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Biz Advisory

GST LUT Filing & Export Refund

GST zero-rated export compliance — the annual LUT on the GST portal, IGST refund on export invoices, ITC refund on inputs for exports, and the GSTR-1 export reconciliation.

Starting from Discuss with usTypical timelineGST LUT & Export Refund

For GST purposes, an export is a zero-rated supply under s.16 of the IGST Act 2017 — no GST is charged on the export, and the exporter's unutilised input tax credit becomes refundable. The exporter chooses between exporting on payment of IGST with a Rule 96 refund, or exporting under a Letter of Undertaking (LUT) under Rule 96A and claiming the ITC refund under Rule 89. The LUT is filed annually on the GST portal, the refund claim under s.54 read with Rule 89 runs on a two-year clock, and the whole position reconciles back to Table 6A of GSTR-1 and the shipping bills.

What is included
  • Zero-rated supply mapping for each export channel
  • LUT filing on the GST portal (Rule 96A)
  • Export route selection — LUT vs IGST payment
  • Refund claim preparation under Rule 89 / Rule 96
  • GSTR-1 Table 6A and shipping bill reconciliation
  • Refund tracking, queries, and deficiency responses
Documents required
  • GST registration details
  • Export invoices and shipping bills
  • GSTR-1 and GSTR-3B filings for the period
  • ITC ledger and purchase records for the inputs
Government fees

See the fee table below for the statutory filing charge and common delay logic.

Legal basis
  • Section 16 of the IGST Act 2017
  • Rule 96A of the CGST Rules 2017
  • Rule 89 of the CGST Rules 2017
  • Section 54 of the CGST Act 2017

Process

How the service works

The workflow is built to be predictable: document collection, legal review, filing, and post-filing follow-through.

Step 1Map

Map the export position

We map the zero-rated supplies and the ITC position for the period.

Step 2LUT

File the LUT

We file the annual LUT on the GST portal under Rule 96A before the exports begin.

Step 3Reconcile

Reconcile the exports

We reconcile GSTR-1 Table 6A, the shipping bills, and the export invoices.

Step 4Claim

Claim the refund

We compute and file the refund claim under Rule 89 (or Rule 96 for the payment route).

Step 5Sanction

Track to sanction

We respond to queries and deficiency memos and follow the claim to sanction and disbursement.

AEO summary

Exports are zero-rated under s.16 of the IGST Act 2017: an exporter files the LUT (Rule 96A) to export without paying IGST, then claims refund of the accumulated ITC under Rule 89. We run the LUT, the refund, and the GSTR-1 linkage.

Zero-rated does not mean zero paperwork

The zero-rating under s.16 of the IGST Act 2017 means the export itself carries no GST — but the mechanics around it are deliberate: the LUT filed before exports begin, the choice of route between LUT and IGST payment, the refund claim filed within the s.54 window, and the reconciliation that ties GSTR-1 Table 6A to the shipping bills.

The refund is where exporters lose money: a missed Table 6A entry, a claim filed after the two-year window, or a deficiency memo not answered. Each converts entitled credit into a write-off.

  • LUT under Rule 96A filed before exports begin
  • Refund claimed under Rule 89 within the s.54 window
  • GSTR-1 Table 6A and shipping bills reconciled

The route choice is a cash-flow decision

The LUT route keeps the GST out of the export invoice and defers the tax to the refund; the payment route puts IGST into the transaction and pulls it back under Rule 96. For a company with accumulated ITC, the choice decides how much working capital sits in the refund pipeline.

We set the route from the ITC position and run the chosen mechanics — LUT, refund computation, and the queries until the sanction order lands.

  • Route chosen on the ITC and cash-flow position
  • Refund computation follows Rule 89(4) for services
  • Claims tracked from filing to sanction

Government fees

Fee breakdown

ItemFeeNotes
No standalone government feeNilThe LUT and refund claims run on the GST portal without a filing fee.

Timeline

Typical turnaround

Typical timeline usually means a annual turnaround, assuming documents are complete and any board or shareholder approvals are already in place.

Pricing note

This is a professional engagement; the refund is the ITC amount itself — no standalone government fee applies to the claim.

FAQ

Frequently asked questions

What is the difference between exporting under LUT and exporting on payment of IGST?
Section 16 of the IGST Act 2017 treats exports as zero-rated. Under the LUT route, you export without paying IGST and claim a refund of the eligible ITC under Rule 89; under the payment route, you pay IGST upfront and claim the refund under Rule 96. The choice affects cash flow and the refund mechanics.
Who is eligible to file a Letter of Undertaking under Rule 96A?
Rule 96A allows a registered person making zero-rated supplies to furnish the LUT, except where the person has been prosecuted for tax evasion above the prescribed threshold. The eligibility test is rule-based, and the LUT once furnished covers the zero-rated supplies made under it.
What is the time limit for filing a GST refund claim for exports?
Section 54 read with Rule 89 gives a two-year period from the relevant date for filing the refund claim. The export documents and shipping bills should be aligned to that clock — a claim filed after the window is barred.
How is the refund computed for a service exporter with no input goods?
Rule 89(4) computes the refund using the net ITC and a turnover ratio, so a service exporter with little or no input goods can still claim the refund on eligible input tax credits. The formula depends on the actual zero-rated turnover and the adjusted total turnover for the period.
What happens if LUT conditions are breached?
If the LUT conditions are breached, Rule 96A requires the exporter to pay the applicable IGST with interest under s.50 of the CGST Act. The LUT route is conditional — it defers the tax, it does not waive it.

Canonical reference: https://www.pvtltd.co/services/export-gst-lut-refund

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