Export Without LUT explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
A Letter of Undertaking lets you export without paying IGST. Forgetting to file it for the year is one of the most common exporter mistakes, and it usually comes to light when the refund is filed or a notice arrives. The consequences depend on what you actually did on the invoices, and in most cases the refund can still be saved.
Under section 16 of the IGST Act (sub-sections (3) and (4)), a zero-rated supply is made either under bond or LUT without IGST, or on payment of IGST with a refund. If you paid IGST without an LUT, you simply use the IGST-paid refund route. If you charged no IGST and had no LUT, IGST with interest becomes payable, but the Refunds Handbook records that LUT delay can be condoned ex post facto where the exports are genuine. If GST was deposited only because the LUT was missing, it can be claimed back under the "Any Other" refund category, provided the zero-rating conditions are met.
What the LUT does
The LUT is filed online in FORM GST RFD-11. It is accepted as soon as the ARN is generated and is valid for the whole financial year. It is available to all registered persons except those prosecuted for an offence where the tax evaded exceeds ₹250 lakh; they must furnish a bond with a bank guarantee instead.
Without an LUT or bond, the law does not permit an export without payment of IGST. That is the root of every consequence below.
Three situations, three outcomes
| What happened | Legal position | What to do |
|---|---|---|
| No LUT, IGST charged and paid on the export invoice | Valid zero-rated supply on payment of IGST | Claim the IGST: shipping bill route for goods (Rule 96), RFD-01 for services |
| No LUT, invoice issued without IGST | Tax due with interest; zero-rating benefit still available on the facts | Seek ex post facto acceptance of the LUT; file the current year's LUT now |
| No LUT, GST deposited later (for example through DRC-03) only because the LUT was missing | Payment made because of the missing LUT | Claim the refund under "Any Other", with the zero-rating proof |
Situation 1: you paid IGST
Nothing is wrong. You followed the other zero-rating route. For goods, the shipping bill is the refund application once the manifest is filed and GSTR-3B is filed, and GSTR-1 Table 6A must match the shipping bill. For services, file RFD-01 for the IGST paid. One point: IGST-route refunds are not available for goods restricted under Notification 01/2023-Integrated Tax, and section 54(15) bars refunds where the goods are subject to export duty.
Situation 2: you charged nothing and had no LUT
Here the invoice says "without payment of IGST", but the condition for that route was not met. The Refunds Handbook reproduces the CBIC position on condonation: the substantive benefit of zero-rating may not be denied where it is established that exports were made in terms of the law, and the delay in furnishing the LUT will be condoned, with the LUT facility allowed on an ex post facto basis, taking into account the facts of each case.
In practice, file the LUT for the current year straight away, then approach the jurisdictional officer for condonation of the missed period with evidence that the goods left India or the service payment was received. If an officer insists on tax, you are back to Situation 3.
If you are unsure which situation you are in, or an officer has already raised the point, our LUT export refund team can review the invoices and take the condonation request forward.
Situation 3: you deposited the tax because the LUT was missing
The Refunds Handbook answers this directly in its FAQs: where GST was paid solely because an LUT was not executed, the taxpayer can claim a refund under the "Any Other" category on the portal, provided all other conditions of zero-rated supply are satisfied and the payment was made because of the missing LUT.
Illustration: A services exporter forgets the LUT for a year and issues invoices without IGST worth ₹80 lakh. On audit, it deposits IGST at an illustrative 18%, i.e. ₹14.4 lakh, plus interest through DRC-03. All payments had been received in foreign exchange.
- The ₹14.4 lakh tax is claimable under "Any Other", with the FIRCs, invoices and DRC-03 challan.
- Expect the interest to be a sunk cost. The Handbook's treatment of Rule 96A payments (below) shows that interest paid for delayed compliance is not refunded.
- The accumulated ITC for the year remains claimable in the normal way if it was not used to pay the IGST.
The other LUT trap: Rule 96A
Even with a valid LUT, Rule 96A requires IGST with interest within fifteen days after:
- goods: three months from the invoice date, if the goods have not been exported;
- services: one year from the invoice date, if payment has not been received in convertible foreign exchange (or permitted INR), or the FEMA period if later.
The Commissioner can extend these periods, including ex post facto. If the IGST is not paid, the LUT facility is deemed withdrawn and exports must be on payment of IGST or under bond with bank guarantee until you pay and the facility is restored.
Circular 197/09/2023-GST softens the blow: when the goods are later exported or the service payment later received, you can claim both the refund of accumulated ITC and the IGST paid under Rule 96A. The interest paid is not refunded.
Check your own numbers on the GST refund calculator.
A checklist so it does not happen again
- File RFD-11 in the first week of April every year, before the first export invoice.
- Put the LUT ARN and date on your export invoice template.
- Track invoices against the Rule 96A deadlines monthly: three months for goods, one year for services.
- For services, track receipts and FIRCs by invoice, not in bulk.
Need help after exporting without an LUT?
A missed LUT is fixable if it is handled early and with the right evidence. We sort out which situation applies, prepare the condonation request or the "Any Other" refund, and set up the LUT and tracker so the next year is clean. See our export refund under LUT service, or the GST refund on excess tax paid page if tax has already been deposited.
Key takeaways
- Without an LUT or bond, an export cannot be made without IGST.
- If you paid IGST, use the IGST-paid refund route; nothing is lost.
- If you charged nothing, seek ex post facto acceptance of the LUT; zero-rating should not be denied for a procedural lapse.
- GST paid only because the LUT was missing can be claimed under "Any Other".
- Rule 96A interest is not refunded, even when the export or payment is completed later.
Read next
- GST refund on export of services: conditions and filing
- GST refund for self-employed professionals exporting services
- Refund of IGST on exports: with and without payment of tax
- Common reasons for GST refund rejection
Disclaimer: Positions stated as on 30 September 2026, based on the CGST Act and Rules as amended, the Finance Act 2026, and the ICAI Handbook on Refunds under GST (January 2026). Verify current notifications before filing.