Home Blog Export/Import Day 2: Export Under GST – IGST vs LUT Explained | Complete Guide for Indian Exporters

Day 2: Export Under GST – IGST vs LUT Explained | Complete Guide for Indian Exporters

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Day 2: Export Under GST – IGST vs LUT Explained | Complete Guide for Indian Exporters
Day 2 Export Under GST – IGST vs LUT Explained Complete Guide for Indian Exporters by CA Devesh Thakur
Day 2 – Export Under GST: IGST vs LUT | 15 Days Export Challenge | CA Devesh Thakur
Day Progress

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✈️  15 Days Export from India Challenge
# DAY 2

Export Under GST
IGST Payment vs LUT

Zero-Rated Supplies · Rule 96A · Form GST RFD-11 · Working Capital Strategy

June 2025 CA Devesh Thakur · FCA cadeveshthakur.com
📺

Missed Day 1? Watch the Introduction Reel

Day 1 covered the Export Ecosystem, IEC, FEMA basics, Incoterms & India’s export overview. Catch up before diving into Day 2!

▶ Watch Day 1 Reel
📌 The Core Question Every Exporter Faces

India is rapidly becoming a global export hub. Whether you export goods through Amazon Global, sell products overseas, or provide services to foreign clients — one critical decision every exporter must make is:

“Should I export with payment of IGST, or under LUT without IGST?”

This decision directly affects your cash flow, working capital, GST refunds, and compliance burden.

Exports Are Zero-Rated Supplies

✅ Section 16, IGST Act — Zero-Rated Supply
  • GST law applies to exports — exports are NOT exempt
  • Input Tax Credit (ITC) remains fully available
  • The final tax burden on exports becomes zero
  • India’s exports remain globally competitive

Two Routes to Achieve Zero Tax on Exports

GST law provides two legal pathways — choose the one that suits your business.

💳

Route 1 — Pay IGST

Pay first, claim refund later

  • 1Issue export invoice with IGST charged
  • 2Pay IGST via ITC or Cash Ledger
  • 3Export goods / supply services
  • 4File GSTR-1, GSTR-3B, Shipping Bill & EGM
  • 5Claim IGST refund from Government
⚠️ Best for: Businesses with excess ITC / high refund efficiency
📋

Route 2 — LUT (No IGST)

File undertaking, export freely

  • 1File LUT in Form GST RFD-11
  • 2Issue export invoice — IGST = NIL
  • 3Export goods / supply services
  • 4Receive foreign exchange within timelines
  • 5No refund needed — working capital preserved
✅ Best for: MSMEs, Startups, Freelancers, Service Exporters

₹1 Crore Export — Side by Side

💳 Exporter A — IGST Route
Export Value₹1,00,00,000
IGST @ 18%₹18,00,000
Upfront Payment₹18,00,000
Working Capital BlockedUntil Refund
Cash Flow ImpactHigh ❌
📋 Exporter B — LUT Route
Export Value₹1,00,00,000
IGST PayableNIL ✅
Upfront PaymentZero
Working CapitalFully Preserved
Cash Flow ImpactExcellent ✅

Today’s Class Notes

📓

Day 2 Notes — Export Under GST · IGST vs LUT Mind Map

Click image to zoom · Download full PDF on WhatsApp Channel
Day 2 Handwritten Notes – Export Under GST IGST vs LUT Mind Map
🔍 Click to enlarge

What is LUT?

📜

LUT — Letter of Undertaking

LUT is filed in Form GST RFD-11. By filing LUT, the exporter gives a legal undertaking to the Government that all export-related GST provisions will be complied with. In return, the Government permits exports without upfront payment of IGST.

🇮🇳

Addressed to “The President of India”

LUT is formally furnished to the President of India through the jurisdictional GST authority. This demonstrates that LUT is not merely a procedural formality but a legal undertaking — carrying real legal responsibilities and consequences.

Three Critical Undertakings in LUT

Undertaking 1

Export Within Prescribed Time

The exporter promises to export goods or services within the timelines specified under Rule 96A.

🏭 Goods: 3 months from invoice date
🖥️ Services: 1 year from invoice date (foreign exchange receipt)
Undertaking 2

Comply with All GST Laws

The exporter promises to follow the GST Act, GST Rules, export provisions, documentation requirements, and all return filing obligations.

Undertaking 3

Pay IGST + Interest if Conditions Violated

If export conditions are not fulfilled, the exporter agrees to pay IGST along with 18% interest per annum from the invoice date until the date of payment.

Form GST RFD-11 — LUT Sample

📄

Form GST RFD-11 — Letter of Undertaking

[See Rule 96A] · Click image to view in full
Form GST RFD-11 – Letter of Undertaking Sample
🔍 Click to enlarge

Rule 96A — Foundation of LUT

📘 Rule 96A of CGST Rules

🎯 Purpose

Governs the entire framework of exports without payment of tax under LUT.

⏱️ Time Limits

Prescribes timelines for export of goods (3 months) and realisation of service payments (1 year).

💰 Recovery

If conditions violated — IGST + 18% interest per annum recovered from the exporter.

📋 Compliance

Lays down documentation, return filing and undertaking compliance requirements.

IGST vs LUT — Complete Comparison

Particulars 💳 IGST Route 📋 LUT Route
Tax Payment RequiredYes — UpfrontNo — NIL
Working CapitalBlocked till refundFully preserved
Refund DependencyHighNone
Cash Flow ImpactAdversePositive
Upfront CostIGST amountZero
Compliance FormGSTR-1, 3B, Shipping BillGST RFD-11 + above
Annual RenewalNot requiredRequired every FY
Best ForExcess ITC holdersMSMEs, Startups, Freelancers, Service exporters
📅

⚠️ LUT Is Valid for ONE Financial Year Only!

A common and costly mistake — exporters assume LUT remains valid indefinitely. It does not.
LUT filed on 15 April 2026 → expires on 31 March 2027. A fresh LUT must be filed every financial year. Exporting without a valid LUT can cause serious compliance issues.

Exporter’s Compliance Checklist

✅ Pre-Export Compliance Checklist

GST Registration
Import Export Code (IEC)
LUT Filed in Form GST RFD-11
Current FY’s LUT is Active
Correct Export Invoice Raised
Shipping Bill Filed
Foreign Remittance Tracked
GSTR-1 Filed on Time
GSTR-3B Filed on Time
Rule 96A Timelines Monitored
LUT Renewed Every Financial Year

Common Mistakes by Exporters

Exporting Before Filing LUT

Can create GST complications and attract recovery proceedings.

📅

Not Renewing LUT Annually

May result in GST demands and interest liability on all exports.

📋

Incorrect Shipping Bill Details

Can delay automatic IGST refunds significantly.

💱

Delayed Foreign Remittance

May violate Rule 96A — attracting IGST + 18% interest.

🔄

Return vs Export Data Mismatch

Can result in refund rejection or departmental queries.

Day 2 Video Summary

📱

Instagram Reel — Day 2 · Export Under GST: IGST vs LUT

Watch, Save & Share with fellow exporters and CA aspirants

⚠️ 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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