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LUT Filing for Exporters — Complete 2025 Guide (GST Zero-Rated Supply Made Simple)

Infographic warning exporters about a common GST export mistake that can lead to 18% IGST liability, penalties, and compliance issues in FY 2025–26.

Introduction: The ₹50,000 Mistake 70% of Exporters Make Every April

Real scenario (happens every year):

April 5, 2025
A Bangalore-based SaaS startup invoices their first US client of the new financial year: $10,000 (₹8.5 lakhs).

Founder thinks: “We’re exporters, GST is 0%.”

Invoice raised at 0% GST. Payment received. Everyone’s happy.

July 2025
GST notice arrives:

“Export invoice issued on April 5 without valid LUT for FY 2025-26. IGST of ₹1,53,000 (18%) payable + interest @ 18% p.a. + penalty.”

Total demand: ₹1,78,000+ for a single mistake.

The mistake?
They filed LUT for FY 2024-25 (last year) but forgot to renew for FY 2025-26.


This happens to 70% of exporters:

  • ❌ File LUT once, assume it’s lifetime valid
  • ❌ File LUT in May/June (after first export invoices)
  • ❌ File incorrectly (wrong signatory, missing documents)
  • ❌ Don’t link LUT to export invoices
  • ❌ Fail to maintain export documentation
  • ❌ Mix up LUT for goods vs. services

The cost:

  • IGST liability: 18% of export value
  • Interest: 18% p.a. from invoice date
  • Penalty: Up to ₹25,000
  • Refund hassles: 6-12 months to recover
  • Cash flow impact: Huge (especially for SMEs)

What is LUT and why does it matter?

LUT (Letter of Undertaking) is a simple declaration that allows you to export goods/services without paying IGST upfront.

Without LUT:
Export invoice → Pay 18% IGST → File refund → Wait 6+ months → Get refund (maybe).

With LUT:
Export invoice → 0% GST → No payment → No refund wait → Clean cash flow.

The difference: ₹18 lakhs blocked for every ₹1 crore export vs. zero blockage.


This comprehensive guide covers:

  1. What is LUT (crystal clear explanation)
  2. Who should file LUT
  3. When to file (critical timelines)
  4. Step-by-step online filing process (2025 updated)
  5. Documents required
  6. LUT vs. Bond vs. IGST Refund route
  7. How to use LUT for invoicing
  8. Common mistakes & rejections
  9. LUT for goods vs. services
  10. Practical compliance tips
  11. Troubleshooting guide

1. What is LUT Under GST? (Simple Explanation)

Definition:

LUT (Letter of Undertaking) = A declaration filed by exporters with GST authorities stating they will export goods/services and fulfill all export obligations without paying IGST upfront.


Key Features:

Online form (Form GST RFD-11)
Annual validity (April 1 – March 31)
No bank guarantee required (removed since 2018)
Applies to both: Goods & Services exports
Also covers: Supply to SEZ units/developers
Zero cost to file (government doesn’t charge fee)


Legal Basis:

  • Section 16 of IGST Act, 2017: Zero-rated supply provisions
  • Rule 96A of CGST Rules, 2017: LUT furnishing procedure
  • Notification No. 37/2017-Central Tax: LUT/Bond conditions

How LUT Works:

Step 1: Exporter files LUT before first export of FY
Step 2: GST system auto-approves (instant/3 days)
Step 3: Exporter issues invoice mentioning “Export under LUT without payment of IGST”
Step 4: Invoice shows 0% GST
Step 5: Goods/services exported
Step 6: Payment received in foreign exchange
Step 7: Export reflected in GSTR-1 (Table 6B)
Step 8: No IGST paid, no refund needed


What LUT Enables:

BenefitImpact
Zero IGST paymentNo cash outflow on export sales
No refund waitMoney not blocked for 6+ months
Faster cash flowCan reinvest immediately
Simpler complianceJust file GSTR-1, no refund application
Lower scrutinyRefunds invite more questions

What LUT Does NOT Mean:

Not a license (it’s a declaration)
Not lifetime (valid only 1 FY)
Not exemption from compliance (must maintain export proof)
Not exemption from GSTR filing (still report exports in GSTR-1)


2. Who Can (and Cannot) File LUT?

✅ Eligible to File LUT:

