GST LUT Form Filing Services

A Letter of Undertaking (LUT) under GST is a formal undertaking in Form GST RFD-11 filed by an eligible registered person who intends to make zero-rated supplies — exports of goods or services, or supplies to a Special Economic Zone (SEZ) developer or unit — without payment of integrated tax (IGST). It is governed by Section 16 of the IGST Act, 2017 read with Section 54 of the CGST Act and Rule 96A of the CGST Rules, 2017, along with CBIC Notifications that prescribe the eligibility, procedure, and consequences of LUT-backed exports. The LUT essentially replaces the earlier bank-guarantee-backed bond route for most eligible exporters, allowing them to export zero-rated without blocking working capital in IGST payment and subsequent refund cycles.

An LUT is financial-year specific — a fresh LUT must be filed on the GST portal before the start of every financial year and remains valid from the date of its acceptance until 31st March of that financial year. It covers all eligible zero-rated outward supplies during the year as long as the conditions of Rule 96A are satisfied, the exporter has not been prosecuted for tax evasion of Rs. 2.5 crore or above under the CGST Act, IGST Act, or any earlier law, and the exporter furnishes an undertaking to complete the export of goods within 3 months of the date of invoice (or such extended period allowed by the Commissioner), and to complete the realisation of foreign exchange for export of services within 1 year of the invoice date (or such extended period). Non-compliance with these timelines converts the supposedly zero-rated supply into a taxable one, with IGST and interest becoming payable — a commercially painful outcome that a well-managed LUT process is specifically designed to prevent.

Our GST LUT Form Filing Services cover end-to-end handling of RFD-11 — from eligibility assessment, preparation of the undertaking, witness arrangement and KYC, filing on the GSTN portal, ARN tracking, mapping LUT reference across ERP / e-invoicing / e-way bill systems, annual renewal, and full support in case of non-realisation or breach consequences under Rule 96A(1) — so that zero-rated exports continue without IGST outflow, working capital stays protected, and every LUT filing is defensible on a multi-year horizon.

Form RFD-11

Letter of Undertaking

1 Financial Year

Validity of each LUT

Rule 96A

3 months / 1 year rule

Rs. 2.5 Cr

Prosecution disqualifier

Laws & Frameworks We Work Under

IGST Act – Sec 16

CGST Act – Sec 54

CGST Rules – Rule 96A

CGST Rules – Rule 89

Form GST RFD-11

Form GST RFD-01

CBIC Not. 37/2017-CT

Master Circular on Refund

Main Zero-Rated Supply Scenarios Covered by LUT

Export of Goods

Physical Export of Goods

Export of goods out of India — directly by exporter or through a merchant exporter — without IGST.

Direct export
Merchant exporter
EPCG / Advance Auth
EOU / STP / EHTP
Shipping bill linkage
3-month export window

Export of Services

Cross-border IT, ITES, consulting, engineering, and other services qualifying as export under IGST Act.

IT / ITES exports
Consulting services
Engineering & design
FIRC / BRC evidence
1-year realisation
POS mapping

SEZ Supplies

Supplies to SEZ Unit / Developer

Supply of goods or services to SEZ units and developers for authorised operations without IGST.

SEZ unit supplies
SEZ developer supplies
Endorsed invoices
Authorised operations
Bill of export
Zero-rated treatment

Deemed Exports

Deemed Exports Interplay

Guidance on LUT relevance for deemed exports and merchant exporter transactions under Rule 89.

0.1% rate supplies
Advance Authorisation
EPCG holders
Supplier / recipient refund
Notification 40/41-CT
Documentation pack

E-Commerce Exports

E-Commerce & Courier Exports

LUT for e-commerce exports through postal, courier, and marketplace routes with PBE / CSB filings.

Courier Shipping Bill (CSB-V)
Postal Bill of Export
Marketplace exports
D2C exports
Low-value shipments
FEMA coordination

Breach & Renewal

Non-Realisation & Renewal

Handling of LUT renewal and consequences where export / realisation timelines are breached.

Annual renewal
IGST on breach
Interest computation
Extension requests
Re-credit on realisation
Bond + BG alternative

Key LUT Concepts at a Glance

RFD-11

LUT Form

Standard form on GST portal for filing the undertaking — signed with DSC / EVC.

Rule 96A Online

Section 16 IGST

Zero-Rated Supply

Exports and SEZ supplies treated as zero-rated — with IGST or under LUT without IGST.

Exports SEZ

Rule 96A

Export Time Limits

3 months for export of goods from invoice date; 1 year for realisation of export of services.

3 Months 1 Year

Witnesses

2 Independent Witnesses

LUT requires signatures of two independent witnesses with name, address, and occupation.

Witness 1 Witness 2

Eligibility

Prosecution Bar

Not prosecuted for tax evasion of Rs. 2.5 crore or above under GST / earlier laws.

Clean Record Self-Declared

ARN

Acknowledgement

LUT is deemed accepted on the portal on submission — an ARN is generated automatically.

