED
Defend — when the department disagrees
Exit under r.74 priced early — duty on depreciated capital goods
Duty on depreciated capital goods — Rule 49(1) allows 4% per quarter in year one for general capital goods and 10% per quarter for computers, tapering after — so the exit date changes the bill materially. A one-time exit on EPCG terms under Rule 74(4) where you qualify.
Transfer of assets instead of exit (r.74A)
Exiting by transferring the unit's assets and liabilities to another entity in the zone rather than paying duty on everything, where the buyer takes on the LoA obligations.
NFE shortfall and penalty exposure
Representations before the DC and UAC on block-period extension and genuine hardship; penalty proceedings under s.11 of the FT(D&R) Act if the shortfall stands.
Specified Officer demands — SCN reply and hearing
Show-cause notices on duty-free goods, stock differences or removals from the zone are Customs Act proceedings — answered on the s.28 / s.124 ladder, not with a compliance letter.
Appeal to the Board of Approval (Form J, 30 days)
Against an Approval Committee order under s.15 or a cancellation of the LoA under s.16 — an appeal to the Board in Form J within thirty days of receipt (Rules 55–56), the SEZ-specific route, distinct from the Customs appeal ladder.
We help you navigate the SEZ lifecycle — from the initial set-up to day-to-day operations and any dispute that arises.
A senior advisor replies within one business day, not a call centre.
