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Export Under LUT Without GST Payment – Complete Guide (Day 4)

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Export Under LUT Without GST Payment – Complete Guide (Day 4)
Export Under LUT Without GST Payment – Complete Guide (Day 4) by CA Devesh Thakur
Day 4 – Export Under LUT Without Payment of GST | 15 Days Export Challenge | CA Devesh Thakur
Day Progress

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✈️  15 Days Export from India Challenge
# DAY 4

Export Under LUT
Without Payment of GST

Form GST RFD-11 · Rule 96A · RFD-11A Deemed Acceptance · Benefits vs Disadvantages · How to File Online

June 2025 CA Devesh Thakur · FCA cadeveshthakur.com
📌 Day 4 — The LUT Deep Dive

In Day 2 we learnt the two routes — IGST payment vs LUT. Today we go deep into LUT itself: What is it? How does the flow work? What are the real benefits and risks? And most importantly — How to file it online step by step. This is the practical session every exporter needs.

How Export Under LUT Works

Step-by-Step LUT Export Flow

From export order to ITC refund — the complete journey
1

Receive Export Order from Foreign Buyer

Exporter receives a Purchase Order (P.O.) from an overseas buyer — e.g. USA, Nepal, UAE. This triggers the export process.

🌍 e.g. USA Buyer → India Exporter
2

File Form GST RFD-11 on GST Portal

Exporter logs into the GST portal and files the Letter of Undertaking electronically in Form GST RFD-11 before making exports.

📋 Services → User Services → Furnish LUT
3

GST Dept Issues RFD-11A — Deemed Acceptance

Once filed, the system auto-generates Form RFD-11A — an acknowledgment that serves as Deemed Acceptance of the LUT. No manual approval required.

✅ RFD-11A = Proof of Valid LUT
4

Supply Goods / Services Without Paying IGST

Exporter raises export invoice with LUT declaration. IGST = NIL. Goods dispatched through customs after filing Shipping Bill.

📦 Export Invoice carries LUT declaration
5

Report in GSTR-1 (Table 6A)

Export invoices reported in GSTR-1 under Table 6A with Shipping Bill details and port code. GSTR-3B filed showing Zero-Rated Supplies.

📊 GSTR-1 Table 6A → Type: WOPAY
6

Customs / GST System Verifies Export

ICEGATE verifies Shipping Bill data against GSTR-1. Export General Manifest (EGM) filed by the carrier confirms goods actually left India.

🛃 Invoice ↔ Shipping Bill ↔ ICEGATE match
7

Claim Refund of Unutilized ITC (if applicable)

Exporter files Form GST RFD-01 to claim refund of accumulated Input Tax Credit on inputs used in exported goods/services.

💰 File GST RFD-01 for ITC refund

RFD-11A — Deemed Acceptance of LUT

🏛️

What is Deemed Acceptance?

Under the current GST portal system, once Form GST RFD-11 is successfully filed, the portal automatically generates Form RFD-11A — an acknowledgment certificate. This acknowledgment itself constitutes Deemed Acceptance of the LUT by the GST Department.

Exporters do not need to wait for manual approval from the GST officer. The RFD-11A acknowledgment is sufficient proof to proceed with exports without payment of IGST immediately.

  • AFile RFD-11 → System processes → RFD-11A generated instantly
  • BDownload RFD-11A acknowledgment from the GST portal
  • CKeep RFD-11A as export compliance record
  • DQuote LUT details on export invoices immediately

Handwritten Notes — LUT Flow & Analysis

📓

Day 4 — LUT Export Flow, Benefits vs Disadvantages & Online Filing

Click image to zoom · Download full notes on WhatsApp Channel
Day 4 Handwritten Notes – Export Under LUT by CA Devesh Thakur
🔍 Click to enlarge

LUT — Benefits vs Disadvantages

Benefits of LUT

Why most exporters prefer this route

💰

No IGST Payment on Exports

Biggest advantage — exporters need not pay IGST at the time of export. Improves liquidity immediately.

🏦

No Blocking of Working Capital

Funds are not blocked waiting for a refund. Money is available for inventory, salaries and operations.

