GST LUT Filing - Form RFD-11 Annual Renewal Under Rule 96A

Form GST RFD-11 is the gateway to zero-rated GST exports without working capital lock-up. Section 16 of the IGST Act 2017 grants the zero-rated facility for exports and SEZ supplies. Two routes are available - either pay IGST and claim refund (Rule 96 auto-route), or supply under Letter of Undertaking (LUT) or Bond without payment of IGST and claim refund of accumulated ITC (Rule 89 LUT route). The LUT route is structurally faster for working capital because it skips the IGST outflow entirely; the LUT is the instrument that authorises this no-IGST supply.

Rule 96A of the CGST Rules 2017 is the foundational provision for LUT/Bond. Notification 37/2017-Central Tax dated 04 October 2017 widened eligibility to all exporters except those prosecuted for tax evasion exceeding Rs 2.5 crore in any 5-year period (in which case Bond + Bank Guarantee 15 percent of bond amount is required). Circular 40/14/2018-GST dated 06 April 2018 enabled the online deemed approval mechanic - LUT is approved automatically on ARN generation. Patron Accounting LLP files LUT for 200+ exporters and SEZ suppliers annually with same-day deemed approval and proactive 31 March renewal scheduling.

Content is reviewed quarterly for accuracy.

LUT validity is strictly one financial year - 1 April to 31 March. Patron's annual cycle calendar below covers the upcoming FY 2027-28 schedule and the late-filing remedies for those who missed prior deadlines.

Critical point - FY 2026-27 LUT already effective: If you have not yet filed your FY 2026-27 LUT (validity period 01.04.2026 to 31.03.2027), every export invoice raised since 01.04.2026 without LUT attracts IGST. Patron's same-day late-filing service captures the LUT immediately; gap-period exports proceed under Rule 96 IGST-paid route with subsequent auto-refund - blocked working capital. The forward exports from late-filing date onwards proceed under LUT zero-rated route.

If you are a new exporter who has not yet registered under GST, complete GST registration before initiating any LUT filing. For exporters of physical goods, IEC registration is also a separate mandatory requirement under the Foreign Trade Policy.

Keep the following documents ready before filing each annual LUT cycle. Patron Accounting maintains a digital document vault per client with year-on-year LUT acknowledgement archive.

For LUT filing (standard path):

• GSTIN active and not suspended.
• GST registration certificate showing eligible export activity.
• Two witnesses - PAN, complete address, signature ready.
• Authorised signatory PAN and DSC (companies/LLPs) or Aadhaar (individuals/proprietors).
• Previous year LUT acknowledgement (for renewal cases).
• Section 132 prosecution clearance check (no evasion above Rs 2.5 crore in past 5 years).
• Last 12 months export turnover summary (for record-keeping).

For Bond path (where LUT eligibility lost):

• Bond format in prescribed RFD-11 Bond template.
• Bank Guarantee from scheduled bank - 15 percent of bond amount.
• Bond amount typically equal to projected annual IGST liability if no LUT.
• Manual filing with jurisdictional Commissioner.
• Acknowledgement issued by Commissioner.
• Renewal of Bank Guarantee aligned with FY cycle.

For LUT cancellation defence:

• Notice of cancellation from Department citing breach (3-month export missed, service realisation delayed, IGST not paid).
• Counter-evidence - shipping bills, export realisation evidence, FIRC, EGM, EBRC.
• Circular 37/11/2018-GST citation for Commissioner extension where applicable.
• Section 50 interest already paid evidence (DRC-03 challan).

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 LUT Filing consultation - Call +91 945 945 6700 or WhatsApp us. No-obligation assessment.

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Outcome proof: A Pune IT services exporter recovered LUT zero-rated status with same-day filing on 02 April 2026 after missing the 31 March deadline. The 2 invoices issued before LUT filing were processed under Rule 96 IGST-paid route with shipping-bill auto-refund within 21 days; exports from 02 April onwards proceeded under LUT with no working capital lock-up. Annual subscription locked in for FY 2027-28 to FY 2029-30 at Rs 10,000 total.

Trusted by Hyundai, Asian Paints, Bridgestone, and 200+ Indian exporters and SEZ suppliers across pharma, IT services, engineering, textile, electronics, chemical, and auto components sectors filing annual LUT cycles. With offices in Pune, Mumbai, Delhi, and Gurugram, Patron Accounting serves exporters across India - both in-person and remotely.

LUT filing is the upstream prerequisite for LUT-route exports. Common service bundles for exporters and SEZ suppliers:

• GST refund (general) - the parent practice covering Section 54 refund spectrum including accumulated ITC refund under LUT route via Form GST RFD-01.
• GST returns filing - monthly GSTR-1 and GSTR-3B that underpin every LUT-route refund claim.
• GST annual returns - GSTR-9 and GSTR-9C reconciliation ensures clean year-end position for LUT-route exporters.
• GST audit support - for exporters above the prescribed turnover threshold.
• GST registration - end-to-end registration for new exporters before initiating any LUT filing.
• IEC registration - mandatory for exporters of physical goods under the Foreign Trade Policy.
• GSTAT appeal for exporters - second-tier appellate route where refund or LUT-related disputes escalate beyond Section 107.