Category 1: All Registered GST Exporters

  • Companies
  • LLPs
  • Partnership firms
  • Proprietorships
  • Individuals (professionals exporting services)

Category 2: All Export Types

  • Goods exporters
  • Service exporters
  • Both goods + services exporters

Category 3: SEZ Suppliers

  • Suppliers to SEZ units
  • Suppliers to SEZ developers

Category 4: Deemed Exports (in some cases)


❌ Not Eligible to File LUT (Must Use Bond):

Category A: Prosecuted Taxpayers
Persons prosecuted for any offense under GST/Excise/Service Tax/Customs where tax evasion exceeds ₹2.5 crores.

Category B: GST Fugitives
Persons notified as wilful defaulters or absconders.

These categories must furnish Bond instead of LUT (with bank guarantee/surety).


Common Question:

Q: I’m a new exporter with no history. Can I file LUT?
A: Yes! LUT has no turnover threshold or experience requirement. Even first-time exporters can file.


3. When Should LUT Be Filed? (Critical Timelines)

Annual Renewal Requirement:

LUT validity: April 1 to March 31 (financial year)

Must file fresh LUT every FY — it does NOT auto-renew.


Ideal Filing Timeline:

DateActionWhy
April 1-5File LUT for new FYBefore any export invoice
April 6+Start exporting under LUTSafe, compliant
Throughout FYKeep exportingLUT valid till March 31
March 31LUT expiresNeed new one for next FY

Critical Rules:

Rule 1: File BEFORE issuing first export invoice of FY
If you export on April 3 but file LUT on April 10 → April 3 invoice becomes IGST-liable.

Rule 2: Can file even if you haven’t finalized clients yet
Preventive filing allowed.

Rule 3: Multiple GSTINs = Multiple LUTs
Each GSTIN needs separate LUT.

Rule 4: Mid-year start = File immediately
Started exporting in August? File LUT now; valid till March 31.


What Happens If You Forget?

Scenario: Exported in April without LUT.

Consequences:

  • 18% IGST becomes payable on April exports
  • Interest @ 18% p.a. from invoice date
  • Penalty up to ₹25,000
  • Must file refund application for IGST paid

Solution:

  • File LUT immediately
  • Pay IGST + interest for pre-LUT invoices
  • File refund claim
  • Avoid repeat for rest of FY

4. Documents Required for LUT Filing (2025 Checklist)

Good news: LUT filing is mostly auto-fill. Minimal documents needed.


Required Information:

GSTIN (auto-filled from login)

PAN (auto-filled)

Legal name of business (auto-filled)

Registered address (auto-filled)

Financial year (select from dropdown)

Authorized signatory details:

  • Name
  • Designation
  • PAN
  • Mobile
  • Email

Digital Signature Certificate (DSC) for companies/LLPs
OR
EVC (E-Verification Code) for proprietorships/individuals


Optional (But Recommended):

Board Resolution/Authorization Letter
If signatory is not Managing Director/Proprietor, upload authorization.

Previous year’s LUT (for reference; not mandatory)


Documents NOT Required (Common Misconception):

❌ Bank guarantee (abolished since 2018)
❌ Shipping bills / export proof (not at filing stage)
❌ GST payment proof
❌ Trade license
❌ IEC (Import Export Code) certificate


5. Step-by-Step LUT Filing Process (2025 Edition)

Pre-Filing Preparation:

Step 0.1: Ensure DSC/EVC is ready

  • Companies/LLPs: Get Class 2/3 DSC from licensed CA
  • Proprietors: Use Aadhaar OTP for EVC

Step 0.2: Clear pending returns (if any)

  • System may flag if multiple returns pending
  • File pending GSTR-1/3B first

Step 0.3: Update authorized signatory on GST portal (if needed)


Online Filing Steps:

Step 1: Login to GST Portal

Go to: https://www.gst.gov.in

Enter:

  • Username (GSTIN)
  • Password
  • Captcha

Click Login


Step 2: Navigate to LUT Section

Dashboard → ServicesUser ServicesFurnish Letter of Undertaking (LUT)


Step 3: Select Financial Year

Dropdown menu: Select 2025-26 (for FY starting April 2025)

Click Proceed


Step 4: Form GST RFD-11 Loads

Auto-filled fields appear:

  • GSTIN
  • Legal name
  • Trade name
  • Address

Verify accuracy (usually correct from registration).


