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How to Claim a GST Refund on Exports Without Payment (LUT)

How to claim a GST refund of unutilised ITC on exports made without payment of tax under a Letter of Undertaking (LUT) — file RFD-11 for the LUT and RFD-01 to claim the...

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GST
Published
August 25, 2026
Last updated
Oct 1, 2026
Reading time
4 min
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Last updated: October 2026Applies to: FY 2026-27Verified against: Government sources

Overview

Exports are zero-rated, so exporters can supply without paying tax by furnishing an LUT and later claim back the input tax credit that accumulates on their purchases. This is the "without payment of tax under LUT" route, preferred by exporters who want to avoid blocking working capital in IGST.

When It Is Required & Legal Basis

Section 16 of the IGST Act, 2017 (zero-rated supplies) with Section 54 of the CGST Act, 2017 and Rule 89 and Rule 96A of the CGST Rules, 2017 govern this route. The LUT is furnished in Form GST RFD-11 and the refund of unutilised ITC is claimed in Form GST RFD-01.

Step-by-Step Process

  1. Furnish the LUT. File Form GST RFD-11 for the financial year before making zero-rated supplies without payment of tax.
  2. Export and maintain records. Raise export invoices without IGST, mentioning "Supply meant for export under LUT without payment of IGST".
  3. Report in GSTR-1 and 3B. Disclose zero-rated supplies in GSTR-1 Table 6A and GSTR-3B Table 3.1(b).
  4. Open RFD-01. Go to Services → Refunds → Application for Refund → "Export of goods/services without payment of tax".
  5. Compute and upload. Enter Net ITC, turnover figures, upload statements (Statement 3/3A) and CA certificate if refund exceeds ₹2 lakh.
  6. Submit and track. File with DSC/EVC; an ARN is generated and the officer processes RFD-02/RFD-04/RFD-06.

Forms, Attachments & Fees

FormPurposeTimeline
GST RFD-11Letter of Undertaking (LUT)Once per financial year, upfront
GST RFD-01Refund application (unutilised ITC)Within 2 years of relevant date
GST RFD-02AcknowledgementWithin 15 days
GST RFD-04Provisional refund (90%)Within 7 days of acknowledgement
GST RFD-06Final sanction orderWithin 60 days

No government fee. Attach export invoices, shipping bills/FIRC, Statement 3 and a CA/CMA certificate where the claim exceeds ₹2 lakh.

Timeline & Due Dates

File the LUT before the first export of the year. File RFD-01 within two years from the relevant date. The officer acknowledges within 15 days (RFD-02), grants 90% provisional refund within 7 days for zero-rated supplies, and passes the final order within 60 days; interest at 6% applies if delayed beyond 60 days.

Penalty for Delay / Non-compliance

If export proceeds are not realised within the period allowed under FEMA (or goods not exported within three months under Rule 96A), the exporter must pay IGST with interest at 18% under Section 50. Excess refund is recoverable with interest.

Practical Tips

  • File the LUT at the start of every financial year — exporting without a valid LUT forces the IGST-payment route.
  • Refund is period-wise; do not club tax periods across financial years in one RFD-01.
  • Reconcile Net ITC with the electronic credit ledger to avoid deficiency memos (RFD-03).
  • Keep bank realisation certificates/FIRC ready for service exports.

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Quick recapKey facts & short answers

Key Facts About Claim a GST Refund

  • Applies in: All states across India, under the relevant central law.
  • Mode: Mostly online via the official government portal.
  • Typical timeline: Ranges from a few days to a few weeks depending on the case.
  • Non-compliance: May attract penalties, interest or late fees.
  • Expert help: TaxClue completes the entire process end to end for you.

What is an LUT and who needs it?

A Letter of Undertaking (Form GST RFD-11) lets an exporter supply goods or services without paying IGST. Any registered exporter can furnish an LUT; it must be filed afresh for each financial year.

Which form is used to claim the refund under LUT?

The refund of accumulated unutilised input tax credit is claimed in Form GST RFD-01 on the GST portal, selecting the category "Export of goods/services without payment of tax".

Claim a GST Refund: a key compliance topic in Indian tax and corporate law that businesses and individuals must understand to remain compliant.

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Disclaimer: This article is for general informational purposes only and does not constitute professional tax, legal or financial advice. Laws, rates and due dates change and can vary by individual case — always verify with the relevant government source (e.g. mca.gov.in, incometax.gov.in) or consult a qualified professional before acting. TaxClue accepts no liability for decisions taken based on this content.

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Questions, answered

Short, direct answers to the 6 questions readers ask most on this topic.

A Letter of Undertaking (Form GST RFD-11) lets an exporter supply goods or services without paying IGST. Any registered exporter can furnish an LUT; it must be filed afresh for each financial year.

The refund of accumulated unutilised input tax credit is claimed in Form GST RFD-01 on the GST portal, selecting the category "Export of goods/services without payment of tax".

Under Rule 89(4), Refund = (Turnover of zero-rated supplies × Net ITC) ÷ Adjusted total turnover. Net ITC is the ITC availed on inputs and input services during the period.

The application must be filed within two years from the relevant date under Section 54 of the CGST Act — generally the date of export or the end of the relevant tax period.

A certificate (Annexure 2) from a CA or CMA is required where the refund claimed exceeds ₹2 lakh, unless it falls within categories exempted from the certificate requirement.

The officer must issue a provisional refund of 90% within 7 days of acknowledgement and pass the final order in Form GST RFD-06 within 60 days of a complete application.