LUT Filing Assistance

Export Without Payment of IGST Through Proper LUT Filing

If your business exports goods or services from India, or makes zero-rated supplies to an SEZ unit or SEZ developer, one of the most important GST compliances is filing a Letter of Undertaking (LUT). A valid LUT allows eligible registered persons to make zero-rated supplies without payment of Integrated GST (IGST), thereby avoiding blockage of working capital and the need to first pay tax and then claim refund.

At CLEANFILINGS, we assist businesses, service exporters, manufacturers, traders, freelancers, IT companies, consultants, and other eligible exporters with GST LUT filing, annual LUT renewal, document review, RFD-11 filing support, and practical compliance guidance for export transactions under GST.

What is LUT under GST?

LUT means Letter of Undertaking. It is a declaration filed by an eligible registered person in Form GST RFD-11 on the GST portal for making zero-rated supplies without payment of IGST. In simple terms, instead of paying IGST on exports or SEZ supplies and then claiming a refund, the exporter can furnish LUT and export without upfront tax payment.

LUT is primarily used for:

✔ Export of goods without payment of IGST
✔ Export of services without payment of IGST
✔ Supply to SEZ unit or SEZ developer without payment of IGST, where treated as zero-rated supply

Legal Basis of LUT

LUT filing is linked to the zero-rated supply framework under the GST law. Broadly:

• Zero-rated supplies include exports of goods or services and supplies to SEZ unit / SEZ developer.
• Eligible taxpayers may supply such goods or services without payment of IGST by furnishing LUT in Form GST RFD-11.

This compliance operates under the IGST Act read with Rule 96A of the CGST Rules, and the filing is done online on the GST portal.

Why LUT Filing is Important

1. Export without payment of IGST

The biggest advantage of LUT is that it allows you to export goods or services or make eligible SEZ supplies without paying IGST upfront.

2. Better cash flow

If LUT is not filed, the exporter may need to pay IGST first and then claim refund. LUT helps avoid this working-capital blockage.

3. Simpler export compliance

For many exporters, LUT is the most practical route because it reduces refund dependency and makes recurring export transactions smoother.

4. Useful for service exporters and freelancers

IT service providers, software exporters, consultants, agencies, freelancers, and digital businesses serving foreign clients often use LUT to avoid charging / paying IGST on export of services, subject to fulfilment of export conditions.

Who Can File LUT?

LUT can generally be furnished by any GST-registered person making zero-rated supplies, including:

✔ exporters of goods
✔ exporters of services
✔ suppliers to SEZ unit / SEZ developer
✔ IT / software / SaaS businesses serving overseas clients
✔ consultants / freelancers exporting services
✔ manufacturers exporting finished goods
✔ merchant exporters / trading exporters
✔ e-commerce sellers exporting products internationally

The general disqualification is where the person has been prosecuted for any offence under GST or an existing law involving tax evasion above the prescribed threshold.

Who Cannot Use LUT in Practical Terms?

A person may not be able to use LUT if:

• the legal eligibility conditions for furnishing LUT are not satisfied, or
• the person falls in a category that is required to furnish bond instead of LUT in the relevant circumstances, or
• the person is not making zero-rated supplies at all.

Also, composition taxpayers generally cannot export under the normal LUT route because composition dealers are restricted in the nature of supplies they can make under GST.

What Supplies Are Covered by LUT?

LUT is relevant for zero-rated supplies, mainly:

1. Export of Goods

Where goods are exported outside India and the exporter wants to export without payment of IGST.

2. Export of Services

Where services qualify as export of services under GST and the exporter wants to supply them without payment of IGST.

3. Supply to SEZ Unit / SEZ Developer

Supplies made to SEZ units or developers can also be covered as zero-rated supplies, subject to the GST framework and documentary conditions.

