Harun Raaj & AssociatesHarun Raaj & Associates

Export & Customs · Step 4 of 6

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Exporters — Tax, GST & FEMA

GST LUT Filing & Export Refund

GST LUT & Export Refund

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SCOPEConfirmed in writing
TYPICAL TIMELINE7–10 days
DOCS REQUIRED3 documents

Regulatory Framework

Integrated Goods and Services Tax Act, 2017: Section 16(1)(a) classifies export of goods or services as a "zero-rated supply." Section 16(3) gives the exporter two routes to give effect to this zero-rating: (a) export under a Letter of Undertaking (LUT) or bond without payment of integrated tax and claim refund of unutilised input tax credit, or (b) export on payment of integrated tax and claim refund of the tax paid. Rule 96A of the CGST Rules, 2017 prescribes the procedure and conditions for furnishing the LUT/bond, including the requirement to realise export proceeds within the period allowed under FEMA and to pay tax with interest if this condition is not met.

Central Goods and Services Tax Act, 2017: Section 54 governs refund claims generally, and Section 54(6) specifically entitles an exporter to a 90% provisional refund of the claimed amount within 7 days of acknowledgment of the refund application, pending final verification. Rules 89 and 96 of the CGST Rules prescribe the application procedure for refund of unutilised ITC (Rule 89) and refund of IGST paid on exports (Rule 96), respectively. LUT filing and refund claims should be tracked against these provisions to avoid working-capital lock-up beyond the statutory turnaround.

Overview

GST LUT and export refund is the machinery that keeps exporting businesses' cash flow intact under GST. Zero-rated supplies — exports — can be made without paying IGST by filing a Letter of Undertaking under Rule 96A of the CGST Rules 2017, in which case the exporter's input tax credit accumulates and is refunded under Section 54 of the CGST Act read with the refund rules. Alternatively, the exporter can pay IGST on the export and claim the automatic refund. Either way, the exporter is entitled to the tax paid on inputs — the question is the documentation.

The LUT is the operational key for exporters: filed at the start of the year, it lets the exporter ship without blocking working capital in IGST. The refund claim — the accumulated input tax credit on the zero-rated supplies — is where the cash actually returns. The claim requires the returns, the invoices, the shipping bills and the LUT to all be in order, and the department's scrutiny of refund claims is detailed: a mismatch in the shipping bill details, a return not filed, or an invoice missing from the reconciliation sends the claim back.

Skipping the LUT or filing the refund late costs real cash flow. Without the LUT, the exporter pays IGST on every export and waits for the refund; a refund claim filed without the complete documentation waits months; and an exporter who never claims the credit simply loses the input tax into the government's hands.

This service is for exporters managing their GST export position. We file the LUT under Rule 96A of the CGST Rules 2017, reconcile the zero-rated supplies, prepare and file the refund claims under Section 54 of the CGST Act, respond to the department's queries and scrutiny, and keep the export position running so the input tax credit comes back on schedule.

How It Works

  1. 1

    LUT Filing

    We file the Letter of Undertaking under Rule 96A of the CGST Rules 2017 for the year.

    Harun Raaj & Associates does this1-2 days
  2. 2

    Zero-Rated Reconciliation

    We reconcile the zero-rated supplies, returns and the input tax credit position.

    Harun Raaj & Associates does this3-5 days
  3. 3

    Refund Claim Preparation

    We prepare the refund application under Section 54 of the CGST Act with the shipping bill and invoice evidence.

    Harun Raaj & Associates does this1 week
  4. 4

    Filing & Department Processing

    We file the claim and follow the department's processing and scrutiny.

    Harun Raaj & Associates does this2-8 weeks
  5. 5

    Credit & Query Support

    We confirm the refund credit and answer departmental queries and deficiencies.

    Harun Raaj & Associates does thisAs needed

Frequently Asked Questions

When must an exporter file an LUT instead of paying IGST on exports?
Any registered person exporting goods or services without payment of integrated tax must furnish a Letter of Undertaking in Form RFD-11 under Rule 96A of the CGST Rules 2017, read with Section 16(3)(a) of the IGST Act 2017. Without a valid LUT for the financial year, the exporter must pay IGST upfront and then claim a cash refund — the LUT route eliminates that outflow entirely.
What is the time limit to file a GST refund claim for exports, and which form is used?
A refund application under Section 54(1) of the CGST Act 2017 must be filed within two years from the relevant date. For export of goods under the LUT route, the relevant date is the date the shipping bill is filed with customs. The application is filed in Form RFD-01 on the GST portal, supported by GSTR-1 shipping bill data and GSTR-3B ITC details.
What is the relevant date for a services export refund when foreign remittance is delayed?
For export of services, the relevant date under Section 54(14) of the CGST Act 2017 read with Explanation (2)(b) is the earlier of: (i) date of receipt of payment in convertible foreign exchange (or INR where RBI permits), or (ii) date of issue of the invoice. If remittance arrives months after invoicing, the invoice date governs the two-year limitation — so filing cannot be deferred until receipt of payment.
Can merchant exporters and SEZ units use the LUT route?
SEZ developers and SEZ units are covered by Section 16(1)(b) of the IGST Act 2017 (zero-rated supply) and may furnish an LUT under Rule 96A. Merchant exporters purchasing goods for export can avail the concessional 0.1% GST rate under Notification No. 40/2017-CT(Rate) and 41/2017-IGST(Rate), but the supplier must hold a valid export order and the merchant must hold a valid LUT and GSTIN; the shipping bill must be linked in GSTR-1 to close the export chain.
What happens if export proceeds are not realised within the RBI-prescribed period after filing under LUT?
Rule 96A(1) of the CGST Rules 2017 requires export proceeds to be realised within the period prescribed under FEMA 1999 — generally 9 months for goods exports as per RBI Master Direction on Export of Goods and Services (extendable by the AD bank). If proceeds are not realised in time, the LUT is treated as void for that supply and the exporter must pay the IGST that would have been due, along with interest at 18% per annum under Section 50 of the CGST Act 2017 from the date of export.

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