The question
1 answer
Practising chartered accountants at ERPCA · 15 Sep 2026
In short
Almost certainly not. File the LUT now; the CBIC has instructed officers to accept a delayed LUT and treat the exports made in the meantime as covered.
The rule is that a Letter of Undertaking in Form RFD-11 should be furnished before exporting without payment of IGST, and it is valid for one financial year. Circular 37/11/2018-GST (paragraph 4) states that where an LUT is filed late, the delay may be condoned and the facility allowed on an ex post facto basis, provided the exporter was otherwise eligible. Eligibility is simple: you must not have been prosecuted for evasion above ₹2.5 crore. File the LUT on the portal today (it is accepted instantly without officer approval), keep the acknowledgement, and quote this circular if a notice ever arrives.
Two things to put in order: make sure each export invoice carries the words "supply meant for export under LUT without payment of IGST", the client's address outside India, and the place of supply; and reconcile the ₹70 lakh of receipts with FIRCs or bank advices showing convertible foreign exchange. Exports must be realised within nine months of the invoice under FEMA; unrealised invoices beyond that period lose zero-rating and attract tax with interest.
Also check that these invoices were reported in GSTR-1 table 6A as exports without payment of tax and in GSTR-3B table 3.1(b); if they went into the regular taxable line by mistake, amend in the next GSTR-1.
Next step
File the LUT now, add a recurring reminder for the first week of April, and run an FIRC reconciliation for April to date.
General guidance on the facts given, not an engagement. Law as on the date of the answer.
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