LUT vs IGST Refund Route – Important Difference

There are generally two broad ways in which zero-rated supplies may be handled under GST:

Option 1 – Export / zero-rated supply under LUT without payment of IGST

Under this route:

• LUT is filed in Form GST RFD-11
• goods / services are supplied without payment of IGST
• exporter can generally claim refund of eligible unutilised ITC, subject to law and conditions

Option 2 – Export on payment of IGST and then claim refund

Under this route:

• IGST is paid on the export / zero-rated supply
• refund of the IGST paid is claimed / processed as per GST law

For many exporters, the LUT route is preferred because it avoids upfront IGST outflow.

Is LUT Mandatory for Export Without IGST?

If an exporter wants to make zero-rated supplies without payment of IGST, then furnishing LUT is the usual route for eligible taxpayers. If LUT is not furnished, the exporter may have to use the bond / payment-and-refund route, depending on the facts and the applicable legal position.

Validity of LUT

LUT is valid for one financial year

A Letter of Undertaking is generally valid for one financial year. Therefore, it needs to be furnished every year if the taxpayer wants to continue exporting without payment of IGST in the new financial year.

Example

If LUT is filed for FY 2026–27, it will generally cover the period 1 April 2026 to 31 March 2027. A fresh LUT should be filed for the next financial year if zero-rated supplies are to continue without payment of tax.

Latest Practical Position for FY 2026–27

The GST portal has enabled LUT filing for FY 2026–27, and businesses intending to make zero-rated supplies in that year should furnish LUT in advance to avoid disruption in export operations from the start of the year.

Practical compliance approach

Although the law works on the basis of furnishing LUT for the relevant financial year, businesses commonly file / renew LUT before the beginning of the new financial year or before the first export / SEZ supply of that year to ensure uninterrupted coverage. Guidance materials and portal resources commonly refer to filing it before the start of the year for smooth compliance.

When Should LUT Be Filed?

As a practical compliance approach, LUT should ideally be filed:

✔ before the beginning of the financial year in which zero-rated supplies will be made, or
✔ before the first export / first zero-rated supply of that year

This helps ensure that export invoices / supplies are covered from day one of the financial year.

Time Conditions After Export Under LUT

LUT filing is not the end of compliance. Once supplies are made under LUT, certain conditions must still be met.

1. Export of goods

Where goods are supplied under LUT, they should generally be exported within the prescribed time from the date of invoice, unless extended by the competent authority. Guidance material commonly refers to a 3-month export timeline for goods under Rule 96A, subject to permitted extension.

2. Export of services

For export of services under LUT, the exporter should receive payment in accordance with the prescribed FEMA / RBI timelines and satisfy export-of-services conditions. Recent guidance materials note that the realisation period is linked to the FEMA-permitted period for receipt of export proceeds.

If the export conditions are not fulfilled within the prescribed framework, the tax implications need to be reviewed carefully.

Documents / Details Required for LUT Filing

The LUT filing process is online, but certain information and supporting details are generally required.

Common details required:

• GSTIN and GST portal login credentials
• Legal name and trade name of business
• Financial year for which LUT is being filed
• Name, address, and occupation details of two witnesses
• Authorised signatory details
• DSC / EVC, as applicable
• Previous LUT copy / ARN, if filing for renewal and required for reference
• Authorisation / board resolution / letter of authority, where needed internally for the signatory

In some practical cases, it is also useful to keep ready:

• IEC details for goods exporters
• export profile / nature of export activity
• previous LUT acknowledgement, if any

Portal guidance and practical filing resources consistently show witness details and year selection as core parts of the filing process.

How LUT is Filed on GST Portal

LUT is filed online on the GST portal in Form GST RFD-11.

Step-by-step process

Step 1 – Login to GST portal

Login at the GST portal using the registered GST credentials.

Step 2 – Navigate to LUT filing section

Go to:
Services → User Services → Furnish Letter of Undertaking (LUT)

Step 3 – Select the financial year

Choose the financial year for which LUT is being furnished, for example FY 2026–27.

Step 4 – Fill declaration and witness details

Complete the declaration, fill in the details of two witnesses, and confirm the prescribed undertakings.

