Trusted by 10,000+ Businesses

GST Refund - Exports under LUT (Rule 96A and Rule 89)

Reviewed by CA & CS Team · Patron Accounting LLP ICAI & ICSI Registered| 15+ Years Experience| Last Updated: 11 May 2026 Verify Credentials →

Documents: Form RFD-11 (LUT), GSTR-1, GSTR-3B, shipping bill or eBRC/FIRC, RFD-01, CA certificate above Rs 2 lakh

Fees: Starts at Rs 8,000 per refund period plus 18 percent GST (RFD-11 LUT filing from Rs 3,500)

Eligibility: Any registered exporter of goods or services not prosecuted for tax evasion above Rs 2.5 crore (Rule 96A(1))

Timeline: 30 to 60 days for accumulated ITC refund under Rule 89; LUT acknowledgement instant via DSC or EVC

10,000+ Businesses Served | 4.9 Google Rating | 15+ Years of GST Compliance and Export Refund Experience

15+ YearsIndustry Experience
CA & CSCertified Experts
4.9
Based on 500+ reviews

Get Free Consultation

Talk to a CA/CS expert today

🇮🇳 +91

Our team will get back to you shortly. No spam.

Real Stories from Real People

Hear how teams across industries use Patron to save time, cut costs, & stay in control.

Fetching latest Google reviews…
Patron recovered Rs 1.07 crore in accumulated ITC refund under our LUT route for FY 2024-25. Provisional 90 percent in 11 days, balance Rs 10.7 lakh in 53 days. The Mavenir Systems case-law citation overturned an FIRC-based RFD-08 rejection cleanly.
RK
Rakesh Kapoor
CFO / Pune IT Services Exporter
★★★★★
2 months ago
Took minimum time, really impressive acumen. Patron filed our FY 2026-27 LUT in early March - zero disruption when April hit. The LUT calendar service is the kind of discipline most CAs miss entirely.
RD
Rajib Dutta
Director / Bengaluru SaaS Exporter
★★★★★
3 months ago
The LUT vs IGST-paid working capital diagnostic was eye-opening - we had been doing IGST-paid for years and losing weeks of cash flow. Patron switched us to LUT route, recovered Rs 65 lakh accumulated ITC in 48 days.
SM
Subhendu Mishra
Finance Head / Mumbai Software Product Exporter
★★★★★
1 month ago
Goods couldn't be exported within 3 months due to a Suez Canal delay. Patron computed our Section 50 interest exposure cleanly, filed DRC-03 self-assessment, restored LUT, and represented for interest waiver. Saved us Rs 4 lakh in interest.
NG
Nishikant Gurav
Director / Engineering Goods Exporter
★★★★★
5 months ago
As an SEZ supplier, only LUT route is available to us. Patron's Form A1 endorsement coordination with SEZ Specified Officer is fast and reliable. Three years of consistent refund recovery - never a single RFD-08.
AG
Anita Gaur
VP Finance / Hyderabad SEZ DTA Supplier
★★★★★
4 months ago

Join 10,000+ Satisfied Businesses

From RFD-11 LUT filing through to RFD-06 bank credit - Patron handles the full Rule 96A and Rule 89 export refund pipeline with CA-led working-capital diagnostic and Mavenir Systems-backed eBRC defence.

Talk to an Expert
10,000+Businesses ServedGST compliance and litigation support across India.
15+Years ExperienceDeep expertise in IP registration, GST & business compliance.
50,000+Documents FiledReturns, appeals, and filings handled accurately.
4.9★Client RatingTrusted by entrepreneurs, startups, and growing businesses.
ISO CertifiedProfessional standards and documented processes.
SSL SecureYour financial and business data is fully protected.

Exports under LUT Refund Overview

📌 TL;DR - Exports under LUT Refund Services at a Glance

Exports of goods and services are zero-rated under Section 16 of the IGST Act 2017. Under the LUT route (Rule 96A read with Rule 89), an exporter files Form GST RFD-11 to export without paying IGST and then claims refund of accumulated ITC via Form GST RFD-01. The Rule 89(4) formula applies. The LUT for FY 2026-27 must be filed before 31 March 2026.

Exports of goods and services from India are zero-rated supplies under Section 16 of the IGST Act 2017. Section 16(3) gives the exporter two refund routes - supply under bond or LUT without payment of IGST and claim refund of accumulated unutilised ITC under Rule 89, or supply on payment of IGST and claim refund of the IGST under Rule 96 with the shipping bill itself acting as the refund application. The LUT route preserves working capital and is the dominant route for IT services, SaaS, and software product exporters. The IGST-paid route is faster and auto-processed through ICEGATE for goods exporters.

