In re Sunwoda Electronic India Pvt. Ltd.
Written by CA Minal Buch, Chartered Accountant, Lead Brain and Founder
Reviewed by Adv Parth Mehta, Advocate, Lead Brain
Last reviewed 31 October 2026
Facts
Sunwoda imported lithium battery systems into a third-party Free Trade Warehousing Zone and sold them on an "as is where is" basis to an OEM holding a Section 65 MOOWR licence. The OEM cleared the goods from the FTWZ into its MOOWR bonded premises. Sunwoda asked whether the FTWZ sale attracted GST.
Decision
The authority held that the sale of warehoused goods before clearance for home consumption falls within clause 8(a) of Schedule III of the CGST Act. It is therefore treated as neither a supply of goods nor of services, and GST is not leviable on that transaction.
What it means in practice
Supply chains that move imported goods from an FTWZ into a MOOWR unit can avoid a GST charge on the intermediate sale, provided the goods have not been cleared for home consumption. This is an advance ruling and binds only the applicant, so similar structures should be reviewed on their own facts.
This summary is general information, not tax, legal or professional advice.