Which head in GSTR 1 for Tax Invoice to Regular Dealer in India but supply to SEZ Area

This query is : Resolved

Deepak Rawat (Querist)
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07 August 2024 Dear Experts,
I am selling some goods to a Customer A having GSTIN of Karnataka. Here, I am raising Tax Invoice at his Karnataka GSTIN but supply is being made to another person B at SEZ, Noida Uttar Pradesh on the instruction of Customer A.
In GSTR 1, Will it be shown in 4A (B2B Regular) or 6(B) supplies made to SEZ Unit ?
Please guide.

Aashok Kumar Sharma

Aashok Kumar Sharma

(Expert)
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13 August 2025 This is a classic case of "Bill to – Ship to" transaction under GST, involving supply to an SEZ unit on behalf of a regular customer.
🔹 Transaction Summary:
Bill To: Customer A (Regular Dealer) – Karnataka GSTIN
Ship To: SEZ Unit – Noida, Uttar Pradesh
Nature of Supply: Supply to SEZ, but invoice is issued to regular domestic customer
✅ Correct Reporting in GSTR-1
You should report this in Table 6B – Supplies made to SEZ unit/developer with or without payment of tax, not under Table 4A (B2B regular).
Reason:
Supply to SEZ (whether on instruction of another customer or not) is treated as zero-rated supply under Section 16 of IGST Act.
As long as the goods physically move to an SEZ and necessary endorsement from SEZ officer is available, the supply qualifies as SEZ supply, even if the billing is done to a normal domestic party.
✅ Supporting GST Rule/Clarification
As per CBIC Circular No. 46/20/2018-GST, dated 06.06.2018:
"In a 'Bill to – Ship to' model, the place of supply is determined based on the location of the third party receiving the goods (in this case, SEZ), and the supply will be considered as made to SEZ, if the goods are delivered to SEZ unit/developer."
🧾 So, in GSTR-1:
Report under Table 6B: “Supplies made to SEZ unit/developer”
Mention:
GSTIN of Customer A (Karnataka)
Shipping address as SEZ (Noida)
Choose "With/Without payment of tax" depending on your LUT/IGST applicability
🛡️ Important: Documentation
Ensure you have:
Endorsed copy of tax invoice from SEZ customs officer (for goods)
Letter of Instruction from Customer A
LUT or IGST payment proof, if applicable
✅ Conclusion:
Item Value
Table to report in GSTR-1 Table 6B – Supplies to SEZ
Type of Supply Zero-rated (Section 16 of IGST Act)
Invoice issued to Regular Dealer
Goods delivered to SEZ Unit
Tax treatment Supply to SEZ with/without payment of tax

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