GST LUT Filing

A LUT, filed in Form GST RFD-11 under Rule 96A of the CGST Rules, is a self-declared undertaking by an exporter that they will comply with the conditions for zero-rated supply — exporting the goods or services (or supplying to an SEZ unit/developer) and realising the proceeds within the prescribed timelines — so that IGST does not need to be paid at the time of invoicing. It replaces the older, more cumbersome requirement of furnishing a bond with a bank guarantee for most exporters.

Under Notification No. 37/2017–Central Tax, any registered person intending to supply goods or services for export or to an SEZ can furnish a LUT — except a person who has been prosecuted for an offence under the CGST Act, 2017 or the erstwhile Central Excise Act, 1944 where the amount of tax evaded exceeds ₹2.5 crore. That narrow category must furnish a bond with bank guarantee instead.

No. There is no minimum turnover, no minimum period of registration, and no export track-record requirement for LUT eligibility. A business can furnish a LUT from its very first day of GST registration if it intends to export goods or services or supply to an SEZ.

A LUT is valid for one financial year only — 1 April to 31 March. It must be furnished afresh for each new financial year before the first export invoice of that year is raised without IGST. A LUT filed for FY 2025-26 has no legal effect on an invoice dated 1 April 2026 or later.

If an export or SEZ invoice is raised without a valid LUT (or bond) in place for that financial year, the supply cannot be treated as zero-rated under the LUT mechanism. The correct treatment in that situation is that IGST should have been charged on the invoice — requiring a credit note, a corrected invoice, and, in some cases, interest exposure and departmental scrutiny on the classification.

No. Form RFD-11 for LUT is a self-declaration filed entirely online — it does not require uploading financial statements, export invoices, shipping bills, or turnover proof at the filing stage. The portal accepts the declaration and, in the current process, generally issues an acknowledgement automatically on successful submission without a manual officer verification step for most applicants.

Form RFD-11 requires the name, occupation, and address of two witnesses who attest the undertaking. There is no statutory restriction requiring them to be employees, professionals, or unrelated third parties — but they should be identifiable, contactable individuals whose details are accurately recorded, since incorrect or fictitious witness details can be a ground for the undertaking to be questioned later.

Any registered person can file a LUT — proprietorships, individuals, partnership firms, LLPs, and companies of any type. Proprietorships and individuals have the added convenience of being able to authenticate the filing via EVC (Aadhaar-linked OTP) instead of a Digital Signature Certificate, whereas companies and LLPs must use a Class 3 DSC.

Under LUT, you invoice the export or SEZ supply without charging IGST at all, and separately claim a refund of the input tax credit accumulated on your purchases (Rule 89(4)). Under the alternative route, you charge and pay IGST on the export invoice as if it were a normal supply, and then claim a refund of that IGST paid. Both routes achieve zero-rating in substance, but the LUT route avoids funding IGST out of your own working capital on every invoice, which is why most regular exporters prefer it.

This depends entirely on whether the arrangement meets the 'export of services' definition under Section 2(6) of the IGST Act — supplier located in India, recipient located outside India, place of supply outside India, payment received in convertible foreign exchange (or permitted INR), and the supplier and recipient must not be merely 'establishments of a distinct person' under Explanation 1 to Section 8 of the IGST Act. If your Indian entity is a branch or representative office of the same legal entity as the US parent (rather than a separate subsidiary), the supply may be treated as a supply between distinct establishments of the same person and may not qualify as an export — with GST implications that are materially different from a genuine cross-border export.

Under Rule 96A, goods must be exported out of India within 3 months from the date of the export invoice. If the goods are not exported within this period (and no extension has been granted by the proper officer), the exporter becomes liable to pay the IGST that would have applied, along with interest at 18% per annum computed from the date of the invoice.

For services, Rule 96A allows a period of one year from the date of the export invoice for the proceeds to be realised in convertible foreign exchange (or permitted INR), unless the proper officer has allowed a longer period. If realisation does not occur within the permitted period, the same consequence applies as for goods — the IGST that would otherwise have applied becomes payable, along with 18% per annum interest from the invoice date.

