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:
- What is LUT (crystal clear explanation)
- Who should file LUT
- When to file (critical timelines)
- Step-by-step online filing process (2025 updated)
- Documents required
- LUT vs. Bond vs. IGST Refund route
- How to use LUT for invoicing
- Common mistakes & rejections
- LUT for goods vs. services
- Practical compliance tips
- 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:
| Benefit | Impact |
|---|---|
| Zero IGST payment | No cash outflow on export sales |
| No refund wait | Money not blocked for 6+ months |
| Faster cash flow | Can reinvest immediately |
| Simpler compliance | Just file GSTR-1, no refund application |
| Lower scrutiny | Refunds 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:
| Date | Action | Why |
|---|---|---|
| April 1-5 | File LUT for new FY | Before any export invoice |
| April 6+ | Start exporting under LUT | Safe, compliant |
| Throughout FY | Keep exporting | LUT valid till March 31 |
| March 31 | LUT expires | Need 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
✅ 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 → Services → User Services → Furnish 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
| Aspect | Details |
|---|---|
| What it is | Annual declaration (no bank guarantee) |
| GST payment | Zero (export at 0%) |
| Cash flow | Excellent (no blockage) |
| Refund needed | No (just ITC refund if applicable) |
| Renewal | Annual (every April) |
| Cost | Free |
| Processing time | Instant |
| Best for | All exporters (default choice) |
Option B: Bond (Bank Guarantee/Surety)
| Aspect | Details |
|---|---|
| What it is | Bond with bank guarantee |
| Who needs it | Prosecuted taxpayers (tax evasion >₹2.5Cr) |
| GST payment | Zero (export at 0%) |
| Cash flow | Good (no GST blockage, but bank charges for BG) |
| Cost | Bank guarantee fees (1-2% of BG amount annually) |
| Processing | 7-15 days (bank + GST approval) |
| Best for | Only those ineligible for LUT |
Option C: Export with Payment of IGST (Then Refund)
| Aspect | Details |
|---|---|
| What it is | Pay 18% IGST on invoice, claim refund later |
| GST payment | 18% upfront |
| Cash flow | Poor (₹18L blocked per ₹1Cr export) |
| Refund time | 60 days (legal); 6-12 months (reality) |
| Documentation | Heavy (shipping bills, bank certificates, etc.) |
| Scrutiny | High (every refund scrutinized) |
| Best for | Rarely 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)
| Aspect | Goods Export | Services Export |
|---|---|---|
| LUT filing | Same process | Same process |
| Invoice declaration | Mention LUT | Mention LUT |
| Additional docs | Shipping bill (Customs) | No shipping bill (services have no Customs clearance) |
| GSTR-1 Table 6B | Enter actual port code + shipping bill no. | Use port code 000000; shipping bill: invoice no. or NA |
| FIRC | Required (foreign exchange receipt) | Required |
| FEMA timeline | 9 months to realize proceeds | 9 months |
| E-way bill | Yes (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. | Date | Client | Country | Value (USD) | Value (₹) | LUT ARN | FIRC Date | Status |
|---|---|---|---|---|---|---|---|---|
| EXP-001 | 05-Apr | ABC Inc | USA | $10,000 | ₹8.5L | AB123… | 20-Apr | Realized |
✅ 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:
- File LUT immediately (for future exports)
- 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:
- Set calendar reminder: “File LUT by April 5” (recurring annually)
- Review current LUT status (if already filed)
- Update invoice template with LUT declaration
- Inform accounts team about LUT process
- 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:
- Login to GST Portal (gst.gov.in)
- Services → User Services → Furnish LUT
- Select FY (e.g., 2025-26)
- Fill Form GST RFD-11 (auto-fill fields)
- Accept declarations
- Sign with DSC (companies/LLPs) or EVC (proprietors)
- 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:
- File LUT immediately (for future exports)
- For past exports without LUT:
- Pay IGST + interest on those invoices
- File refund application (Form RFD-01)
- Wait 6-12 months for refund
- 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:
- Export at 0% GST (no IGST payment)
- 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.