Auto-Accept ARN

Bond + BG

Alternative Route

Ineligible exporters must furnish a bond with bank guarantee (typically 15%) for zero-rated supplies.

Bond BG 15%

Consequence

Breach of Conditions

Failure to export / realise in time leads to IGST plus interest, recoverable under Rule 96A(1).

IGST + Int Recovery

What Our LUT Filing Engagement Covers

Eligibility

Eligibility & Readiness Review

Confirm eligibility under Rule 96A, check prosecution record, and assess past compliance history.

Rule 96A eligibility check
Prosecution declaration
Prior LUT review
Notice / demand scan
ERP mapping
Witness arrangement

Filing

Preparation & Portal Filing

End-to-end RFD-11 preparation and filing with DSC / EVC, plus ARN capture.

RFD-11 drafting
Witness KYC
Portal upload
DSC / EVC signing
ARN download
Board resolution / POA

Run

Lifecycle & Breach Management

Annual renewal reminders, breach monitoring, extension requests, and consequence handling.

Renewal calendar
Realisation tracker
FIRC / BRC control
Extension applications
IGST + interest computation
Refund claim on realisation

Our GST LUT Filing Services

Eligibility Assessment

Review of eligibility under Rule 96A, past prosecution record, and compliance standing.

RFD-11 Preparation

Preparation of the Letter of Undertaking, witness KYC, and board resolution / POA.

Portal Filing & ARN

Filing on the GSTN portal with DSC / EVC and capturing the ARN for records.

Annual Renewal

Proactive renewal before the start of every financial year to avoid IGST exposure on exports.

Bond + BG Route

Preparation and filing for ineligible exporters through the bond with bank guarantee route.

Export Realisation Tracking

Monitoring 3-month / 1-year Rule 96A timelines with FIRC / BRC and shipping bill reconciliation.

Breach Consequence Handling

IGST + interest computation, payment, and re-credit mechanism where breach occurs.

Refund & ICEGATE Support

Support for IGST refund on exports, unutilised ITC refund under RFD-01, and ICEGATE reconciliation.

When You Need Expert LUT Filing Support

New Exporter

First-time exporter who has just registered under GST and wants to avoid IGST blockage.

Annual Renewal Due

Existing LUT expiring on 31st March — fresh LUT must be in place before 1st April.

Service Exporters

IT / ITES / consulting exporters needing 1-year realisation monitoring and FIRC discipline.

SEZ Suppliers

DTA suppliers to SEZ units / developers seeking zero-rated treatment without IGST.

Multi-GSTIN Exporters

Exporters with GSTINs across multiple states requiring separate LUTs for each GSTIN.

Breach Suspected

Export not completed within 3 months or forex not realised within 1 year — rectification needed.

E-Commerce Exporters

D2C and marketplace exporters using CSB-V / PBE routes needing LUT-aligned documentation.

Prosecution Bar

Earlier tax dispute crossing Rs. 2.5 crore threshold — Bond + Bank Guarantee route applies.

Information & Documents Needed for LUT

Entity Data

GSTIN certificate
PAN of entity
Certificate of incorporation
MOA / AOA / partnership deed
Authorised signatory list
Board resolution / POA
DSC of signatory

Witness Data

Witness 1 & 2 PAN
Witness address proof
Witness occupation
Witness contact details
Independence confirmation
Prior LUT KYC files
Signed declaration

Operational & Evidence

IEC code
Prior LUT / ARN
Sample export invoice
FIRC / BRC files
Shipping bills / bill of export
Export contract / PO
FEMA documentation

Our End-to-End LUT Filing Approach

Eligibility Check

Review of Rule 96A eligibility, prosecution record, and past LUT / export compliance.

Documentation

Witness KYC, board resolution, authorised signatory confirmation, and evidence pack.

Portal Filing

Preparation and filing of Form RFD-11 on the GSTN portal with DSC / EVC.

ARN & Archival

ARN capture, LUT mapping in ERP / e-invoice / e-way bill systems, and archival.

Lifecycle Control

Renewal calendar, realisation tracker, and breach / refund support through the year.

Why Choose Us for GST LUT Filing

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Zero IGST outflow on exports

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End-to-end RFD-11 expertise

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Proactive annual renewal

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Rule 96A timeline tracking

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Multi-GSTIN coordination

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Bond + BG alternative route

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Breach consequence handling

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Seamless refund continuity

FAQs on GST LUT Form

What is an LUT under GST and who should file it?

A Letter of Undertaking (LUT) under GST is a formal undertaking in Form GST RFD-11 filed by a registered person to make zero-rated supplies — exports of goods or services, or supplies to a Special Economic Zone (SEZ) developer or unit — without payment of integrated tax (IGST). It is governed by Section 16 of the IGST Act read with Rule 96A of the CGST Rules. Any registered person undertaking zero-rated supplies should ordinarily file an LUT before the start of each financial year to avoid the working-capital blockage that would otherwise arise from paying IGST on exports and then seeking refund. Eligibility is restricted by a prosecution bar: a person prosecuted for tax evasion of Rs. 2.5 crore or above under the CGST Act, IGST Act, or any earlier law cannot use LUT and must instead furnish a bond with bank guarantee.