Step 5: Read and Accept Undertaking

Three declarations appear:

Declaration 1:
“I undertake to comply with provisions of Section 16 of IGST Act…”

Declaration 2:
“I have not been prosecuted for any offense under CGST/SGST/IGST/UT GST Acts where tax evaded exceeds ₹2.5 crores…”

Declaration 3:
“I will maintain proper documentation of exports as per GST laws…”

Action: Tick all three checkboxes.


Step 6: Enter Authorized Signatory Details

Name: As per PAN
Designation: Director / Proprietor / Partner / Authorized Signatory
PAN: (enter)
Mobile: (OTP may be sent)
Email: (for communication)


Step 7: Upload Authorization (If Applicable)

If signatory is NOT Managing Director/Proprietor:

Upload: Board resolution/authorization letter (PDF, max 5MB)

Sample text:

“Resolved that [Name], [Designation] is authorized to sign and submit Form GST RFD-11 (LUT) for FY 2025-26 on behalf of [Company Name].”


Step 8: Preview Form

Click Preview

Review all details carefully:

  • Financial year correct?
  • Name spelling correct?
  • All declarations ticked?

Step 9: Sign Using DSC or EVC

For Companies/LLPs:

  • Insert DSC (USB token)
  • Select certificate
  • Enter DSC password
  • Click Sign

For Proprietors:

  • Click File with EVC
  • Enter Aadhaar number
  • Request OTP
  • Enter OTP
  • Submit

Step 10: Submit

Click Submit with DSC/EVC

System processes (usually instant):

  • Validation checks run
  • ARN (Application Reference Number) generated
  • Success message displayed

ARN Format: AB12345678901234V (17 characters)


Step 11: Download Acknowledgment

Save two files:

File 1: LUT Form (PDF with ARN and submission date)
File 2: Acknowledgment receipt

Store in: Compliance folder (digital + physical backup)


Step 12: Check Status (If Not Auto-Approved)

Dashboard → Services → User Services → Track Application Status

Enter ARN → Search

Status options:

  • ✅ Submitted (auto-approved, can export)
  • 🕐 Pending (rare; officer review needed; max 3 working days)
  • ❌ Rejected (correct and resubmit)

Processing Time:

99% cases: Instant approval (system-generated)
1% cases: 1-3 working days (manual review if flagged)


6. How to Invoice Using LUT (Practical Guide)

Once LUT is filed, your export invoices must reflect this.


Mandatory Invoice Elements:

Invoice title: “Tax Invoice” / “Export Invoice”

Supplier details: Name, GSTIN, address

Recipient details: Foreign client name, address, country

Invoice number & date

Service/goods description + SAC/HSN code

Quantity, rate, amount (in foreign currency + INR equivalent)

Place of supply: Outside India / [Country name]

Tax rate: 0% or NIL

IGST amount: ₹0

Declaration text:

“Supply meant for export under Letter of Undertaking (LUT) without payment of Integrated Tax as per Rule 96A of CGST Rules, 2017. LUT ARN: [Your ARN Number]. Place of supply is outside India.”

LUT Reference Number (ARN from Step 10 above)


Sample Declaration Box (For Invoice):

EXPORT UNDER LUT
-----------------
This is an export of [goods/services] under Section 16 of IGST Act, 2017.
Supply made under LUT (Form GST RFD-11) without payment of Integrated Tax.
LUT ARN: AB12345678901234V
LUT Valid for: FY 2025-26
Place of Supply: United States of America

Common Invoice Mistakes:

Showing 18% IGST (even at 0% or N/A, creates confusion)
No LUT mention (auditors may question)
Wrong place of supply (showing India instead of client country)
No SAC/HSN code (mandatory for GST reporting)


7. LUT vs. Bond vs. IGST Refund Route (Comparison)

Exporters have 3 options:


Option A: LUT (Letter of Undertaking) ⭐ RECOMMENDED

AspectDetails
What it isAnnual declaration (no bank guarantee)
GST paymentZero (export at 0%)
Cash flowExcellent (no blockage)
Refund neededNo (just ITC refund if applicable)
RenewalAnnual (every April)
CostFree
Processing timeInstant
Best forAll exporters (default choice)