The Letter of Undertaking is filed in Form GST RFD-11 on the GST portal under Rule 96A of the CGST Rules 2017, originally notified by Notification No. 16/2017-Central Tax dated 07 July 2017. The LUT is valid for one financial year, and a fresh LUT must be filed before the first export of every new financial year. For FY 2026-27, the deadline is 31 March 2026 - missing it means every export invoice after 1 April 2026 attracts IGST that must then be paid and refunded separately, blocking working capital. Patron Accounting LLP files RFD-11 LUT, structures the LUT-versus-IGST-paid choice by working capital impact, prepares the Rule 89(4) Net ITC computation, and files RFD-01 with the Statement 3 export annexure.

ParameterDetail
Governing ProvisionSection 16(3)(a) of IGST Act 2017 read with Rule 96A and Rule 89 of CGST Rules 2017
LUT FormForm GST RFD-11 (Notification No. 16/2017-CT dated 07 July 2017)
LUT ValidityOne financial year (1 April to 31 March). Fresh LUT required every FY before first export.
LUT Deadline FY 2026-2731 March 2026 (or before first export of FY 2026-27, whichever is earlier)
Refund FormForm GST RFD-01 - category 'Refund of ITC on Export of Goods or Services without Payment of Tax'
Time Limit2 years from relevant date under Section 54(1) - date ship leaves India for goods, date of FX receipt or invoice (whichever later) for services
AuthorityJurisdictional GST officer, RFD-02 acknowledgement, RFD-06 sanction order, ICEGATE for IGST-paid route

Content is reviewed quarterly for accuracy.

What Is GST Refund on Exports under LUT Route

GST refund on exports under LUT is the refund of accumulated unutilised Input Tax Credit allowed under Section 54(3)(i) of the CGST Act 2017 to a registered exporter who supplies zero-rated goods or services under a Letter of Undertaking (LUT) in Form GST RFD-11 without payment of IGST.

Section 16 of the IGST Act 2017 defines zero-rated supply to include exports and supplies to Special Economic Zones. Section 16(3)(a) gives the exporter the option to supply under bond or LUT without payment of IGST. Rule 96A of the CGST Rules 2017 prescribes the LUT mechanism, the Form GST RFD-11, and the eligibility test under Rule 96A(1). Rule 89 of the CGST Rules 2017 prescribes the refund procedure - the application is filed in Form GST RFD-01, the documentary evidence in Annexure 1 is enumerated under Rule 89(2), and the maximum refund formula is given under Rule 89(4). The Rule 89(4) formula apportions Net ITC to the turnover of zero-rated supply against Adjusted Total Turnover.

For primary source materials see the official GST portal, CBIC notifications and circulars, DGFT eBRC portal, ICEGATE Customs portal, and India Code.

Rule 89(4) Refund Formula

ComponentValue
FormulaMaximum Refund = (Turnover of Zero-Rated Supply x Net ITC) / Adjusted Total Turnover
Net ITC under Rule 89(4)Includes input goods + input services + capital goods (unlike Rule 89(5) IDS)
CapRefund cannot exceed balance in Electronic Credit Ledger at end of refund period

Key Terms for Exports under LUT Refund:

TermPlain Meaning
Letter of Undertaking (LUT)Self-declaration filed in Form GST RFD-11 under Rule 96A of CGST Rules 2017 to export without payment of IGST
Zero-Rated Supply (Section 16 IGST)Exports and supplies to SEZ. Output IGST is zero, but ITC on inputs remains eligible for refund
Bank Realisation Certificate (BRC)Bank-issued certificate confirming realisation of export proceeds in convertible foreign exchange; largely replaced by eBRC on the DGFT portal
Foreign Inward Remittance Certificate (FIRC)Bank certificate confirming receipt of foreign currency for any inward remittance; for services exports, FIRC or modern FIRA is the proof of foreign exchange realisation
eBRCElectronic Bank Realisation Certificate generated on the DGFT portal by the authorised dealer bank; most widely accepted refund proof
FIRAForeign Inward Remittance Advice - modern bank document replacing FIRC for services exports, especially IT and software
Rule 89(4) FormulaMaximum Refund equals (Turnover of Zero-Rated Supply x Net ITC) divided by Adjusted Total Turnover; Net ITC includes input services and capital goods - unlike Rule 89(5)
Statement 3 (RFD-01 Annexure)Invoice-level statement of zero-rated exports without IGST payment; mandatory in RFD-01 filing for LUT route
Statement 3ARule 89(4) computation sheet - Net ITC, Adjusted Total Turnover, Turnover of Zero-Rated Supply
EDPMSExport Data Processing and Monitoring System maintained by RBI for tracking goods export realisation
APL-05 Exports under LUT Refund
Form RFD-11 + RFD-01

8 Exporter Categories - Who Can File LUT and Claim Refund

The LUT route is available to any registered person making zero-rated supplies. Eligibility, exclusions, and refund timing differ across exporter categories - the table below maps the 8 most common exporter profiles served by Patron.