What is the validity of an LUT and does it need annual renewal?

An LUT is financial-year specific. Once filed, it remains valid from the date of its acceptance until 31st March of that financial year. A fresh LUT must therefore be filed every year, ideally before 1st April, to ensure that zero-rated supplies made during the new financial year are covered. If the LUT is not renewed in time, exports made during the unprotected period are technically not covered by an active LUT and the department can insist on IGST being paid on those supplies, with a follow-on refund claim being the only remedy — which is commercially inefficient. A clean LUT renewal process, kicking off in February each year, is far cheaper than cleaning up an accidental gap later.

What are the time limits to complete exports and realise payment under Rule 96A?

Under Rule 96A of the CGST Rules, an exporter who has furnished an LUT undertakes that export of goods shall be completed within three months from the date of issue of the invoice for export, and realisation of payment against export of services in convertible foreign exchange (or Indian rupees where permitted by RBI) shall be received within one year from the date of issue of the invoice. The Commissioner is empowered to extend these periods on sufficient cause. If these conditions are not met, the supply is deemed not to have qualified for zero-rated treatment and IGST along with interest becomes payable. Where the export is completed or payment realised after paying IGST, the refund mechanism still allows recovery of the tax paid, subject to conditions.

What is the difference between exporting with IGST and exporting under LUT?

GST law provides two routes for zero-rated supplies. Under the first route, the exporter pays IGST on the export invoice, claims refund of the IGST from the department (typically a faster route integrated with ICEGATE for goods exports), and continues to utilise ITC freely against other outward supplies. Under the second route — using an LUT — the exporter does not pay any IGST on the export invoice but may accumulate unutilised ITC, which can be claimed as a refund under Rule 89. The right choice depends on cash-flow profile, ITC position, and mix of exports vs domestic supplies. Many exporters with predominantly export operations prefer the LUT route because it avoids tying up working capital in IGST at all, while others with balanced domestic and export revenues prefer the IGST-and-refund route for its direct ICEGATE integration.

What is the bond and bank guarantee route and when is it required?

Registered persons who are not eligible to furnish an LUT — primarily those prosecuted for tax evasion exceeding Rs. 2.5 crore under GST or earlier indirect tax laws — are required to furnish a bond with bank guarantee to export goods or services or supply to SEZ without payment of IGST. The bank guarantee is typically required at 15% of the bond amount, though the Commissioner has the power to vary this based on the track record of the exporter. Bond value is usually estimated with reference to the expected quantum of zero-rated supplies during the year. The bond route involves materially higher compliance cost and working capital, which is why LUT — where eligible — is almost always preferred. Where prosecution has concluded, or where the threshold test is re-satisfied, the taxpayer can transition back to the LUT route.

Can an LUT be filed after the financial year has begun?

Yes — LUT can be filed at any time during the financial year on the GST portal, and it is generally accepted with effect from the date of filing, subject to applicable procedural conditions. However, exports made in the period before the LUT was filed — where no LUT was in place — are technically not covered by any zero-rated undertaking. The practical consequences depend on how the department assesses such gaps; taxpayers have in some cases been asked to pay IGST on such interim exports and seek refund. The cleanest outcome is to always file the LUT before the start of the financial year, and where a gap has occurred, to file the LUT immediately and document the operational reasons along with evidence that all Rule 96A conditions are otherwise met.

What happens if export is not completed or payment not realised within the prescribed period?

If goods are not exported within three months of the invoice date, or services are not paid for in convertible foreign exchange within one year of the invoice date, the registered person is required to pay IGST along with interest (typically at 18% per annum) on the supply treated as not zero-rated. This is self-assessed and paid through DRC-03 or subsequent GSTR-3B. Where the export is later completed, or payment is realised after the prescribed period, the taxpayer can claim refund of the IGST paid, subject to the conditions under Section 54 and Rule 89, and subject to any extension granted by the Commissioner. Close monitoring of Rule 96A timelines — invoice-wise, shipping-bill-wise, and FIRC-wise — is therefore a core operational discipline for LUT-backed exporters.

Is a separate LUT required for each GSTIN of a multi-state exporter?

Yes — LUT is filed at the GSTIN level, and a registered person with multiple GSTINs across different states is required to file a separate LUT for each GSTIN that undertakes zero-rated supplies. Each state GSTIN independently files Form RFD-11 on the GSTN portal with its own witnesses, authorised signatory, board resolution, and DSC / EVC. From an internal control standpoint, large multi-GSTIN exporters typically maintain a central LUT register listing the LUT ARN, reference number, validity dates, authorised signatory, and witness details for each GSTIN, with a centralised renewal calendar to ensure no GSTIN is left unprotected at the start of a new financial year.

Zero-Rated Exports Without IGST Outflow — Done Right

Partner with our specialists for end-to-end GST LUT Form Filing Services — eligibility, RFD-11, annual renewal, Rule 96A monitoring, and refund support — under one roof.

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