Step 5 – Sign and submit

Submit the LUT using DSC or EVC, as applicable to the taxpayer / authorised signatory.

Step 6 – ARN generation / acknowledgement

On successful submission, an acknowledgement / ARN is generated on the portal. The LUT acknowledgement should be saved for records.

Common Undertakings in LUT

While filing LUT, the exporter generally undertakes compliance with conditions relating to zero-rated supplies, including export / realisation conditions and payment of tax with interest where the prescribed conditions are not fulfilled within the allowed period. Practical GST guidance for LUT filing reflects these undertakings as part of the online declaration process.

LUT Renewal / Annual Filing Support

Since LUT is valid only for one financial year, businesses that export regularly should track annual LUT renewal.

We assist with:
✔ fresh LUT filing for a new exporter
✔ annual LUT renewal for the next financial year
✔ correction / practical guidance where LUT was missed at the start of the year
✔ review of export invoices and LUT coverage period
✔ assistance for goods exporters, service exporters, and SEZ suppliers

LUT Filing for Service Exporters – Important Practical Relevance

LUT is especially useful for service exporters, including:

✔ software / SaaS businesses
✔ digital agencies
✔ consultants and advisors
✔ freelancers serving overseas clients
✔ back-office / BPO / support service providers
✔ marketing / design / IT / development service exporters

For such businesses, LUT can be an important compliance tool to avoid payment of IGST on export of services, subject to satisfaction of export-of-services conditions and receipt of export proceeds as per law.

LUT Filing for Goods Exporters – Important Practical Relevance

LUT is also widely used by:

✔ manufacturers exporting products
✔ merchant exporters
✔ wholesalers / traders exporting goods
✔ Amazon / marketplace exporters
✔ food exporters, apparel exporters, handicraft exporters, machinery exporters, etc.

In goods export cases, timely LUT filing is important so that export invoices are issued under valid LUT coverage and working capital is not unnecessarily blocked.

Common Situations Where We Help

We commonly assist in the following LUT matters:

✔ first-time LUT filing for a new exporter
✔ LUT renewal for the next financial year
✔ LUT filing for service exporters and IT companies
✔ LUT filing for goods exporters and merchant exporters
✔ LUT for supplies to SEZ unit / SEZ developer
✔ practical review where export has started but LUT was not filed timely
✔ guidance on export under LUT vs payment of IGST route
✔ assistance with GST portal filing and acknowledgment download

Why LUT Filing Should Be Done Carefully

LUT is a simple-looking compliance, but it directly impacts export GST treatment. Incorrect or delayed handling can create issues such as:

• export invoices being issued before LUT coverage is in place
• confusion between LUT route and IGST payment route
• mismatch in treatment of export / zero-rated supplies in GST returns
• missed annual renewal causing compliance gaps
• issues in service export cases where payment realisation conditions are not tracked

A proper filing and record process helps avoid these issues.

What Do We Provide?

Our LUT Filing Assistance may include:

✔ applicability review for LUT vs other export GST route
✔ filing of LUT in Form GST RFD-11
✔ annual LUT renewal support
✔ assistance for exporters of goods and services
✔ assistance for SEZ zero-rated supply cases
✔ guidance on document / witness / signatory requirements
✔ LUT acknowledgement and record support
✔ practical support for GST export compliance linked with LUT

Why Choose CLEANFILINGS?

✔ practical GST support for exporters, service providers, traders, and startups
✔ assistance in filing LUT accurately and on time for the relevant financial year
✔ useful for both goods exporters and service exporters
✔ support for recurring annual LUT compliance and renewal
✔ practical understanding of GST, export compliance, and zero-rated supply framework
✔ pan-India professional assistance

If your business exports goods or services or supplies to SEZs and wants to avoid payment of IGST on zero-rated supplies, LUT filing is one of the most important annual GST compliances. CLEANFILINGS can assist you with the complete LUT filing process from review to submission.

CLEANFILINGS PRIVATE LIMITED

Smart Filings. Clean Future.