Gujarat High Court Grants Interim Relief To R.R. Exports Against HSNSC Cess Registration

The Gujarat High Court on 26 February granted interim relief to R.R. Exports after it challenged a requirement to register its unit, operating in a Special Economic Zone (SEZ), under the Health Security and National Security Cess Act, 2025 (HSNSCA).

A Bench comprising Justice A.S. Supehia and Justice Pranav Trivedi issued notice in the case while recording that:

“Prima facie, we find merit in the submissions advanced by the learned advocate for the petitioner.”

R.R. Exports is a 100% Export Oriented Unit located in the Kandla Special Economic Zone, engaged in manufacturing pan masala under the Special Economic Zones Act, 2005.

The dispute arose after authorities required the unit to register under the HSNSCA, which imposes cess on certain goods, including pan masala.

Challenging this requirement, the petitioner argued that units operating in SEZs enjoy statutory exemptions under Section 26 of the SEZ Act, and that Section 51 of the SEZ Act gives the Act overriding effect over other laws. Therefore, the cess provisions could not be applied to the SEZ unit.

The High Court noted that the petitioner's submissions appeared to have merit at the prima facie stage and therefore issued notice in the matter.

Accordingly, the Court issued notice to the respondents and granted ad-interim relief, making the matter returnable on 2 April 2026. It clarified that the interim protection would continue in terms of the petitioner's prayer, pending further consideration of the case.

Appearance for the Petitioner: MR SHEGUN B CHOKSHI Adv,  MR SP MAJMUDAR Adv

Appearance for the Respondent: MAUNIL G YAJNIK for the Respondent(s) No. 2, NIDHI T VYAS for the Respondent(s) No. 1