Exporter CategoryLUT EligibilityKey DocumentsTypical Timeline
IT Services and SaaS Exporters (place of supply outside India)Eligible - LUT route preferredFIRC, FIRA, eBRC; Statement 3 in RFD-01; place-of-supply evidence (contract, IP logs)30 to 60 days under Rule 89
Software Product Exporters (B2B sales abroad)Eligible - LUT route preferredFIRC or eBRC; Statement 3; export invoice with USD or other foreign currency30 to 60 days under Rule 89
Goods Exporters (textile, pharma, engineering)Eligible - LUT or IGST-paid choiceShipping bill, EGM, BRC, GSTR-1 Table 6A, Statement 3 (LUT route)7 to 15 days under Rule 96 IGST-paid; 30 to 60 days under Rule 89 LUT
Merchant Exporters (trader, no own ITC build-up)Generally IGST-paid route preferredShipping bill, BRC; concessional supply at 0.1 percent IGST under Notification 40/2017-CT (R)7 to 15 days under Rule 96
SEZ Suppliers (DTA to SEZ unit or developer)LUT route only - Rule 96 auto-refund does not applyForm A1 or A2 endorsement by SEZ specified officer; RFD-01 manual30 to 60 days under Rule 89
Deemed Exports (advance authorisation, EOU supplies)Refund allowed under Section 54 read with Notification 48/2017-CTDisclaimer from recipient; receipt evidence; Statement 530 to 60 days under Rule 89
Persons Prosecuted for Tax Evasion above Rs 2.5 croreNOT ELIGIBLE under Rule 96A(1)Must furnish bond with bank guarantee insteadBond-based, separate procedure
Categories Notified Ineligible (Notification 14/2025-CT)Provisional refund deniedManual processing only, no auto-90 percentDetailed scrutiny under Rule 92

Eligibility test for LUT (Rule 96A(1)): the supplier must be registered under GST, must not have been prosecuted for any offence under the CGST Act, IGST Act, or any existing law (Central Excise, Service Tax, State VAT) where the tax evaded exceeds Rs 2.5 crore. Mere issuance of show cause notice or demand does not disqualify - actual prosecution is the bar. Patron audits the prosecution record before LUT filing.

What Patron Accounting Delivers

ServiceWhat We Do
Form RFD-11 LUT Filing for FY 2026-27 and BeyondEnd-to-end LUT filing on the GST portal under Rule 96A. Witness selection (two independent witnesses, not family of proprietor or partners), DSC or EVC signing, ARN tracking, and re-filing for fresh GSTIN or rejection cases.
LUT vs IGST-Paid Route Working-Capital DiagnosticCash-flow comparison between Rule 96A LUT route (refund in 30 to 60 days, no upfront IGST) and Rule 96 IGST-paid route (refund in 7 to 15 days, but 18 percent IGST locked upfront). Sector-specific recommendation with quantified working-capital impact.
Rule 89(4) Computation and Statement 3 PreparationNet ITC computation, Adjusted Total Turnover under Rule 89(4), Turnover of Zero-Rated Supply, and invoice-level Statement 3 preparation matching GSTR-1 Table 6A and shipping bill or eBRC data.
RFD-01 End-to-End Filing for Accumulated ITC RefundOnline RFD-01 filing under category Refund of ITC on Export of Goods or Services without Payment of Tax. ARN tracking, RFD-02 follow-up, response to RFD-03 deficiency memo, and pursuit till RFD-06 sanction with RFD-05 bank credit.
BRC, FIRC, eBRC, and FIRA Documentation DefencePre-filing audit of foreign exchange realisation proof. Engagement with authorised dealer bank for eBRC upload to DGFT portal, FIRA generation for IT services, and Mavenir Systems case-law-backed defence against summary rejection on technical lapses.
LUT Default Recovery and Section 50 Interest MitigationIf exports are not completed within 3 months of invoice date or services proceeds within 1 year, IGST plus 18 percent interest under Section 50 CGST Act becomes payable within 15 days. Patron computes the exposure, files self-assessment, and restores LUT facility post-payment.
Our Process

Refund Procedure (8 Sequential Steps)

Patron Accounting's LUT export refund pipeline runs the steps below. Each step cites the relevant Act, Section, Rule, or Form so finance and tax teams can audit each handoff.

Step 1

Eligibility and Prosecution Check (Rule 96A(1))

Confirm registered under GST. Confirm no prosecution under CGST Act, IGST Act, Central Excise Act 1944, Finance Act 1994 Chapter V, or State VAT for tax evasion above Rs 2.5 crore. If prosecuted, exporter must furnish bond with bank guarantee instead of LUT. (1 day.)

GSTIN verified Prosecution record clean LUT eligibility confirmed
Rule 96A(1)No prosec.above 2.5cr
Eligibility Check 01
Step 2

Form RFD-11 LUT Filing

Login to GST portal > Services > User Services > Furnish Letter of Undertaking. Select financial year (e.g., 2026-27). Enter two independent witnesses (name, address, occupation - not family of proprietor or partners). Tick all three self-declaration boxes. Sign with DSC (mandatory for companies and LLPs) or EVC (allowed for proprietors and partners). Submit; ARN generated; status flows to Approved or Deemed Approved (3 working days). (1 day.)

