File GST LUT Online Export Without Paying IGST

An LUT is a legal declaration filed in Form GST RFD-11 under Section 16(3) of the IGST Act, 2017, and Rule 96A of the CGST Rules. It allows registered exporters to make zero-rated supplies without paying IGST upfront, preserving working capital and eliminating refund claims.

Under Section 16(1) of the IGST Act, zero-rated supplies include exports of goods or services and supplies to SEZ units or developers. An LUT under Rule 96A lets suppliers make these zero-rated supplies without upfront IGST, avoiding the lengthy refund process under Section 54.

Form GST RFD-11 is the statutory form for filing an LUT under Rule 96A of the CGST Rules, filed online at www.gst.gov.in. Upon submission via DSC or EVC, an ARN is generated instantly. If the officer takes no action within 3 working days, the LUT is deemed approved per Circular No. 40/14/2018-GST.

An LUT is a simple online declaration, while an Export Bond requires a Bank Guarantee as security. Per Notification No. 37/2017-Central Tax, LUT is available to all eligible exporters except those prosecuted for tax evasion exceeding ₹2.5 Crore, who must furnish a Bond instead.

Yes. Section 16(1)(b) of the IGST Act explicitly includes supplies to SEZ units and developers as zero-rated supplies. An LUT under Rule 96A applies equally to SEZ transactions and direct exports.

No. Composition dealers under Section 10 of the CGST Act cannot make inter-state supplies or exports, so they are ineligible for LUT. To export, they must first convert to regular GST registration by filing Form GST CMP-04 and Form GST REG-01.

Any GST-registered taxpayer making zero-rated supplies — goods, services, or supplies to SEZs — is eligible under Rule 96A. Per Notification No. 37/2017-Central Tax, the only disqualification is prosecution for tax evasion exceeding ₹2.5 Crore.

Yes. Section 16 of the IGST Act covers both goods and services exports. Software developers, IT firms, consultants, and freelancers serving foreign clients are all eligible. Without LUT, they must charge IGST and claim refunds under Section 54 — a lengthy process.

No minimum turnover threshold exists under Rule 96A. However, GST registration is mandatory for all exporters under Section 24 of the CGST Act, as exports are treated as inter-state supplies under the IGST Act.

Yes. A newly registered business with a valid GSTIN can file an LUT immediately. No export track record is required — the LUT is a forward-looking undertaking, and new exporters can access this facility from their very first transaction.

Yes. Simply file Form GST RFD-11 for the current or upcoming financial year. Both routes can even be used selectively across different export transactions within the same year, providing complete flexibility.

Yes. Per Circular No. 40/14/2018-GST, LUT filing is entirely online at www.gst.gov.in via Services → User Services → Furnish Letter of Undertaking (LUT). No physical submission is required. The process typically takes 20–30 minutes once documents are ready.

You need GST Portal login credentials, details of two independent witnesses (names, addresses, occupations), a Board Resolution or Authorisation Letter, DSC for companies/LLPs or EVC for proprietors, and, for renewals, the previous year’s LUT in PDF/JPEG (max 2 MB). Goods exporters should also have their IEC from DGFT.

Under Rule 26 of the CGST Rules, authorised signatories include a Working Director, Managing Director, or Company Secretary for companies; any working partner for partnerships; and the proprietor for sole proprietorships. A Board Resolution designating the signatory is mandatory for companies, LLPs, and firms.

Yes. The GST Portal allows filing at any point during the year. However, exports made before the LUT is filed require IGST payment. Setindiabiz recommends filing in the first week of March to avoid any compliance gap at year-start.

The ARN is system-generated immediately upon successful submission of Form GST RFD-11. If the officer takes no action within 3 working days, the LUT is deemed approved per Circular No. 40/14/2018-GST. Download your acknowledgement from Services → User Services → View My Submitted LUTs.

Under Rule 96A, an LUT is valid for one financial year (1 April to 31 March). A mid-year filing — say on 1 October — covers only until 31 March. A fresh Form GST RFD-11 must be filed for each subsequent year before 1 April.

Under Rule 96A(1)(a), goods must be exported within 3 months from the invoice date. Failure triggers IGST + 18% interest under Section 50(1) within 15 days. The Commissioner can grant extensions as clarified in Circular No. 37/11/2018-GST.

Per amended Rule 96A(1)(b) vide Notification No. 12/2024-Central Tax, payment must be received within 1 year or the FEMA-permitted period — whichever is later. Following RBI Notification FEMA 23(R)/(7)/2025-RB dated 13 November 2025, the FEMA period is now 15 months. Payment must be in convertible forex or INR through permitted channels.

Under Rule 96A(3), if export obligations are not met, the LUT facility is withdrawn. Recovery proceedings under Section 79 of the CGST Act are initiated for outstanding IGST + 18% interest. Once paid in full, the LUT facility can be restored.

Yes. The Karnataka High Court held that the LUT requirement is directory, not mandatory — delayed filing is not fatal if actual export occurred. Circular No. 40/14/2018-GST also permits ex-post-facto filing, subject to the jurisdictional officer’s review.

Zero. The GST Portal charges no fee for Form GST RFD-11. The only cost is the professional service fee charged by your CA or a compliance provider like Setindiabiz for end-to-end filing assistance.

Under LUT, no IGST is paid upfront, preserving working capital. Under the IGST refund route, you pay IGST and claim refund via Form RFD-01 under Section 54 — typically taking 2–6 months. LUT is preferred for most exporters due to a lower compliance burden.

Yes. Exporters under LUT can claim a refund of accumulated ITC on inputs via Rule 89 and Form GST RFD-01. This is a key advantage — you neither pay IGST on exports nor forfeit your ITC, keeping working capital fully intact.

Verify your GSTIN is active, and GSTR-1/GSTR-3B returns are up to date, as pending returns can block LUT filing. If the issue persists, raise a ticket at help.gst.gov.in or contact your jurisdictional officer. Setindiabiz handles such escalations as part of its managed service.

No. LUT filing is routine and does not increase audit risk. In fact, the IGST refund route attracts greater scrutiny since refund claims require officer verification and may trigger ITC audits under Section 65. LUT is the lower-risk compliance option.

Yes. Both routes can be used within the same financial year. Each export invoice can be independently treated — some under LUT (no IGST) and others with IGST payment and refund claim, allowing strategic ITC utilisation.

A fresh LUT must be filed under the new GSTIN for the remaining financial year. The previous LUT does not carry forward automatically. This was clarified by GSTN in the context of UT reorganisations.

Setindiabiz provides fully managed LUT filing through its expert panel of independent CAs. The service covers document review, Board Resolution preparation, witness formatting, Form GST RFD-11 submission, DSC/EVC authentication, ARN confirmation, and annual renewal reminders — ensuring zero compliance gaps.