Advisory for Maintenance of Export Documents

Advisory for Maintenance of Export Documents

Published on November 02, 2025 · By Admin

Blog Details

In case of export without payment of tax under Letter of Undertaking (LUT) as per Rule 96A of the CGST Rules, 2017, the following documents and provisions apply:

1. Statutory Provisions

  • Section 16(3)(a) of the IGST Act, 2017 – Export of goods or services may be made without payment of IGST under LUT/Bond, subject to prescribed conditions.
  • Rule 96A of the CGST Rules, 2017 – Provides for furnishing of LUT/Bond prior to export.
  • Notification No. 37/2017–Central Tax, dated 4.10.2017 – Prescribes eligibility, validity, and form of LUT.

???? 2. Documents Required for Export Without Payment of Tax

Document

Purpose / Description

a. Letter of Undertaking (LUT)

Must be furnished online in FORM GST RFD-11 on the GST portal. Valid for the financial year.

b. Export Invoice

Should clearly mention “SUPPLY MEANT FOR EXPORT UNDER LUT WITHOUT PAYMENT OF IGST”. Must include all particulars as per Rule 46 of the CGST Rules.

c. Shipping Bill / Bill of Export

Acts as the document evidencing export of goods. For services, proof of receipt of payment in convertible foreign exchange or INR (where permitted).

d. Transport / Courier Documents

e.g., Airway Bill, Bill of Lading, etc. evidencing actual movement of goods.

e. Bank Realisation Certificate (BRC) / Foreign Inward Remittance Certificate (FIRC)

Proof of receipt of export proceeds as per Rule 96A(1)(b).

f. Packing List

Details of contents and quantity of export consignment.

g. Export General Manifest (EGM)

Filed by the carrier; required for validating export in customs records.

3. Compliance Requirements

  • LUT must be furnished before export; otherwise, export is treated as without authorization.
  • Export proceeds must be realized within the period prescribed under FEMA (currently 9 months unless extended).
  • In case proceeds are not realized within time, exporter must pay IGST along with interest within 15 days after expiry of such period (Rule 96A(1)(b)).
  • Goods must be Exported within 3 months from Invoice Date.

4. Advisory (Best Practices)

  • Ensure timely filing of LUT each financial year.
  • Maintain proper documentation for audit and refund verification.
  • Cross-verify shipping bill details with GSTR-1 Table 6A to avoid mismatch in export data.
  • Use electronic invoices where applicable for better traceability.
  • Regularly reconcile export data with ICEGATE and GSTN.