SEZ · Mumbai, for clients across India
SEZ Consultants in India
SEZ consultants for units and developers across India: the SEZ lifecycle, from initial set-up to day-to-day operations and any dispute that arises.
A senior advisor replies within one business day.
Is this you?
Special Economic Zone units and developers.
“Setting up a GCC and weighing an SEZ unit against a DTA unit, need the benefit comparison and the exit terms.”
- Led by
- IRS (Retd.) officers
- Trade facilitated
- ₹1,000+ Cr
- Litigation handled
- ₹100+ Cr
- Approvals secured
- 25+
What we do
Your SEZ file, the way we would keep it.
Three stages, fifteen pieces of work, the same advisors at every one. They kept files like this inside the government for decades. Now the file is yours. Open any line for the detail.
- SEZ Act 2005
- SEZ Rules 2006
- DC → UAC → Board of Approval
Who leads this area
R. K. Jain, IRS (Retd.)
30+ years Indian Revenue Service · Customs, SEZ and Trade Policy
New to SEZ? The 60-second brief
A Special Economic Zone is a notified area treated as outside India's customs territory for its authorised operations under the SEZ Act, 2005 and SEZ Rules, 2006. Units procure duty-free and receive zero-rated supplies in exchange for a positive Net Foreign Exchange obligation. We advise developers, co-developers and units through approval, operation and exit, advised by officers who shaped SEZ, EOU, STPI and FTWZ policy at the Ministry of Commerce.
TRADE BRIDGE ADVISORS LLP · MUMBAI
SUBJECT: SEZ
What has to be decided, applied for and signed before the first transaction.
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.
The obligations, records and clocks that keep the benefit from leaking back as a demand.
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.
Notices, exits, investigations and appeals, argued by people who sat on the deciding side of the desk.
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.
LICENCES OBTAINED HERE: SEZ UNIT APPROVAL (LOA)
ON FILE: 5 ANSWERS, READY BEFORE YOU ASKThe SEZ situations we see most, and how we would handle each.
Open the file ▾Close ▴
We are weighing an SEZ unit against a DTA unit for a new centre. What do you actually deliver?
One model with a recommendation: SEZ against EOU, MOOWR and plain DTA on your own numbers, duty and GST benefits, the Net Foreign Exchange obligation, and the Rule 74 exit cost, all in the same spreadsheet. If the answer is not SEZ we say so; the model is the deliverable either way, and it is usually the first thing a board asks us for.
Will you take our unit approval through the UAC?
End to end: the Form F proposal built to survive scrutiny, projections and NFE arithmetic that hold up, the hearing before the Unit Approval Committee, the Letter of Approval in Form G, and then the Bond-cum-LUT and Specified Officer onboarding that make the unit actually operational. A clean file clears in one sitting; drafting that file is the work.
Who tracks our NFE and APR once the unit is running?
We do, as standing work: the NFE ledger kept year by year under Rule 53 instead of discovered at year five, the Form I Annual Performance Report reconciled to your books before submission, DTA sale, sub-contracting and job-work permissions kept current, and the LoA renewed on time. The APR trail we keep becomes the evidence if a dispute ever comes.
The Specified Officer has raised demands on our unit. Do you defend it?
Yes: the show cause reply and the hearing, the NFE shortfall representation made before the five-year block closes, when there is still room to act, and the appeal to the Board of Approval in Form J within its thirty-day window where the matter must go up. The defence stands on the compliance record, which is why we insist on keeping it.
What would exiting the SEZ cost, and can you manage the exit?
We price it before anything is announced: duty on capital goods at depreciated value, duty on stock, and the NFE position, all under Rule 74, and where a transfer of assets under Rule 74A beats a full exit, we structure that instead. Exits planned eighteen months out are computations; exits planned late become litigation, and we have seen both kinds from the other side of the desk.
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Tell us what is happening and attach the notice or approval if there is one. A senior advisor replies within one business day. Scope and fees are agreed in writing before work starts: annual retainership · project-based mandates · one-time representations & opinions.