Option B: Bond (Bank Guarantee/Surety)

AspectDetails
What it isBond with bank guarantee
Who needs itProsecuted taxpayers (tax evasion >₹2.5Cr)
GST paymentZero (export at 0%)
Cash flowGood (no GST blockage, but bank charges for BG)
CostBank guarantee fees (1-2% of BG amount annually)
Processing7-15 days (bank + GST approval)
Best forOnly those ineligible for LUT

Option C: Export with Payment of IGST (Then Refund)

AspectDetails
What it isPay 18% IGST on invoice, claim refund later
GST payment18% upfront
Cash flowPoor (₹18L blocked per ₹1Cr export)
Refund time60 days (legal); 6-12 months (reality)
DocumentationHeavy (shipping bills, bank certificates, etc.)
ScrutinyHigh (every refund scrutinized)
Best forRarely used (only if LUT/bond not feasible)

Quick Decision Tree:

Are you eligible for LUT?
→ Yes → Use LUT (Option A)
→ No (prosecuted >₹2.5Cr) → Use Bond (Option B)

99.9% of exporters use LUT.


8. GSTR-1 Reporting with LUT

Filing LUT doesn’t exempt you from GST returns. You must still report exports.


Where to Report in GSTR-1:

Table 6B: Exports (Zero-rated supply without payment of tax – under LUT/Bond)

Not Table 6A (that’s for exports with payment of IGST).


Information to Enter:

  • Invoice number
  • Invoice date
  • Invoice value (₹)
  • Port code (for goods: actual port; for services: 000000)
  • Shipping bill number/date (for goods: from Customs; for services: can use invoice number)
  • Rate of tax: 0%

Common GSTR-1 Mistakes:

❌ Reporting in Table 4 (taxable supplies) instead of Table 6B
❌ Showing 18% rate (should be 0%)
❌ Wrong invoice value (mismatch with books)
❌ Missing SAC/HSN code


9. Common LUT Mistakes & How to Avoid Them

❌ Mistake 1: Filing LUT After First Export

Scenario: Exported on April 5, filed LUT on April 15.

Impact: April 5 invoice becomes IGST-liable.

Solution: File LUT by April 5 latest (ideally April 1-3).


❌ Mistake 2: Thinking LUT is Lifetime

Reality: LUT expires March 31 every year.

Solution: Set annual reminder: “File LUT by April 5, 2025/2026/2027…”


❌ Mistake 3: Not Mentioning LUT on Invoice

Impact: Auditors may question 0% GST; may demand IGST payment.

Solution: Always include LUT ARN and declaration on invoice.


❌ Mistake 4: Using Wrong Signatory

Scenario: LUT signed by Sales Manager, but GST portal only has MD authorized.

Impact: LUT rejected.

Solution: Either:

  • Use authorized signatory as per GST registration, OR
  • Update GST registration with new signatory, OR
  • Upload board resolution authorizing the signatory

❌ Mistake 5: Not Maintaining Export Proof

What to maintain:

  • Export invoices
  • Shipping bills (goods) / Delivery proof (services)
  • FIRC/SWIFT (foreign exchange receipt)
  • Bank statements
  • GSTR-1 copies
  • LUT acknowledgment

Why: GST audits check if exports actually happened.


❌ Mistake 6: Forgetting to File GSTR-1

LUT ≠ exemption from returns.

Solution: File GSTR-1 monthly/quarterly reporting all exports in Table 6B.


❌ Mistake 7: Multiple GSTINs, Single LUT

Reality: Each GSTIN needs its own LUT.

Example:

  • Maharashtra unit: GSTIN 27ABC…
  • Karnataka unit: GSTIN 29XYZ…
  • Need: 2 separate LUTs

❌ Mistake 8: Not Receiving Payment in Foreign Exchange

LUT doesn’t waive FEMA requirement.

Rule: Export proceeds must come in convertible foreign exchange (or RBI-permitted INR).

Solution: Ensure client pays in USD/EUR/GBP etc. to your bank account with proper FIRC.


❌ Mistake 9: Mixing Domestic and Export in Same Invoice

Wrong: Invoice showing both Indian customer (18% GST) and foreign customer (0% GST) on same bill.