💻

Easy Online Compliance

Completely online filing through GST portal. Simple, quick and paperless — no physical submission required.

📅

Valid for 1 Full Financial Year

One filing covers all exports for the entire financial year. Once filed, export without IGST throughout the FY.

🇮🇳

Encourages Export Promotion

Supports Make-in-India and Atmanirbhar Bharat by making Indian exports cost-competitive globally.

⚠️

Disadvantages / Conditions

Strict obligations you must comply with

⏱️

Strict Timeline — Rule 96A

Goods must be exported within 3 months from invoice date. Service payments within 1 year. No flexibility without Commissioner’s extension.

💸

Tax + Interest @ 18% if Violated

If export conditions are not fulfilled — IGST becomes payable along with 18% interest per annum from invoice date till payment.

🔄

Annual Renewal Compulsory

A fresh LUT must be filed every financial year. Old LUT does not carry forward. Missing renewal = compliance violation.

🆔

Only for Registered Exporters

GST registration is mandatory to avail LUT facility. Unregistered persons or composition dealers cannot use this route.

Prescribed Time Limits Under LUT

📦

Export of Goods

Physical goods sent outside India

3
Months from Invoice Date
Goods must physically be exported within 3 months from the date of the export invoice. Extension can be granted by the Commissioner for genuine reasons.
⚠️ Breach → IGST + 18% interest from invoice date
💻

Export of Services

Foreign currency receipt from overseas clients

1
Year from Invoice Date
Foreign currency payment must be received within 1 year from invoice date. Relevant for IT services, consulting, freelancers and all service exporters under FEMA.
⚠️ Breach → IGST + 18% interest from invoice date

How to File LUT Online — GST Portal

🖥️ LUT Online Filing — Complete Steps

As highlighted in your notes: “How to file LUT online? (Wait till end)” — here’s the complete guide

1

Login to GST Portal

Go to gst.gov.in → Login with GSTIN credentials (Username + Password + OTP)

2

Navigate to LUT Section

ServicesUser ServicesFurnish Letter of Undertaking (LUT)

3

Select Financial Year

Choose the relevant Financial Year for which LUT is to be filed (e.g. 2025-26). LUT is FY-specific.

4

Fill Declaration & Witness Details

Complete the Form RFD-11 — exporter declarations (3 undertakings) + 2 witness names, occupations & addresses.

5

Verify Using DSC or EVC

Digitally sign using DSC (Digital Signature Certificate) or verify via EVC (OTP on registered mobile/email).

6

Submit & Download RFD-11A

Submit the form. Portal immediately generates RFD-11A acknowledgment. Download and save — this is your proof of valid LUT.

Key Takeaways — Day 4

🎯 What You Must Remember

  • LUT = Form GST RFD-11 — filed on GST portal before exports begin
  • Governed by Rule 96A of CGST Rules, 2017 — the foundation of the entire LUT mechanism
  • RFD-11A = Deemed Acceptance — no manual approval needed, export immediately after filing
  • Goods must be exported within 3 months from invoice date (Rule 96A time limit)
  • Service export payment must be received within 1 year from invoice date
  • Violation = IGST + 18% interest per annum from invoice date till payment date
  • LUT valid for ONE financial year only — must be renewed before 1st April every year
  • Only GST-registered exporters are eligible — composition dealers cannot use LUT
  • LUT = No IGST outflow + No working capital blockage + Simple online compliance
  • LUT supports Make-in-India and Atmanirbhar Bharat by making exports cost-competitive
📺

Catch Up — Day 1, 2 & 3 Reels

Day 1 — Export Ecosystem  ·  Day 2 — IGST vs LUT  ·  Day 3 — Export Tax Invoice

Day 4 Video Summary

⚠️ Disclaimer

The content shared on this channel is purely for educational purposes. As a Chartered Accountant, I strive to provide accurate and insightful information related to GST, Income Tax, Accounting, and Tax Planning. However, please note that the content should not be considered as professional advice or a substitute for personalized consultation. For specific matters, please consult a qualified professional.

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