GSTAT remands a refund claim involving SEZ Refund Claim Remanded for Invoice-Wise Turnover Reconciliation

Subhajit Leather Works claimed refund of ₹9,06,045 as unutilised ITC on zero-rated supplies for FY 2021-22, including supplies to SEZ units without payment of tax. The Department rejected the claim because the alleged SEZ turnover was not disclosed in the statutory returns. The taxpayer contended that the turnover had been incorrectly reported as exports due to a columnar error and that supporting documents were available. GSTAT Kolkata held that the matter involved disputed questions of fact and required proper verification of the underlying transactions. It set aside the appellate order and remanded the refund claim to the jurisdictional Proper Officer for fresh examination, with specific directions for invoice-wise reconciliation and supporting documentation.