Right: Separate invoices for domestic (18% GST) and export (0% under LUT).


❌ Mistake 10: Not Tracking Exports vs. Realizations

LUT undertaking includes: Export proceeds realized within prescribed time (9 months per FEMA).

Solution: Maintain export register tracking:

  • Invoice date
  • Invoice value
  • Expected realization date (Invoice date + 9 months)
  • Actual realization date
  • Status

10. LUT Rejection Reasons & Solutions

Although rare (95%+ auto-approved), LUT may be rejected:


Rejection Reason 1: Pending GST Returns

Issue: Multiple GSTR-1/3B not filed.

Solution: File all pending returns, then reapply for LUT.


Rejection Reason 2: Wrong Financial Year Selected

Issue: Selected 2024-25 instead of 2025-26 in April 2025.

Solution: Refile with correct FY.


Rejection Reason 3: Mismatch in Signatory Details

Issue: PAN on LUT doesn’t match authorized signatory PAN in GST registration.

Solution: Correct PAN or upload authorization letter.


Rejection Reason 4: DSC Issue

Issue: DSC expired, revoked, or doesn’t match PAN.

Solution: Get valid DSC from licensed CA; ensure PAN matches.


Rejection Reason 5: Previous Violations/Prosecution

Issue: You’re ineligible due to prosecution >₹2.5Cr tax evasion.

Solution: Cannot file LUT; must use Bond instead.


What If Rejected?

Step 1: Check rejection reason on portal (ARN status)
Step 2: Correct the issue
Step 3: Refile LUT immediately
Step 4: Usually approved in 1-3 days after correction


11. LUT for Goods vs. Services (Differences)

AspectGoods ExportServices Export
LUT filingSame processSame process
Invoice declarationMention LUTMention LUT
Additional docsShipping bill (Customs)No shipping bill (services have no Customs clearance)
GSTR-1 Table 6BEnter actual port code + shipping bill no.Use port code 000000; shipping bill: invoice no. or NA
FIRCRequired (foreign exchange receipt)Required
FEMA timeline9 months to realize proceeds9 months
E-way billYes (for movement within India)No

Key takeaway: Service exporters have simpler documentation (no Customs involvement).


12. Practical Compliance Tips for Exporters

✅ Tip 1: Create Annual Compliance Calendar

Set reminders:

  • April 1: File LUT for new FY
  • 11th/13th each month: File GSTR-1
  • 20th each month: File GSTR-3B
  • Quarterly: Review export vs. realization (FEMA)
  • December 31: File GSTR-9 (annual return)

✅ Tip 2: Standardize Export Invoice Template

Create template with:

  • Auto-fill: LUT declaration, ARN, place of supply
  • Mandatory fields pre-formatted
  • Version control (update annually with new LUT ARN)

✅ Tip 3: Maintain Export Register

Excel/Software tracking:

Invoice No.DateClientCountryValue (USD)Value (₹)LUT ARNFIRC DateStatus
EXP-00105-AprABC IncUSA$10,000₹8.5LAB123…20-AprRealized

✅ Tip 4: Coordinate with Accounts Team

Ensure:

  • Accounts team knows LUT is filed
  • Invoice format updated
  • GSTR-1 entries correct (Table 6B, not Table 4)
  • Books match GST returns

✅ Tip 5: Use Professional Help (If Complex)

Engage CA/GST expert if:

  • Multiple GSTINs across states
  • Both goods + services export
  • High-value exports (scrutiny risk)
  • Past GST issues/notices
  • First-time exporter (get it right from start)

13. Troubleshooting Guide

Issue 1: LUT Filed But Not Showing in System

Check:

  • ARN status (track application)
  • If approved, may take 24 hours to reflect

Solution: Wait 24-48 hours; if still not visible, raise ticket on GST helpdesk.


Issue 2: Export Invoice Rejected by Client (Wants IGST Invoice)

Rare: Some foreign clients insist on seeing tax.

Solution: Explain GST zero-rating; provide LUT copy + invoice with clear 0% mention. If client still insists, consult CA (may need special handling).


Issue 3: Bank Asking for Shipping Bill for Services Export

Issue: Bank forex dept unfamiliar with services export (no shipping bill exists).