Two independent witnesses DSC or EVC signed ARN + Deemed Approved in 3d
RFD-11LUT FY 2026-27
RFD-11 Filed 02
Step 3

Export Invoicing under LUT

Raise export invoice with the LUT ARN reference. Mark as Zero-rated supply under Section 16 IGST Act. Foreign currency line, INR equivalent at RBI reference rate on invoice date. Place of supply outside India for services (Section 13 IGST Act); shipping bill for goods (Customs).

LUT ARN on invoice Foreign currency + INR rate Place of supply outside India
Export InvoiceUSD 50,000Zero-Rated (No IGST)
Export Invoice 03
Step 4

Export within Rule 96A Window

For goods, complete export within 3 months of invoice date (Rule 96A(1)(a)). For services, realise foreign exchange within 1 year of invoice (Rule 96A(1)(b)). Standard FEMA realisation period is 9 months (extended 15 months for some categories) - LUT timeline runs on the Rule 96A clock. Default triggers IGST plus Section 50 interest payable in 15 days.

Goods: 3-month export Services: 1-year FX realisation Default = IGST + interest
Goods3 moServices1 yrRule 96A(1)
Export Completion 04
Step 5

GSTR-1 (Table 6A) and GSTR-3B Filing

Report export invoices with payment of tax (Rule 96 route) or without payment of tax (Rule 96A LUT route) in Table 6A of GSTR-1. File GSTR-3B for the period including ITC availed. Refund cannot be claimed if GSTR-1 or GSTR-3B is unfiled or mismatched.

GSTR-1 Table 6A populated GSTR-3B filed with ITC Reconciled before RFD-01
GSTR-1Table 6AExport Inv.GSTR-3BITC availed
GSTR Filed 05
Step 6

RFD-01 Filing for Accumulated ITC Refund

GST portal > Services > Refunds > Application for Refund. Select 'Refund of ITC on Export of Goods or Services without Payment of Tax'. Upload Statement 3 with invoice-level data, shipping bill or eBRC, BRC or FIRC, port code, EGM details. Attach LUT ARN, declarations under Rule 89(2)(l) and (m), CA certificate above Rs 2 lakh. Submit with DSC or EVC. (1 to 2 days post-data-readiness.)

Statement 3 + 3A uploaded BRC / FIRC / eBRC / FIRA DSC or EVC signed
RFD-01Statement 3Statement 3A
RFD-01 Filed 06
Step 7

RFD-02 Acknowledgement and Risk-Based Routing

Proper officer issues RFD-02 within 15 days under Rule 90(2). For zero-rated supplies, system-driven risk evaluation under amended Rule 91(2) (Notification 13/2025-CT effective 01.10.2025) classifies the claim. Categories notified ineligible under Notification 14/2025-CT do not get provisional refund. (Within 15 days.)

RFD-02 in 15 days Risk-based routing Notification 13/2025-CT
RFD-0215d
RFD-02 Issued 07
Step 8

Provisional 90 Percent Sanction and Final RFD-06

Section 54(6) provisional refund of 90 percent for zero-rated supplies under Rule 91 (existed since GST inception). Final RFD-06 sanction within 60 days of complete application under Section 54(7). Bank credit via RFD-05. If delayed beyond 60 days, 6 percent simple interest under Section 56; 9 percent for appellate orders. (60 days.)

RFD-04 90 percent provisional RFD-06 final in 60 days RFD-05 bank credit
RFD-0490%7 daysRFD-06100%60 days
Refund Sanctioned 08

Documents Required for LUT Export Refund

For LUT Filing (Form RFD-11)

  • GSTIN and authorised signatory details from GST registration
  • Two independent witness details (name, complete address, occupation - not family of proprietor or partners)
  • Place of filing (city)
  • Previous year's LUT acknowledgement (PDF or JPEG, max 2 MB) - optional
  • DSC for companies and LLPs; EVC (OTP-based) for proprietors and partners

For Refund Filing (Form RFD-01)

  • GSTR-1 with Table 6A populated for every month in refund period
  • GSTR-3B filed for every month in refund period (refund blocked if 3B unfiled)
  • Statement 3 with invoice-level export data, shipping bill or eBRC, BRC/FIRC, port code, EGM details (goods)
  • Statement 3A computation under Rule 89(4) with Net ITC, Turnover of zero-rated supply, Adjusted Total Turnover
  • LUT ARN (Form RFD-11 reference number)
  • Export invoices in foreign currency with INR equivalent
  • For goods: Shipping Bill, EGM (Export General Manifest), BRC or eBRC
  • For services: FIRC, FIRA, eBRC, or bank certificate confirming foreign exchange receipt
  • Declaration under Rule 89(2)(l) - applicant has not been prosecuted
  • Declaration under Rule 89(2)(m) - no other refund claim under any other provision
  • Undertaking on unjust enrichment if refund above Rs 2 lakh
  • CA / Cost Accountant certificate on unjust enrichment under Section 54(8) (above Rs 2 lakh)
  • For SEZ supplies: Form A1 or A2 endorsement by SEZ specified officer

