Introduction
A Special Economic Zone (SEZ) is a duty-free enclave treated as foreign territory for trade and export operations. Before starting work, contractors must file a Letter of Undertaking (LUT) on the GST portal to access zero-rated supply benefits. This SEZ contractor documentation checklist outlines every document you need to collect from the SEZ unit and key procedures to streamline compliance
1. Unit’s SEZ Approval & Status Documents
1.1 Letter of Approval (LOA)
- Obtain a copy of the SEZ Authority’s LOA that formally authorizes the unit’s operations within the zone
1.2 Lease Deed or Allotment Letter
- Collect the registered lease deed or allotment letter showing the unit’s right to the premises, required within six months of LOA issuance
1.3 Bond-cum-Legal Undertaking (BLUT)
- Ensure the unit has executed Form-H (BLUT) and filed it on the SEZ Online portal. Keep a PDF copy of the approved undertaking
- Contractors should confirm that BLUT documents are jointly filed in the unit’s and contractor’s names for import-procurement activities
2. Contractual & Work Authorization Documents
2.1 Signed Contract or Subcontract Agreement
- Secure a full copy of the contract clearly detailing scope of work, payment terms, and LUT/GST references
2.2 Work Orders & Variation Orders
- Archive all official work orders, change orders, and project memos. These establish authorization for additional work and cost adjustments
2.3 Letters of Transmittal & Meeting Minutes
- Document every instruction or deliverable transmission with cover letters or transmittal notes. Keep meeting minutes to support decision-making and timeline adherence
3. Financial & Invoicing Records
3.1 Zero-Rated GST Invoices
- Issue GST invoices under LUT (zero-rated supplies). Each invoice must cite the LUT reference and SEZ unit GSTIN
3.2 Proof of Receipt & Endorsement
- Collect signed acknowledgments from the specified SEZ officer confirming receipt of goods or services
3.3 Payment & Bank Documents
- Retain bank receipts, cancelled cheques, and NEFT mandates associated with contract payments and LUT filings
4. Procurement & Importation Records
4.1 Domestic Tariff Area (DTA) Procurement
- If sourcing from the DTA without duty, ensure you hold ARE-1 bond copies and bill of export filings within 45 days of arrival
4.2 Import-of-Capital-Goods Documentation
- File import documents (Bill of Entry) jointly with the SEZ unit. Keep a copy of the importer-exporter code (IEC) and customs clearance papers
4.3 Vendor Declarations & Certificates
- Obtain vendor-issued certificates indicating duty-free supply eligibility, especially for sub-contracted equipment or materials
5. Ongoing Compliance & Reporting
5.1 Daily Job Reports & Site Diaries
- Maintain contemporaneous daily reports, site diaries, and photographs. These protect contractual rights and support dispute resolution
5.2 Periodic Performance Reports
- Submit bi-annual performance reports in the required format, detailing investments, manpower, and utility consumption
5.3 Internal Audit Trail
- Implement an internal SOP for document retention, including digital backups, version control, and periodic compliance reviews
Conclusion
By following this SEZ contractor documentation checklist, you ensure full compliance with SEZ and GST LUT requirements. Proper collection and maintenance of these documents not only streamline your project operations but also safeguard you during audits and refund claims. Stay organized, stay compliant, and drive your SEZ projects to success!
Stuck somewhere?
Disturb us to help you out!
Harshaditya Kabra
+91-88277-53530
https://www.linkedin.com/in/ca-harshaditya/
https://accorgconsulting.com/