Solution: Provide:

  • Export invoice
  • LUT copy
  • GSTR-1 (showing Table 6B entry)
  • Letter explaining services don’t have shipping bills

Issue 4: Forgot to File LUT, Already Exported

Solution:

  1. File LUT immediately (for future exports)
  2. For past exports without LUT:
    • Pay IGST + interest for those invoices
    • File refund application
    • Learn from mistake; set reminder for next FY

Issue 5: Client Delayed Payment Beyond 9 Months (FEMA Issue)

FEMA rule: Export proceeds must be received within 9 months.

Solution:

  • Apply to RBI for extension (before 9-month deadline)
  • If already delayed: Compounding application
  • Maintain proof of follow-up emails to client

14. Advanced Scenarios

Scenario 1: Mid-Year Business Start

Question: Started export business in September 2025. When to file LUT?

Answer: File immediately (September). LUT valid till March 31, 2026. Renew in April 2026.


Scenario 2: Multiple Services, Same Client

Question: Providing consulting + software to same US client. Single invoice or separate?

Answer: Can combine (both are services export) OR separate (for internal tracking). Both qualify under same LUT.


Scenario 3: Exporting to SEZ + Foreign Country

Question: Need separate LUTs?

Answer: No. Single LUT covers:

  • Exports to foreign countries
  • Supply to SEZ units/developers

Report separately in GSTR-1 (different tables: 6B for foreign, 8C for SEZ).


Scenario 4: Amendments to LUT

Question: Made mistake in LUT (wrong mobile number). Can I amend?

Answer: GST law doesn’t allow LUT amendment. If critical error, file fresh LUT. If minor (like contact update), inform dept via letter/update on portal if possible.


Scenario 5: LUT for Branch vs. HO

Question: Different GSTINs for different states. Separate LUTs?

Answer: Yes. Each GSTIN = separate LUT. Example: Delhi HO (GSTIN 07…) and Mumbai branch (GSTIN 27…) need 2 LUTs.


15. Expert Insights from AdvoFin Consulting

Over 500+ exporters we’ve assisted, here are patterns we notice:


Insight 1: April Rush Creates Errors

70% of LUT issues happen in April (last-minute rush).

Our recommendation: File LUT in first week of April (April 1-5), even if no confirmed orders yet.


Insight 2: Invoice Wording Saves Scrutiny

Exporters with clear LUT declaration on invoice face 80% fewer queries during audits.

Template we provide clients:

“Zero-rated supply for export under LUT ARN [Number] dated [Date] as per Section 16 of IGST Act, 2017 and Rule 96A of CGST Rules, 2017, without payment of Integrated Tax. Place of supply: [Country].”


Insight 3: Export Register Reduces FEMA Violations

Clients maintaining monthly export register have zero FEMA penalties over 3+ years.

Why: Proactive tracking ensures payment follow-up before 9-month deadline.


Insight 4: ITC Refund Success Rate Higher with Clean LUT

Exporters with:

  • ✅ Timely LUT filing
  • ✅ Proper invoice declarations
  • ✅ Complete FIRC documentation

Have 95% ITC refund approval rate (vs. 60% for those with gaps).


16. Conclusion: LUT is Your Export Lifeline

LUT is not just compliance—it’s cash flow optimization.

What proper LUT management gives you:

  • ✅ Zero GST blockage on exports
  • ✅ 18% cash flow improvement (vs. paying IGST)
  • ✅ Faster business scaling (money available for reinvestment)
  • ✅ Lower scrutiny (no refund applications)
  • ✅ Simpler operations (no refund tracking)
  • ✅ Better vendor relationships (can offer competitive pricing)

What poor LUT management costs:

  • ❌ 18% + interest + penalty on missed exports
  • ❌ 6-12 months refund wait
  • ❌ CA fees for refund applications (₹10-50K each)
  • ❌ Scrutiny notices and explanations
  • ❌ Stress and time waste

The 5-minute action you must take:

  1. Set calendar reminder: “File LUT by April 5” (recurring annually)
  2. Review current LUT status (if already filed)
  3. Update invoice template with LUT declaration
  4. Inform accounts team about LUT process
  5. Maintain export documentation folder

At AdvoFin Consulting, we help exporters with:

  • ✅ Annual LUT filing (all GSTINs)
  • ✅ Export invoice template creation
  • ✅ GSTR-1 filing (correct Table 6B reporting)
  • ✅ Export register maintenance
  • ✅ ITC refund applications
  • ✅ GST notice handling (export-related)
  • ✅ FEMA compliance coordination
  • ✅ Full export compliance calendar

Because 18% blocked cash flow is 18% less growth.