Working Rule 89(4) Example - IT Services Exporter

ParameterAmount (Rs)
Turnover of Zero-Rated Supply (IT services exports under LUT)8,00,00,000
Domestic Turnover (taxable, same FY)1,00,00,000
Adjusted Total Turnover9,00,00,000
Net ITC (input goods + input services + capital goods)1,20,00,000
Maximum Refund = (8,00,00,000 x 1,20,00,000) / 9,00,00,0001,06,66,667
Provisional 90 Percent (Section 54(6))96,00,000 (within 7 days of RFD-02)
Balance 10 Percent (final RFD-06)10,66,667 (within 60 days)

Common LUT Export Refund Challenges and Patron Solutions

ChallengeImpactHow Patron Accounting Solves It
Refund rejection on non-production of FIRC even when eBRC submittedGST officers historically insisted on paper FIRC even where banks issue only eBRC or FIRA per RBI policy; refund summarily rejected via RFD-08 / RFD-06Karnataka HC in Mavenir Systems Pvt. Ltd. v. Union of India (2025) held refund cannot be denied if eBRC, FIRC, or equivalent bank evidence is on record; Patron files with eBRC plus authorised dealer bank certificate citing Mavenir Systems and Rule 89(2) wording
LUT expired before fresh filing; export invoices raised in new FY attracting IGSTLUT validity is one financial year; filing late means every invoice from 1 April attracts IGST upfront, blocking working capital; no retroactive LUTPatron's calendar-driven LUT renewal service files RFD-11 in early March of the prior FY to ensure zero-day-one disruption for the new FY
Statement 3 mismatch with GSTR-1 Table 6A or shipping billRefund delays trace to mismatched invoice numbers, port codes, shipping bill numbers, or BRC/FIRC numbers across Statement 3, GSTR-1, and Customs ICEGATEPatron's pre-filing reconciliation checks every invoice against all three sources before RFD-01 submission - reduces RFD-03 deficiency memos to near-zero
Goods not exported in 3 months OR services FX not realised in 1 yearRule 96A(1) default triggers IGST plus 18 percent interest under Section 50, payable in 15 days; LUT facility withdrawn till paymentPatron computes exposure, files self-assessment in DRC-03, restores LUT, and represents to the proper officer for waiver of interest in genuine commercial-default cases
Software-defaulted LUT choice without working-capital analysisMost accounting software defaults exporters into LUT route without quantifying cash-flow impact vs IGST-paid route; merchant exporters often misroutePatron's diagnostic compares Rule 96A LUT (refund 30-60 days, no upfront IGST) against Rule 96 IGST-paid (refund 7-15 days, IGST locked) with sector-specific recommendation
CA certificate issues for refund above Rs 2 lakhRFD-01 refund applications above Rs 2 lakh require CA / Cost Accountant certificate under Section 54(8) and Rule 89(2)(m); generic certificates rejectedPatron issues compliant CA certificate with engagement letter, working papers, unjust enrichment analysis, and Statement 3A computation cross-reference

LUT and Export Refund Fees and Pricing

Fee ComponentAmount
Patron Accounting Professional Fees (RFD-11 LUT Filing - Annual)Starting from Rs 3,500 per LUT (Exl GST and Govt. Charges)
Single Month / Single Period RFD-01 Refund (turnover up to Rs 5 cr)Rs 8,000 per filing (Exl GST and Govt. Charges)
Quarterly Bunched Refund (multi-month, mid-size)Rs 18,000 per filing (Exl GST and Govt. Charges)
Annual / Multi-Year Refund (high turnover)Rs 35,000 per filing (Exl GST and Govt. Charges)
RFD-08 Show Cause Notice ResponseRs 25,000 per response (Exl GST and Govt. Charges)
Section 107 Appeal (RFD-06 Rejection)Rs 35,000 plus success fee (Exl GST and Govt. Charges)
GSTAT Appeal under Section 109Rs 50,000 plus success fee (Exl GST and Govt. Charges)
Success Fee (Discretionary)1 to 3 percent of refund sanctioned (on actual recovery)
Government / Statutory FeesNo separate government fee for RFD-11 or RFD-01 filing

All fees and charges listed are indicative only and do not constitute a binding offer. Final amounts may vary depending on the volume of work and the complexity involved.

Professional service charges for drafting, filing, and representation are separate from the statutory fees. The exact fee depends on the complexity of the case, disputed amount, and number of hearings required. Contact us for a detailed quote.

Get a free Exports under LUT Refund consultation - Call +91 945 945 6700 or WhatsApp us. No-obligation assessment.

