GST problem guide · updated October 2026

Claiming refund of unutilised ITC on exports under LUT

If you export goods or services under a Letter of Undertaking (LUT) without paying IGST, your input tax credit builds up and you can claim it back as a refund through Form RFD-01. Unlike IGST-paid exports, this refund is not automatic, so the application and documents decide how smoothly it goes.

Who can claim

Section 54(3) of the CGST Act allows refund of unutilised ITC for zero-rated supplies made without payment of tax. You need a valid LUT filed in RFD-11 for the financial year, exports reported in GSTR-1 as without payment, and GSTR-3B filed for the period.

How the amount is calculated

Rule 89(4) gives the formula: refund equals turnover of zero-rated supplies multiplied by net ITC, divided by adjusted total turnover. Net ITC here means credit on inputs and input services, not capital goods. For services, export turnover counts only where payment has been received in the period. Keep the working in a spreadsheet, as officers check each figure.

Filing RFD-01

  • Go to Services, Refunds, Application for Refund and choose export of goods or services without payment of tax.
  • Select the period; you can club periods but cannot cross financial years in one claim.
  • Upload Statement 3 with shipping bill or invoice details, and for services the bank realisation or FIRC details.
  • Upload invoices of inward supplies if asked, and a declaration and undertaking.
  • The ITC claimed is debited from the credit ledger on filing. Note the ARN.

Deadlines and pitfalls

The claim must be filed within two years of the relevant date: for goods, the date the ship or aircraft leaves India; for services, the date of receipt of payment, or the invoice date where payment was received in advance. The officer must issue an acknowledgement or a deficiency memo within 15 days.

  • Exporting without a current year LUT.
  • Including capital goods ITC in net ITC.
  • Counting service exports where money has not been received.
  • Mismatch between Statement 3 and GSTR-1.

Get it handled for you

Refund stuck or rejected? We rebuild the claim, reply to deficiency memos and follow up with the refund officer in writing. Call or WhatsApp +91 63677 44602, or use the form below.

This guide explains the law in general terms as of October 2026. Time limits and requirements can depend on the facts of your case and on the notice you received.

Questions

Refund: export under LUT — FAQs

Is provisional refund available?+
Section 54(6) provides for provisional refund of 90 percent for zero-rated supply claims, subject to conditions.
Can I claim monthly?+
Yes, claims can be filed for a tax period or a group of periods within a financial year.
What if ITC is less than the formula amount?+
The refund is limited to the lower of the formula amount and the balance in the credit ledger at the time of filing.
What if I exported without a valid LUT?+
Exports without LUT and without paying IGST are a compliance gap. File the LUT immediately and take advice on whether to pay IGST with interest on those exports, since the officer may question the refund for that period.
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