FAQs: LUT Filing for Exporters (30 Essential Questions)

Q1: What is LUT in GST?

A: LUT (Letter of Undertaking) is an annual declaration (Form GST RFD-11) that allows exporters to export goods/services without paying IGST upfront. It’s valid for one financial year (April-March) and must be renewed annually.


Q2: Is LUT mandatory for exporters?

A: Not mandatory, but highly recommended. Without LUT, you must pay 18% IGST on export invoices and then file refund applications (6-12 month wait). With LUT, you export at 0% GST with no cash blockage.


Q3: When should I file LUT for FY 2025-26?

A: File before April 5, 2025 (before issuing your first export invoice of the new FY). Ideal timeline: April 1-5. If you export on April 3 but file LUT on April 10, your April 3 invoice becomes IGST-liable.


Q4: Does LUT expire?

A: Yes. LUT is valid only for the financial year it’s filed for (April 1 – March 31). You must file a fresh LUT every April. It does NOT auto-renew.


Q5: How do I file LUT online?

A:

  1. Login to GST Portal (gst.gov.in)
  2. Services → User Services → Furnish LUT
  3. Select FY (e.g., 2025-26)
  4. Fill Form GST RFD-11 (auto-fill fields)
  5. Accept declarations
  6. Sign with DSC (companies/LLPs) or EVC (proprietors)
  7. Submit → Receive ARN instantly

Q6: What documents are required for LUT filing?

A: Minimal:

  • ✅ GSTIN (auto-filled)
  • ✅ PAN (auto-filled)
  • ✅ Authorized signatory details (name, PAN, mobile, email)
  • ✅ DSC (companies/LLPs) or Aadhaar OTP for EVC (proprietors)
  • ✅ Optional: Board resolution/authorization letter (if signatory not MD/proprietor)

Not required: Bank guarantee, export proof, IEC, trade license.


Q7: Is there a fee for filing LUT?

A: No. LUT filing is completely free. No government fees, no bank guarantee charges (BG requirement removed since 2018).


Q8: How long does LUT approval take?

A: Instant to 3 working days. 99% of LUTs are auto-approved by the system immediately. Rare cases (if flagged) may take 1-3 days for officer review.


Q9: Can I export services under LUT?

A: Yes! LUT covers both goods and services exports. Service exporters benefit equally—0% GST on export invoices.


Q10: What should I mention on export invoice under LUT?

A: Mandatory declaration:

“Supply meant for export under Letter of Undertaking (LUT) without payment of Integrated Tax as per Rule 96A of CGST Rules, 2017. LUT ARN: [Your ARN Number]. Place of supply is outside India.”

Also show:

  • Tax rate: 0% or NIL
  • IGST amount: ₹0
  • LUT ARN (from filing acknowledgment)

Q11: Where do I report LUT exports in GSTR-1?

A: Table 6B: Exports (Zero-rated supply without payment of tax – under LUT/Bond)

Not Table 6A (that’s for exports with IGST payment).
Not Table 4 (that’s for domestic taxable supplies).

Enter: Invoice number, date, value (₹), port code (000000 for services).


Q12: What if I forget to file LUT and already exported?

A: You become liable for 18% IGST + interest.

Solution:

  1. File LUT immediately (for future exports)
  2. For past exports without LUT:
    • Pay IGST + interest on those invoices
    • File refund application (Form RFD-01)
    • Wait 6-12 months for refund
  3. Set annual reminder to avoid repeat

Q13: Can I file LUT mid-year?

A: Yes. If you start exporting in September, file LUT in September. It will be valid till March 31. Renew in April for the next full FY.


Q14: Do I need separate LUT for each GSTIN?

A: Yes. If you have multiple GSTINs (different states), each GSTIN needs its own LUT.

