# Exporting Under LUT: How to Organise Undertakings and Invoice Records

Organise exports under LUT by linking the relevant GSTIN and financial-year undertaking with each covered invoice and the evidence that its conditions are met. Rule 96A governs the bond or LUT framework for export without IGST payment. A filed undertaking is not proof that every transaction qualifies as an export, and it does not remove the need to monitor shipment or service-receipt obligations. Keep the route evidence accessible before billing.

## Check eligibility and the relevant registration

Confirm that the business can furnish an LUT under the applicable notification and conditions, rather than requiring a bond. Identify the supplying GSTIN and the period for which the undertaking is furnished. A group business's common legal name does not make another registration's file a substitute.

Keep the eligibility decision, authorised signatory information and any relevant exception review. Do not assume a past-year approval resolves every later year or registration. Where the facts are unusual, obtain the specific missing information before allowing the without-payment invoice option to become a routine sales default.

## Preserve the filed undertaking and acknowledgment

GSTN's RFD-11 manual provides a financial-year selection and describes filing and acknowledgment. Save the submitted form, ARN, acknowledgment and relevant attachments or records, with the GSTIN and year visible in the filename or register. A saved draft is not the same as a filed application.

Record who filed and the actual status shown. Use the applicable authorised-signatory and authentication process rather than relying on an old universal instruction about one signing method. Keep access credentials out of the document file; the file should contain evidence of the completed action, not the means to impersonate the signatory.

## Create an invoice coverage register

Use columns for GSTIN, financial year, LUT reference, invoice number and date, customer, supply type, value and route. Add goods-export or service-receipt monitoring fields as appropriate. Link the actual invoice copy and supporting evidence, not just a tick saying “LUT available.”

Review the first invoices around the financial-year boundary. A recurring template can continue displaying last year's reference even after staff file a new undertaking. Correct the approved source configuration and test the final document. Do not edit historical invoice copies simply to show the current year's reference.

## Verify export qualification separately

Goods must meet the relevant export facts, and services must satisfy all section 2(6) conditions. Foreign customer identity, place of supply, permitted payment and establishment relationships require their own evidence. The LUT does not override a service whose reviewed place of supply remains in India.

For SEZ supplies, examine the authorised-operations and other applicable requirements separately. A without-payment route can have relevant LUT treatment, but an address in a zone does not establish every condition. Keep the underlying eligibility conclusion alongside the route record so billing staff can see what was approved.

## Track the Rule 96A obligations

The ordinary Rule 96A framework contains a goods-export period measured from invoice and a service-payment period, with specified extension provisions and consequences. The commonly applicable base periods are three months for goods export and one year for relevant service receipts, subject to the operative text, permitted extensions and particular facts.

Record the applicable start date and evidence of completion or extension. Keep GST monitoring separate from current foreign-exchange realisation requirements. An RBI or authorised-dealer issue and a GST route condition may have different clocks. Do not let a bank's commercial follow-up date silently replace the date required by the relevant tax rule.

## Illustrative goods and services register

Suppose a reviewed goods export invoice is ₹2,40,000 and a separate qualifying service invoice is ₹90,000 under the relevant valid LUT route. The goods row needs actual export and shipping evidence. The service row needs delivery and permitted-payment evidence, with the applicable receipt timeline.

If half the goods remain unshipped, do not close the whole ₹2,40,000 row because one transport document exists. If the service customer pays ₹30,000 initially, track ₹60,000 outstanding. The zero IGST payment under the approved route does not mean the commercial value or open obligation is zero.

## Match wording and tax fields to the route

Use the current prescribed Rule 46 endorsement for the actual export or SEZ arrangement. Check that invoice tax fields, route code, ledger and outward-supply reporting agree. A no-payment endorsement alongside a positive IGST collection needs review before release.

Do not describe a LUT export as an ordinary exempt sale merely because no IGST is collected under that route. The zero-rated framework has different credit and refund implications, subject to conditions. Keep refund eligibility and claim records separate from the fact that an LUT was filed.


Give each open obligation an action owner and a completion document. Dispatch staff can provide actual export evidence, while the service or collection team can resolve a missing receipt allocation. A register showing only a future due date is incomplete if nobody knows what proves closure. Review upcoming exceptions early enough to obtain the required evidence or assess the applicable next action.
## Resolve overdue or changed transactions promptly

Review old open invoices, unshipped balances, cancelled orders and unpaid services. Identify whether an extension, tax-and-interest consequence or another adjustment requires action under the applicable provisions. A customer's email promising payment does not itself provide a statutory extension.

Preserve the original invoice and chronology when correcting records. The LUT file works when staff can identify which undertaking covers an invoice, what evidence remains due and who must act before a condition fails. That turns a once-a-year filing into a usable export control throughout the year.

## Sources and references

- [CBIC CGST Rules: invoice, voucher, valuation and record provisions](https://cbic-gst.gov.in/pdf/01062021-CGST-Rules-2017-Part-A-Rules.pdf)
- [ICAI GST Acts and Rules, November 2025 edition, government-hosted statutory compilation](https://tgct.gov.in/tgportal/Docs/Notifications/TGST/GST%20Act(s)%20and%20Rule(s)-Bare%20Law%20(November,%202025)%20with%20cover%20page%20complete.pdf)
- [CBIC IGST Act: nature and place of supply provisions](https://cbic-gst.gov.in/hindi/IGST-bill-e.html)
- [GSTN manual: filing and acknowledging the financial-year LUT in Form GST RFD-11](https://tutorial.gst.gov.in/userguide/refund/Furnishing_of_Letter_of_Undertaking.htm)