The LUT itself is a self-declaration and is not typically 'rejected' after acceptance in the way an application might be. However, repeated failure to meet the underlying conditions — goods or services not exported within the Rule 96A timeline, proceeds not realised, or misuse of the facility — can result in the LUT facility being withdrawn for the exporter, requiring a transition to the bond-with-bank-guarantee route for subsequent supplies until compliance is demonstrated.

It is a genuine requirement, not a formality. Every invoice issued for a zero-rated supply under LUT must bear the prescribed endorsement — typically along the lines of 'Supply meant for export/supply to SEZ unit or SEZ developer for authorised operations under bond or Letter of Undertaking without payment of integrated tax' — together with a reference to the LUT. An invoice missing this endorsement can be challenged as not properly documented as a zero-rated supply, complicating both your own compliance position and any refund claim built on that invoice.

Yes. The LUT only permits IGST-free invoicing — it does not itself generate any refund. The refund of accumulated input tax credit is a completely separate filing, made through Form RFD-01, applying the Rule 89(4) formula for exporters without payment of tax, and reconciled against your GSTR-1, GSTR-2B, and GSTR-3B for the relevant period.

There is no fixed statutory frequency — a refund application can be filed for one or more consecutive tax periods within the same financial year, subject to the overall two-year limitation period under Section 54 of the CGST Act. Most businesses with meaningful export volume file monthly or quarterly to keep working capital flowing rather than letting credit accumulate for a full year.

Under Section 54 of the CGST Act, a refund application must be filed within two years from the 'relevant date' — for zero-rated supply of goods, this is generally linked to the date of export (as evidenced by the shipping bill/export manifest); for zero-rated supply of services, it is linked to the date of receipt of payment in convertible foreign exchange, or the date of invoice if payment is received in advance. Refunds not claimed within this window are permanently forfeited, with no condonation mechanism for a simply-missed deadline.

A supply to an SEZ developer or SEZ unit for authorised operations is treated as a zero-rated supply under Section 16 of the IGST Act, exactly like a physical export outside India. As the domestic supplier making that supply, you (not the SEZ unit) need the LUT in order to invoice without IGST — the SEZ unit's own GST status is a separate matter and does not substitute for your own LUT.

The portal filing itself is a straightforward online form that a business owner can technically complete without professional help. The value of engaging a CA is not the mechanical act of filing — it is confirming eligibility, verifying the export/SEZ classification is genuinely correct for your specific arrangement (particularly for services), ensuring signatory and witness details are accurate, and — most importantly — setting up the ongoing tracking of Rule 96A timelines, FIRC matching, invoice endorsements, and the annual renewal, none of which the portal itself will remind you about.

There is no separate 'late filing penalty' specifically for a delayed LUT renewal — the consequence flows through the underlying invoices. Any export invoice raised on or after 1 April without a fresh LUT in place for that year cannot rely on the LUT mechanism; the correct treatment is that IGST should have been charged, exposing the business to a classification correction, potential interest, and the administrative cost of reissuing invoices and amending returns.

PNPC builds a client-specific compliance calendar at onboarding that tracks: the LUT's financial-year validity and renewal date, the Rule 96A export/realisation deadline for every individual invoice raised under LUT, FIRC/BRC matching status against each services invoice, and the periodic RFD-01 refund filing schedule. This calendar is monitored actively — not simply handed to the client as a document — and we reach out proactively before each deadline rather than waiting to be asked.

The GST rate rationalisation of September 2025, which moved most domestic goods and services onto a simplified 5%/18%/40% slab structure, governs the rate applicable to domestic taxable supplies. Export and SEZ supplies made under LUT are zero-rated — meaning no GST/IGST is charged on the outward invoice regardless of what domestic rate slab the underlying goods or services would otherwise attract. The rate structure is directly relevant, however, to the ITC refund computation, since the credit being refunded arises from GST paid on domestic purchases (inputs, input services, capital goods) at the applicable domestic rate.

No. A composition dealer under Section 10 of the CGST Act is restricted to intra-state supply and cannot make inter-state supplies, exports, or supplies to SEZ units — this restriction is inherent to the composition scheme itself. A business intending to export must be registered under the regular scheme; LUT and export activity are simply not available to a composition taxpayer.