LUT Export Refund Timeline

StageEstimated Timeline
LUT eligibility check and prosecution audit1 working day
Form RFD-11 LUT filing and ARN generationSame day after sign-off
LUT approval status (Approved or Deemed Approved)3 working days from filing
Refund quantum diagnostic and Rule 89(4) computation2 to 4 working days
RFD-01 online filing1 to 2 working days post data readiness
RFD-02 acknowledgement (proper officer)Within 15 days of RFD-01 (Rule 90(2))
RFD-04 provisional refund sanction (90 percent for low-risk)Within 7 days of RFD-02 (Section 54(6) for zero-rated)
RFD-06 final sanction (balance 10 percent)Within 60 days of RFD-02 (Section 54(7))
Interest if refund delayed beyond 60 days6 percent under Section 56; 9 percent for appellate orders
Time limit to file LUT export refund (Section 54(1))2 years from relevant date - ship leaves India (goods) or FX receipt date / invoice date later (services)

Note on FY 2026-27 LUT deadline: Form RFD-11 LUT for FY 2026-27 must be filed before 31 March 2026. There is NO retroactive LUT - every export invoice raised on or after 1 April 2026 without an active LUT attracts upfront IGST that must be paid and refunded separately, blocking working capital for 7 to 15 days minimum. Patron files all client LUTs in early March of the prior FY for zero-day-one disruption.

Key Benefits

4 Reasons Why CA-Led LUT Export Refund Beats DIY or Software-Only

CA-Led LUT vs IGST-Paid Working-Capital Diagnostic

Software defaults exporters into the LUT route without quantifying cash-flow impact. Patron's diagnostic compares Rule 96A LUT (refund 30 to 60 days, no upfront IGST) against Rule 96 IGST-paid (refund 7 to 15 days, 18 percent IGST locked upfront). For low-margin merchant exporters, the 0.1 percent concessional supply route under Notification 40/2017-CT (R) often beats LUT.

Mavenir Systems Case-Law-Backed eBRC Defence

GST officers still routinely reject services export refunds on FIRC non-production. Patron's defence cites Mavenir Systems Pvt. Ltd. v. Union of India (Karnataka HC 2025) which holds that refund cannot be denied if eBRC, FIRC, or equivalent bank evidence is on record. Pre-filing documentation is structured to survive this scrutiny.

Statement 3 Invoice-Level Reconciliation

Patron pre-validates every export invoice against GSTR-1 Table 6A, ICEGATE shipping bill data (for goods), and DGFT eBRC data before RFD-01 submission. This reduces RFD-03 deficiency memos and RFD-08 show cause notices to near-zero - the most common refund delay cause is mismatched documentation.

LUT Calendar Service - Zero-Day-One Disruption

LUT for FY 2026-27 must be on record before 1 April 2026. Patron files all client LUTs in early March of the prior FY, audits prosecution status under Rule 96A(1), and ensures the LUT ARN reference is on every export invoice from day one of the new FY - protecting working capital for the full year.

Trusted by Indian Exporters and IT Services Companies

10,000+ Businesses | 4.9 Google Rating | 50,000+ Documents Filed | 15+ Years of GST and Export Compliance

Trusted By

Hyundai, Asian Paints, Bridgestone, and 200+ Indian exporters across IT services, SaaS, software products, textile, pharma, engineering goods, and SEZ supplies.

Outcome Proof

A Pune-based IT services exporter recovered Rs 1.07 crore in accumulated ITC refund for FY 2024-25 across 12 months under the LUT route. Provisional 90 percent sanctioned in 11 days under Section 54(6); balance Rs 10.7 lakh in 53 days. An initial RFD-08 deficiency memo on FIRC non-production was overturned with Mavenir Systems case-law citation.

With offices in Pune, Mumbai, Delhi, and Gurugram, Patron Accounting serves exporters across India - both in-person and remotely.

LUT Route (Rule 89) vs IGST-Paid Route (Rule 96)

ParameterLUT Route (Rule 89)IGST-Paid Route (Rule 96)
Upfront IGST paymentZERO - LUT covers zero-rating18 percent IGST paid upfront (concessional 0.1 percent for merchant exporters under Notif 40/2017-CT (R))
Refund mechanismForm RFD-01 manual filing under Rule 89Shipping Bill itself is refund application - auto-processed via ICEGATE under Rule 96
Refund timeline30 to 60 days7 to 15 days post-customs clearance
Documentary burdenRFD-01, Statement 3, eBRC/FIRC, LUT ARN, declarationsGSTR-1 Table 6A plus shipping bill - no separate refund app for goods
Net ITC formula (Rule 89(4))Includes input services and capital goodsNot applicable - refund is of IGST paid, not ITC
Working capital impactBest - no IGST locked upfrontWorse - IGST locked till refund (typically 7 to 15 days)
SEZ suppliesLUT route only - Rule 96 does not apply to SEZNot available
Services exporters (IT, SaaS, software)Strongly recommendedPossible but rarely used
Goods exporters (textile, pharma, engineering)AvailableCommon, faster turnaround
Merchant exporters (no own ITC)Suboptimal - little ITC to refundPreferred via 0.1 percent concessional supply
Risk of LUT default (3 months goods, 1 year services)Yes - 18 percent Section 50 interest if not exportedNot applicable