Example:

  • Delhi office: GSTIN 07ABC… → LUT 1
  • Mumbai branch: GSTIN 27XYZ… → LUT 2

Q15: What is the difference between LUT and Bond?

A:

  • LUT: Annual declaration, no bank guarantee, free, for eligible exporters (99.9%)
  • Bond: Requires bank guarantee, cost involved, only for exporters ineligible for LUT (prosecuted for tax evasion >₹2.5 crores)

Most exporters use LUT.


Q16: Can I claim ITC refund with LUT?

A: Yes! LUT allows you to:

  1. Export at 0% GST (no IGST payment)
  2. AND claim refund of ITC (GST paid on inputs/input services)

File Form RFD-01 for ITC refund after GSTR-1 and GSTR-3B.


Q17: What if my LUT is rejected?

A: Rare (5% cases). Common rejection reasons:

  • Pending GST returns
  • Wrong financial year selected
  • DSC/signatory mismatch
  • Previous prosecution (>₹2.5Cr tax evasion)

Solution: Check rejection reason on portal (ARN status), correct issue, refile LUT.


Q18: Do I need LUT for supply to SEZ?

A: Yes, if you want to supply to SEZ units/developers without paying IGST. Same LUT covers both foreign exports and SEZ supplies.


Q19: Can I amend LUT after filing?

A: GST law doesn’t provide for LUT amendment. If critical error (like wrong FY), file a fresh LUT. If minor (contact update), inform department via letter or portal update if possible.


Q20: What documents should I maintain after filing LUT?

A: Export documentation folder:

  • ✅ LUT acknowledgment (with ARN)
  • ✅ All export invoices
  • ✅ Shipping bills (for goods) / Delivery proof (for services)
  • ✅ FIRC/SWIFT (foreign exchange receipts)
  • ✅ Bank statements (showing inward remittances)
  • ✅ GSTR-1 copies (Table 6B)
  • ✅ Export register (tracking all exports)

Keep for 6+ years (audit requirement).


Q21: What if foreign client pays late (beyond 9 months)?

A: FEMA violation (export proceeds must be realized within 9 months).

Solution:

  • Before 9 months: Apply to RBI for extension (with justification)
  • Already delayed: File compounding application
  • Maintain proof of follow-up emails to client

Q22: Can I use LUT if GST returns are pending?

A: System may flag/reject LUT if multiple returns pending. Best practice: File all pending GSTR-1/3B before applying for LUT.


Q23: Is LUT applicable for goods and services both?

A: Yes, same LUT covers:

  • Goods export
  • Services export
  • Mixed export (goods + services)
  • Supply to SEZ

Q24: What is LUT ARN?

A: ARN (Application Reference Number) = 17-character unique ID generated when you submit LUT. Format: AB12345678901234V.

Use: Reference this ARN on export invoices and in correspondence.


Q25: Can proprietorship file LUT using Aadhaar OTP?

A: Yes. Proprietorships and individuals can use EVC (E-Verification Code) via Aadhaar OTP instead of DSC (which is mandatory only for companies/LLPs).


Q26: What happens if I file LUT for wrong financial year?

A: LUT will be invalid for current FY exports. Solution: File correct FY LUT immediately. (Example: In April 2025, if you accidentally select 2024-25, refile for 2025-26.)


Q27: Do I need IEC (Import Export Code) to file LUT?

A: No. LUT filing doesn’t require IEC. However, for Customs clearance of goods exports, IEC is mandatory (separate from GST LUT).


Q28: Can I file LUT before starting export business?

A: Yes! Preventive filing allowed. Even if you haven’t finalized clients yet, you can file LUT in anticipation of exports. Valid for entire FY.


Q29: What if I export to both foreign country and SEZ?

A: Single LUT covers both. Report separately in GSTR-1:

  • Foreign exports: Table 6B
  • SEZ supplies: Table 8C (similar zero-rated treatment)

Contact AdvoFin Consulting to ensure your exports are 100% compliant and you never pay unnecessary IGST or lose refunds.


Disclaimer: This blog is for informational purposes only and does not constitute legal, tax, or financial advice. GST regulations are subject to amendments. Please consult a qualified Chartered Accountant or GST practitioner for your specific situation. AdvoFin Consulting is not liable for actions taken based solely on this content.

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