Goods & services exporters · Hyderabad · Bangalore
Export compliance: LUT, IGST refund vs ITC route, 9-month FEMA realisation, RoDTEP — the four issues that stall working capital.
Export tax compliance has four distinct moving parts — GST LUT, refund route optimisation, FEMA realisation monitoring, and DGFT incentive claims. A mistake in any one delays cash by months.
The four pillars
Export compliance that unlocks working capital.
LUT, refund route, FEMA realisation, and DGFT incentives are independent compliance tracks — each with its own deadlines, forms, and consequences for delay.
LUT — mandatory before each export supply
A GST-registered exporter must file a Letter of Undertaking (LUT) before making zero-rated export supplies without paying IGST. The LUT is renewed annually (financial year basis) and must be active before the first export invoice of the year — not after. A lapsed LUT means IGST becomes payable on the export invoice, which creates a GST mismatch in the shipping bill and delays customs clearance.
Annual LUT renewal · Rule 96A · active before first export of FY
IGST refund vs ITC drawback — two routes, not one
An exporter has two routes for recovering the GST embedded in export costs. Route 1: pay IGST on exports, claim refund of IGST paid. Route 2: export under LUT (no IGST), claim refund of accumulated ITC. The routes have different refund timelines, documentary requirements, and treatment of restricted credits. Choosing the wrong route for your supply chain can delay working capital by months. Most service exporters should be on Route 2.
Rule 89 ITC refund · Rule 96 IGST refund · different timelines and docs
FEMA — 9-month export realisation period
Under FEMA regulations, export proceeds must be realised (received in India) within 9 months of the date of shipment (or date of invoice for service exports). A delay beyond 9 months without RBI approval constitutes a FEMA violation. Many exporters miss this when dealing with slow-paying overseas buyers. The solution is to either obtain an extension from the Authorised Dealer before the deadline or apply for compounding. Missing the deadline retrospectively is harder to fix.
9-month realisation · AD bank extension before deadline · FEMA Master Direction
RoDTEP — the successor to MEIS
The Remission of Duties and Taxes on Exported Products (RoDTEP) scheme refunds embedded taxes that are not otherwise refunded — state levies, mandi cess, power charges, fuel taxes. RoDTEP rates are product-specific (HS code based) and credited as scrips in ICEGATE. Many exporters either don't claim RoDTEP at all, or claim at the wrong HS code rate. Unlike MEIS, RoDTEP is WTO-compliant and is not a duty drawback — it is remission of embedded costs.
HS code specific rates · ICEGATE scrips · not drawback · WTO compliant
Our engagement
Five tracks for a compliant exporter.
LUT filing and renewal
Annual LUT on the GST portal before the financial year begins — linked to your GSTIN and authorized signatory.
Annual (April)
GST refund filing (Route 1 or 2)
IGST refund on zero-rated supplies (Route 1) or ITC accumulation refund under LUT (Route 2) — documentary compliance, GSTR reconciliation, and ARN tracking.
Monthly / quarterly
FEMA export realisation compliance
9-month deadline tracking per shipment, AD bank extension applications before deadline, EDPMS monitoring.
Ongoing
RoDTEP and DGFT incentive claims
HS code review for correct RoDTEP rate, ICEGATE scrip application, Advance Licence and EPCG compliance.
Per shipment / annual
Income tax — export deductions
Section 10AA SEZ deduction (if applicable), transfer pricing on related-party exports, ITR-3 or ITR-6 with correct export income treatment.
Annual
Common questions
Statute-cited answers.
I forgot to renew my LUT before April. Can I export anyway?
Not under zero-rated LUT export — your options are limited until you file the LUT. If you have already issued export invoices without a valid LUT for the current financial year, technically IGST is payable on those exports. You can file the LUT now and apply for condonation, but there is no automatic waiver — the GST officer has discretion. The safest approach is to file the LUT immediately and, for invoices already issued without it, consider paying IGST and claiming the IGST refund (Route 1). The LUT is filed online on the GST portal under Services → Refunds → Letter of Undertaking — it takes minutes once the prior year's LUT compliance is clear.
Should we export under LUT (Route 2) or pay IGST and claim refund (Route 1)?
For most exporters, Route 2 (LUT + ITC refund) is better because it avoids paying IGST upfront and tying up cash. Under Route 1, you pay IGST at the time of export and wait for the refund — which can take 2-3 months. Under Route 2, you accumulate ITC on inputs and claim a refund of that ITC. However, Route 2 requires meticulous ITC reconciliation with GSTR-2B, and not all ITC is refundable (restricted credits under rule 89(5) for services can only be claimed at a formula-derived rate). For goods exporters with straightforward supply chains, Route 2 is generally preferred. Service exporters should compute the effective refund rate under both routes before choosing.
Our US buyer pays slowly — sometimes after 10-11 months. Is that a FEMA problem?
Yes. Under FEMA Master Direction on Export of Goods and Services, export proceeds must be realised within 9 months of the date of shipment for goods (or date of invoice for software/services). If your buyer is paying after 10-11 months, you are in violation of FEMA for those invoices unless you have obtained an extension from your Authorised Dealer (AD) bank before the 9-month deadline. The extension can be granted by the AD bank for genuine trade reasons without RBI approval in most cases — but the application must be made before the deadline, not after. Retrospective condonation requires RBI intervention and can involve compounding proceedings.
What is RoDTEP and how is it different from duty drawback?
RoDTEP (Remission of Duties and Taxes on Exported Products) refunds the embedded taxes on exported goods that are not otherwise recovered — state VAT on fuel, mandi cess, electricity duty, stamp duty on export documents. It is product-specific, with rates determined by HS code. The credit is issued as a scrip in ICEGATE which can be used to pay Basic Customs Duty. It is not a cash refund. Duty Drawback, on the other hand, refunds Central Excise and Customs duties embedded in inputs. The two schemes are separate and can both be claimed where applicable. MEIS (the predecessor scheme) has been discontinued and subsumed into RoDTEP for most products.
We have an SEZ unit. Can we claim a tax deduction on export profits?
Yes. Section 10AA of the Income-tax Act provides a deduction on profits from an SEZ unit for export of goods or services. The deduction is 100% of export profits for the first 5 years, 50% for the next 5 years, and 50% of the amount transferred to a Special Economic Zone Re-investment Reserve for the following 5 years. The deduction is subject to the MAT provisions under section 115JB. Key condition: the deduction applies only to profits derived from exports — not to domestic sales — and requires the profits to be computed separately for each SEZ unit.
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Export compliance review — 45 minutes.
We review LUT status, refund route optimisation, FEMA realisation position and DGFT incentive eligibility. No obligation until you know your full compliance picture.
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