Related GST and Export Compliance Services

LUT export refund work integrates with Patron's broader GST and export compliance stack. Exporters commonly bundle the services below:

  • GST Refund - parent practice covering the full Section 54 refund spectrum including RFD-01 filing, sanction lifecycle, and all refund category mechanics
  • GSTAT Appeal - Exporters (Refund Rejection) - escalation route where RFD-06 is rejected and APL-04 Order-in-Appeal is also adverse on LUT export refund grounds
  • GSTAT Appeal Filing - second appeal under Section 112 in Form APL-05 for any export refund dispute
  • GST Registration - end-to-end registration including HSN classification for new exporters and amendment of existing registration for export operations
  • GST Returns - monthly GSTR-1 Table 6A export reporting and GSTR-3B compliance, the single most important upstream control for refund eligibility
  • GST Notice - covers Section 73, 74, and 74A demand notices and RFD-08 SCN replies before they crystallise into RFD-06 rejection

Legal and Compliance Framework

Section 16 of IGST Act 2017

Defines zero-rated supply (exports + SEZ). Section 16(3) provides two refund routes: LUT/bond without IGST payment with refund of accumulated ITC, or IGST-paid with refund of IGST.

Section 54(1) of CGST Act 2017

2-year limitation from relevant date. For goods exports - date ship/aircraft leaves India. For services - date of FX receipt or invoice, whichever later. Period 01.03.2020 to 28.02.2022 excluded per Notification 13/2022-CT.

Section 54(3)(i) of CGST Act 2017

Substantive right to refund of accumulated ITC for zero-rated supplies.

Section 54(6) of CGST Act 2017

Provisional refund of 90 percent for zero-rated supplies under Rule 91 - existed since GST inception.

Section 54(7) of CGST Act 2017

Final refund order within 60 days of receipt of complete application.

Section 54(8) of CGST Act 2017

Unjust enrichment doctrine; refund credited to Consumer Welfare Fund unless claimant proves no passing on. CA certificate mandatory above Rs 2 lakh under Rule 89(2)(m).

Section 50 and Section 56 of CGST Act 2017

Section 50 - 18 percent simple interest on IGST default if exports not completed within Rule 96A timelines. Section 56 - 6 percent interest on refund delayed beyond 60 days; 9 percent for appellate orders.

Rule 96A of CGST Rules 2017

LUT mechanism. Form GST RFD-11. 3-month export window for goods; 1-year FX realisation for services. Eligibility: not prosecuted for tax evasion above Rs 2.5 crore.

Rule 96 of CGST Rules 2017

IGST-paid route. Shipping bill is the refund application. Auto-processed via ICEGATE.

Rule 89(4) of CGST Rules 2017

Maximum Refund Amount = (Turnover of Zero-Rated Supply x Net ITC) / Adjusted Total Turnover. Net ITC for zero-rated includes input services and capital goods (distinct from Rule 89(5) IDS).

Notification 16/2017-CT, 37/2017-CT, 13/2025-CT, 14/2025-CT, and 20/2024-CT

Notification 16/2017-CT (07.07.2017) introduced Form RFD-11 LUT under Rule 96A. Notification 37/2017-CT (04.10.2017) extended LUT to all eligible exporters. Notification 13/2025-CT (17.09.2025) amended Rule 91(2) for risk-based provisional refund. Notification 14/2025-CT (17.09.2025) notified taxpayers ineligible for provisional refund. Notification 20/2024-CT post 54th GST Council simplified Rules 89 and 96.

Circular 37/11/2018-GST, 125/44/2019-GST, and 135/05/2020-GST

Master export refund circulars - LUT eligibility, Net ITC interpretation, transitional credit treatment, lowest-of-three-amounts test, and cross-FY bunching of refund claims.

Mavenir Systems Pvt. Ltd. v. Union of India (Karnataka HC 2025)

GST refund for export of services cannot be denied if eBRC, FIRC, or equivalent bank evidence is on record. Quashed refund rejection and directed processing with interest. Foundational case-law for IT services exporter refund defence.

Frequently Asked Questions

Common questions about LUT export refund under Section 16 IGST Act and Rule 96A - covering RFD-11 filing, Rule 89(4) formula, BRC/FIRC/eBRC/FIRA, LUT default consequences, and the Mavenir Systems Karnataka HC ruling.

