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LUT Filing for Exporters: Documents, Timing and Common GST Mistakes

LUT Filing for Exporters: Documents, Timing and Common GST Mistakes
Finin2min GST Desk·June 2026·7 min readLUT FILINGReviewed by CA Nikhil Gupta · 19 June 2026

LUT is a small portal filing with a large compliance impact. If you are registered under GST and want to export goods or services without paying IGST upfront, you generally need to furnish a Letter of Undertaking in Form GST RFD-11 before making zero-rated supplies under LUT.

Quick answer: LUT (Form GST RFD-11) is required BEFORE you raise a zero-rated export invoice, not after - and it only covers the export-procedure step. It does not by itself prove your supply actually qualifies as an export; you still separately need to satisfy the export-of-services or export-of-goods conditions, match your invoices/returns/remittance evidence, and renew LUT every financial year. This reflects Rule 96A of the CGST Rules, 2017 and the GST portal’s current RFD-11 process, both currently in force - this is educational information, not filing advice for your specific facts; verify the live portal workflow and current notifications before relying on any step here.

What LUT Does

LUT allows eligible registered exporters to make zero-rated supplies without payment of integrated tax, subject to conditions. Rule 96A requires the bond or Letter of Undertaking before export. The GST portal user guide states that registered taxpayers having zero-rated supply of goods or services furnish LUT in Form GST RFD-11 through the portal before affecting such supply.

ItemWhat to checkWhy it matters
GSTIN statusRegistration active and returns substantially cleanPortal filing and refund claims can fail if compliance is broken.
Financial yearLUT should be furnished for the relevant yearOld LUT acknowledgement should not be reused blindly.
Export invoicesInvoice should mention export under LUT / without payment of IGST as applicableSupports zero-rated treatment and refund trail.
Remittance proofKeep FIRC/BRC/bank advice or equivalent evidenceExport-of-services condition and refund support.
Authorized signatoryDSC/EVC access and correct signatory detailsAvoids last-minute portal filing failure.
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GST LUT Eligibility and Export Action Checker
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Common LUT Mistakes

  • Filing LUT after export invoices have already been raised.
  • Not renewing LUT for the new financial year.
  • Using LUT even when the transaction does not satisfy export-of-services conditions.
  • Not matching LUT, invoices, GSTR-1, GSTR-3B and refund claim period.
  • Keeping payment gateway statements but no foreign remittance evidence.
âš  Practical caution: LUT is not proof that the supply is an export. It is only one compliance step. The export-of-services or export-of-goods conditions still need to be satisfied separately.

Export of Services: Five Conditions to Test

A service is not automatically an export just because the customer is outside India. Under the IGST framework, export of services requires five checks: supplier located in India, recipient located outside India, place of supply outside India, payment received in convertible foreign exchange or permitted Indian rupees, and supplier and recipient not merely being establishments of a distinct person. Miss any one of these checks and the GST position can change completely.

ConditionWhat to verifyCommon evidence
Supplier in IndiaYour registered place/fixed establishment is in IndiaGST registration, invoice profile, business address.
Recipient outside IndiaCustomer is located outside IndiaContract, purchase order, billing details.
Place of supply outside IndiaSection 13 result should point outside IndiaService classification memo, client scope, evidence of performance.
Payment conditionForeign exchange / permitted INR receiptFIRC/BRC, bank advice, remittance note.
Not same establishmentSupplier and recipient are not merely establishments of same personGroup structure, branch/subsidiary analysis.

Worked Example

A Bengaluru-based software consultancy (registered under GST, LUT already furnished for the current financial year) signs a ₹12 lakh annual contract with a US-based client for custom software development. The consultancy checks the five export-of-services conditions: supplier in India (yes, its registered office); recipient outside India (yes, the US client); place of supply outside India (yes, under the default Section 13(2) rule for this service type); payment in convertible foreign exchange (yes, USD wire transfers with FIRC issued by the bank); and not merely establishments of the same person (yes, no group/branch relationship exists). All five conditions are met, so the consultancy raises invoices marked "export under LUT / without payment of IGST," reports them correctly in GSTR-1 and GSTR-3B, and files the FIRC alongside each invoice in its evidence folder. If even one condition had failed - say, the US entity turned out to be a wholly-owned subsidiary of the same Indian parent - the transaction could instead be treated as an intermediary or non-export supply, changing the GST position entirely despite the LUT already being on file.

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Exporting without payment of IGST?Keep LUT, invoice, return and remittance records in one folder before applying for refund.
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Official References Used

This article uses official GST law, GST portal guides and CBIC circulars only. Verify rates, forms and procedural changes before publishing because GST notifications and portal flows can change.

Frequently Asked Questions

Which form is used for LUT under GST? â–¼
LUT is furnished in Form GST RFD-11 on the GST portal, according to the official GST portal user guide.
Should LUT be filed before or after export? â–¼
The official framework refers to furnishing LUT before export / before affecting such supply, so exporters should not delay it until refund filing.
Does LUT remove the need for export documentation? â–¼
No. Export conditions, invoice trail, return reporting and remittance proof are still required.

Source and review trail

Use the current official instrument, portal or regulator publication before acting. This panel separates the category authority from page-specific references.

Primary category
GST & Indirect Tax
Official starting point
www.gst.gov.in

See “Official References Used” above for the IGST Act 2017, CGST Rule 96A and GST Portal LUT user guide references used in this article.

Additional source links

Primary sources & related provisions

Statutory provisions referenced in this guide:

© 2026 Finin2min. GST articles are for general guidance and do not replace professional advice.
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