As to Ur query I want make refer section 24 Cgst act, Section 16 igst act, & Notification 10 igst
As per section 24, registration is compulsory for unregistered to supply interstate
As per section 16 Igst act Subject to the provisions of sub-section [5] of section 17 of the Central Goods and Services Tax Act, credit of input tax may be availed for making zero-rated supplies, notwithstanding that such supply may be an exempt supply.
As per Notification 10 igst unregistered person can supply services interstate , which exempt him to take registration if his turnover is less then 20 lac
so by Notification 10 which override the section 24, & as to section 16 , read out about the input will not get if it exempted, moreover unregistered person neither charge tax nor avail input.
now as per Zez unit also do not avail any input on their inward supply, so there is no question of doing RCM on such supplies.
CONCULSIONS : unregistered can supply to Sez SEZ is not liable for RCM
I want other expert to plz give their opinion also ( Sir Raja, Sir Divakar )