Rule 96A of CGST Rules 2017: Any registered person availing the option to supply goods or services for export without payment of integrated tax shall furnish, prior to export, a bond or a Letter of Undertaking in Form GST RFD-11 to the jurisdictional Commissioner, binding himself to pay the tax due along with the interest specified under Section 50(1) within 15 days after expiry of three months from the date of issue of invoice for export (for goods), or one year from the date of invoice for export (for services where payment not received in convertible foreign exchange or INR where permitted by RBI).

Notification 37/2017-Central Tax dated 04 October 2017: Foundational widening of LUT eligibility. Any registered person who intends to supply goods or services for export without payment of integrated tax shall be eligible for submission of LUT in place of bond except those who have been prosecuted for any offence under the CGST Act or under any of the existing laws in force in a case where the amount of tax evaded exceeds two hundred and fifty lakh rupees. The five-year look-back applies.

Circular 8/8/2017-GST dated 04 October 2017: Master clarification on LUT and Bond mechanics. Sets out conditions for LUT eligibility, Bond format and Bank Guarantee percentage (15 percent of bond amount), filing procedure with jurisdictional Commissioner, witness requirements, and validity period.

Circular 37/11/2018-GST dated 15 March 2018: Commissioner can extend the 3-month export window where exports are delayed for genuine reasons. The extension is requested via written representation to the jurisdictional Commissioner with supporting evidence such as shipment delays, regulatory clearance, or force majeure.

Circular 40/14/2018-GST dated 06 April 2018: Foundational deemed approval mechanic. The LUT is deemed to be accepted as soon as ARN is generated on online filing. No manual approval signature is required from the Department. The exporter can immediately reference the ARN on export invoices and shipping bills.

Section 16 of IGST Act 2017: Zero-rated supply means (a) export of goods or services or both; or (b) supply of goods or services or both to a Special Economic Zone developer or unit. A registered person making zero-rated supply shall be eligible to claim refund either by exporting under LUT/Bond and claiming refund of unutilised ITC OR by paying IGST and claiming refund of tax paid.

Section 50(1) of CGST Act 2017: Interest at 18 percent per annum on delayed IGST payment where LUT undertakings are breached.

FEMA Master Direction No.16/2015-16 (RBI): RBI direction setting outer realisation period for export of goods and services - currently 15 months from invoice date. Rule 96A(1)(b) reads with this Master Direction to give the longer of 1 year (statutory) or FEMA period as the service realisation window.

Section 132 of CGST Act 2017: Prosecution provision - Rs 2.5 crore evasion threshold for LUT eligibility loss per Notification 37/2017-CT carve-out.

Government references: GST portal, CBIC GST notifications and circulars, RBI FEMA Master Direction, and indiacode.nic.in (CGST Act 2017 and IGST Act 2017).

LUT deadlines run off the FY cycle. Patron tracks each milestone:

1. Annual LUT filing deadline - 31 March of preceding FY. Exports without LUT attract IGST under Rule 96.
2. LUT validity - 1 April to 31 March of the FY filed for. After 31 March, fresh LUT required.
3. 3-month export window for goods (Rule 96A(1)(a)) - from invoice date. IGST plus 18 percent interest if missed.
4. 1-year service realisation window (Rule 96A(1)(b)) - from invoice date. FEMA 15-month period applies if longer.
5. IGST plus interest payment on default - within 15 days of 3-month window expiry, via Form GST DRC-03.
6. Commissioner extension request - before 3-month window expires, per Circular 37/11/2018-GST.
7. LUT cancellation reply - within 15 days of cancellation notice. Or proceed to Bond + Bank Guarantee.
8. Annual Patron reminder cycle - 30 January, 28 February, 15 March. Renewal typically by 10 March.

Get your annual LUT filed early - Call +91 945 945 6700 or WhatsApp us. Free LUT eligibility check within 4 business hours.

Form GST RFD-11 is the annual Letter of Undertaking (LUT) prescribed under Rule 96A of the CGST Rules 2017 - the upstream prerequisite for any zero-rated GST exports under the LUT route. The instrument operates simply - file once a year before 31 March, get deemed approval on ARN per Circular 40/14/2018-GST, and export without IGST outflow for the next 12 months. Notification 37/2017-CT widened eligibility to all exporters except those prosecuted for tax evasion above Rs 2.5 crore in any 5-year period. The 3 undertakings are codified - 3-month export of goods, 1-year or FEMA 15-month service realisation, and IGST plus 18 percent interest on failure.

Patron Accounting LLP brings 15+ years of GST refund and LUT filing experience for 200+ exporters and SEZ suppliers across pharma, IT services, engineering, textile, electronics, chemical, and auto components sectors with four offices in Pune, Mumbai, Delhi, and Gurugram. Exporters gain CA-led same-day eligibility verification, witness PAN pre-verification, deemed approval same-day filing, annual reminder system preventing 31 March bottleneck, and Bond fallback expertise where LUT eligibility is lost.