Quick Answers

  • Who can file LUT? Any registered exporter not prosecuted for tax evasion above Rs 2.5 crore under CGST, IGST, Excise, Service Tax, or State VAT (Rule 96A(1)).
  • Which form for LUT? Form GST RFD-11 on GST portal under Services > User Services > Furnish Letter of Undertaking.
  • Which form for refund? Form GST RFD-01, category 'Refund of ITC on Export of Goods or Services without Payment of Tax'.
  • Which formula? Rule 89(4) of CGST Rules 2017 - Net ITC includes input services and capital goods.
  • LUT validity? One financial year (1 April to 31 March). Fresh filing every FY.
  • LUT FY 2026-27 deadline? 31 March 2026 or before first export of FY 2026-27.
  • Default consequence? IGST plus 18 percent Section 50 interest in 15 days if goods not exported in 3 months or services FX not realised in 1 year.

LUT and Export Refund Statutory Deadlines

LUT and export refund deadlines are time-sensitive. Missing the LUT renewal disrupts day-one of the new FY; missing the 2-year refund window is a permanent loss of right.

  • LUT FY 2026-27 filing - before 31 March 2026 (or first export of FY 2026-27); every export from 01 April 2026 attracts IGST upfront if LUT not on record
  • LUT FY 2027-28 filing - before 31 March 2027
  • Goods export under LUT - within 3 months of invoice date (Rule 96A(1)(a)); IGST plus 18 percent Section 50 interest payable in 15 days on default
  • Services FX realisation under LUT - within 1 year of invoice (Rule 96A(1)(b)); same default consequence
  • RFD-01 refund filing - within 2 years of relevant date (Section 54(1)); permanent loss of refund right
  • RFD-02 acknowledgement - within 15 days of RFD-01 (Rule 90(2)); escalate via grievance under Rule 90 if officer fails
  • RFD-04 provisional 90 percent (zero-rated) - within 7 days of RFD-02 (Section 54(6))
  • RFD-06 final sanction - within 60 days of RFD-02 (Section 54(7)); 6 percent Section 56 interest; 9 percent for appellate orders
  • Section 107 appeal - within 3 months of refund rejection; 10 percent pre-deposit
  • Section 112 GSTAT appeal - within 3 months of Appellate Authority order; additional 10 percent pre-deposit

Engage Patron Accounting in early March for FY 2026-27 LUT renewal - share 12 months of GSTR-1, GSTR-3B, GSTR-2B, and sample shipping bill or eBRC. Call +91 945 945 6700 or WhatsApp us now.

Talk to Patron's LUT and Export Refund Team

GST refund on exports under LUT is the working-capital backbone of Indian exporters - especially IT services, SaaS, software products, and SEZ suppliers where the IGST-paid route under Rule 96 is impractical. Section 16 of the IGST Act 2017 establishes zero-rating as the conceptual foundation; Rule 96A of the CGST Rules 2017 operationalises the LUT mechanism via Form GST RFD-11; and Rule 89 (with the Rule 89(4) formula) governs the refund of accumulated ITC via Form GST RFD-01.

The Notification 20/2024-Central Tax post the 54th GST Council meeting simplified Rule 89 and Rule 96 omissions; the Karnataka High Court ruling in Mavenir Systems Pvt. Ltd. (2025) restored the substantive right against summary rejection on FIRC technicalities; and the November 2025 risk-based provisional refund mechanism (Notification 13/2025-CT) accelerates low-risk sanctions. The LUT for FY 2026-27 must be on record before 31 March 2026 - missing it is a working-capital disaster, not just a compliance lapse.

Patron Accounting LLP brings 15+ years of GST refund, RFD-11 LUT filing, RFD-01 export refund, and zero-rated supply litigation experience across 200+ Indian exporters, with four physical offices in Pune, Mumbai, Delhi, and Gurugram. Exporters gain CA-led LUT-vs-IGST diagnostic, Mavenir Systems-backed eBRC defence, Statement 3 invoice-level reconciliation, and litigation-grade documentation that survives RFD-08 scrutiny and Section 107 or 112 appeal.

Book a Free Consultation - No Obligation.

Related GST and Litigation Services

End-to-end GST refund coverage - from RFD-11 LUT and RFD-01 filing through to GSTAT Section 112 escalation for refund rejection appeals.

Content Created: 7 May 2026  |  Last Updated: 11 May 2026  |  Next Review: 7 August 2026  |  Reviewed By: CA & CS Team · Patron Accounting LLP

Reviewed every 3 months under Tier 1 freshness cycle. Triggers for earlier review: any GST Council notification, CBIC circular on Rules 89 or 96, RBI circular on FIRC/BRC/eBRC, FY-specific LUT deadline, or High Court ruling on remittance proof.

10,000+
Happy Clients

Helping businesses stay compliant and stress-free.

15+
Years Experience

Deep expertise in GST, Income Tax, ROC & business compliance.

50,000+
Documents Filed

Returns, registrations, and filings handled accurately.

4.9★
Client Rating

Trusted by entrepreneurs, startups, and growing businesses.

ISO
Certified

Professional standards and documented processes.

SSL
Secure

Your financial and business data is fully protected.