The core question is again the 'distinct persons' test under Explanation 1 to Section 8 of the IGST Act — if the Indian entity is a separate, distinctly incorporated subsidiary (rather than a branch/liaison office of the same legal person as the UAE entity), and the other Section 2(6) conditions (payment in convertible foreign exchange, place of supply outside India) are met, the arrangement can generally qualify as export of services eligible for LUT. Where the Indian presence is a branch office or liaison office of the same UAE legal entity rather than a separately incorporated company, the supply is between establishments of the same person and does not qualify as export under GST, regardless of how the invoice is worded.

Yes. There is no restriction on switching from the IGST-paid-and-refund route to the LUT route — you simply need a valid LUT furnished for the current financial year before you begin invoicing under it. Existing invoices already raised with IGST paid continue on their original refund track; only invoices raised after the LUT is in place are treated as zero-rated without IGST.

LUT is a GST-law mechanism administered entirely on the GST portal and is legally distinct from DGFT's Foreign Trade Policy framework. However, an Importer Exporter Code (IEC) from DGFT is a separate and independent requirement for any business physically exporting or importing goods, and is generally needed alongside — not instead of — a GST LUT for goods exporters. Services exporters may not always need an IEC depending on the nature of the service and payment mechanism, but goods exporters almost always need both an IEC and a GST LUT running in parallel.

Yes, in specific permitted circumstances. Section 2(6) of the IGST Act requires payment 'in convertible foreign exchange or in Indian rupees where permitted by the Reserve Bank of India.' RBI has, over time, permitted rupee payment for exports in specific arrangements (for example, under the Special Rupee Vostro Account mechanism for trade with certain countries, or where RBI guidelines otherwise specifically allow INR settlement for the export transaction). Whether your specific INR payment arrangement falls within an RBI-permitted route needs to be verified on the facts — it is not automatic that any INR payment qualifies.

At minimum: the LUT acknowledgement and ARN for each financial year, every export invoice bearing the correct endorsement, shipping bills (goods) or FIRC/BRC (services) matched to each invoice, GSTR-1/GSTR-3B/GSTR-2B for each relevant period, the Rule 89(4) refund computation workings for every RFD-01 filed, and correspondence/approvals for any Rule 96A extension sought. These should be retained for at least the statutory record-retention period under Section 36 of the CGST Act.

No. There is no government fee prescribed for furnishing Form RFD-11 (LUT) on the GST portal — it is a free, self-declared filing. Professional fees for the eligibility review, filing, and — more importantly — the year-round compliance tracking that follows, are a separate matter agreed with your CA firm.

A self-filing or a low-cost portal service typically stops at the ARN and acknowledgement — the moment the ticket looks 'closed.' It does not test whether your specific export arrangement genuinely qualifies as export of services under the distinct-persons rule, does not configure your invoicing for the mandatory endorsement, does not track the Rule 96A export/realisation clock invoice by invoice, does not chase FIRC matching with your bank, does not file the separate RFD-01 refund claims that actually recover cash, and will not remind you in March that the LUT needs re-filing before 1 April. PNPC treats the LUT filing as the entry point to a year-round compliance relationship, not the deliverable itself.

The LUT filing mechanics are the same regardless of size, but smaller exporters are often the ones with the least internal bandwidth to track Rule 96A timelines, FIRC matching, and periodic refund filings across a full year — and a missed deadline has the same proportionate consequence (IGST plus 18% interest) whether the business is large or small. For a genuinely small, occasional exporter, a lighter-touch engagement focused on the annual filing plus periodic check-ins is often sufficient; for a business with monthly export invoicing, ongoing tracking earns back its cost many times over in recovered ITC and avoided interest exposure.

For clients with operations spanning India and the UAE — an Indian subsidiary billing a Dubai parent, an Indian exporter shipping to UAE buyers, or a UAE entity setting up Indian operations for export-oriented work — PNPC coordinates the India-side GST/LUT/refund compliance from our Chennai, Bangalore, and Hyderabad offices alongside our Dubai office, which handles the UAE-side VAT, Corporate Tax, and invoicing considerations. This means the cross-border classification question (is this genuinely an export, or an intra-entity supply?) is assessed by one team with visibility into both sides of the transaction, rather than being split between two firms that never compare notes.