Skip to content
Kanoons.®
Resource Center All Services Industries Calculators Due Dates Knowledge Contact Us
Notifications

Create an account Forgot password?

Practice Areas

Startup & Compliances GST, tax & notices IP Rights All Services

Resources

Resource Center Industries Calculators Due Dates Knowledge FAQs Contact Us
Esc

When exporters and SEZ suppliers need Form GST RFD-11 LUT under Rule 96A, who must furnish a bond instead, annual FY validity, and how zero-rated supplies without IGST actually work.

By Kanoons Editorial Team · 12 min read · Last verified 2026-10-06

SummaryShow summaryHide summary

Summary

Zero-rated supplies under section 16 of the IGST Act (exports and SEZ supplies) can move without charging IGST only when a Letter of Undertaking (LUT) — or, in narrow cases, a bond — on file before the supply. The form is GST RFD-11 under Rule 96A of the CGST Rules. Most exporters use the portal LUT path under Notification No. 37/2017-Central Tax; only persons prosecuted for tax evasion of ₹2.5 crore+ are pushed to the bond track. Verified against Circular 8/8/2017-GST, Notification 37/2017-Central Tax and the GSTN LUT user guide on 6 October 2026.

  • Zero-rated without IGST → furnish LUT / bond in Form RFD-11 before the supply (Rule 96A).
  • Default facility: LUT for all registered persons except prosecuted ₹2.5 Cr+ tax-evasion cases (Notif. 37/2017 + Circular 8/8/2017).
  • LUT is FY-scoped on the GST portal — renew each financial year.
  • EOU inward supplies are not zero-rated; SEZ supplies without IGST are.
  • Service path: LUT Filing.

Zero-rated supplies in one paragraph

Under the IGST framework, exports and supplies to SEZ units/developers are zero-rated. You may:

1. Supply without payment of IGST under bond / LUT, then claim refund of unutilised ITC where eligible; or 2. Supply with payment of IGST and claim refund of the tax so paid.

LUT is the operational key to option 1 for almost every compliant exporter. Option 2 still needs clean export documentation and a refund file — see GST Refund.

Bond vs LUT — who uses which

InstrumentWhoCollateralPractical notes
LUT (RFD-11)Registered person not prosecuted for tax evasion ≥ ₹2.5 croreUndertaking only (self-declaration normally accepted; post-facto verification possible)Portal filing; FY validity
Bond (RFD-11)Prosecuted for tax evasion ≥ ₹2.5 crore under CGST / IGST / existing lawBond on stamp paper + bank guarantee (Circular 8 describes 15% of bond amount in the master clarification chain)Running bond covering estimated tax on exports

Circular 8/8/2017-GST is still the master clarification: Notification 37/2017-Central Tax superseded the narrower Notification 16/2017 status-holder / remittance tests and opened LUT to all exporters subject to the prosecution carve-out.

How to furnish LUT on the portal

1. Confirm you will make zero-rated supplies without IGST in the current FY. 2. Login at www.gst.gov.in → Services → User Services → Furnish Letter of Undertaking (LUT). 3. Complete Form GST RFD-11 for the financial year, with the authorised signatory executing the undertaking (proprietor / working partner / MD / CS / duly authorised person — per Circular 8). 4. Submit with EVC / DSC as applicable; download the acknowledgement. 5. Make the zero-rated supply only after LUT is on record for that FY.

Self-declaration that you have not been prosecuted for the ₹2.5 crore threshold is ordinarily accepted; officers may verify later. Do not file LUT in someone else’s name or for a GSTIN that will not make the supply.

Mid-article CTA: File or renew your GST LUT → Cross-sell: GST Refund, GST Return Filing, GST Registration.

Reporting zero-rated supplies correctly

  • Report exports / SEZ supplies in the correct GSTR-1 tables (and pay / adjust via GSTR-3B as the portal design requires for your option).
  • Keep shipping bills, export invoices, FIRC / remittance evidence (for services), and SEZ endorsements in the refund / audit file.
  • If you are on e-invoicing, generate IRNs for export / SEZ documents as notified — see GST e-invoicing threshold guide.
  • Option-with-IGST exporters still need a disciplined refund calendar; LUT exporters need ITC refund hygiene instead of IGST refund hygiene.

SEZ vs EOU — do not mix the labels

Circular 8 is blunt: zero rating is not applicable to supplies to EOUs. Bill an EOU like any other taxable domestic supply unless a separate exemption notification applies to your facts. SEZ supplies without IGST, by contrast, sit inside the zero-rated + LUT design when you choose the without-payment path.

Failure modes that create demand notices

  • Exporting without LUT / bond, then discovering Rule 96A exposure when IGST was never paid.
  • Using last year’s LUT into April without renewing for the new FY.
  • Treating EOU invoices as zero-rated.
  • LUT on one GSTIN while invoices go out on another.
  • Bond amount too low for the running export tax exposure (bond track only).

Related reading on this site

  • How to file GSTR-1
  • GST e-invoicing threshold guide
  • Input tax credit basics
  • E-commerce seller GST / TCS compliance

Primary sources

  • Circular No. 8/8/2017-GST (LUT / bond master circular)
  • Notification No. 37/2017-Central Tax (LUT facility extended under Rule 96A)
  • Rule 96A, CGST Rules, 2017
  • GSTN — Furnishing of LUT
  • gst.gov.in · cbic-gst.gov.in

How Kanoons can help

LUT is a five-minute portal task when nothing is wrong — and a notice magnet when the FY lapses mid-shipment. Kanoons files and renews RFD-11 LUTs, flags bond-track facts, and keeps zero-rated reporting aligned with returns and refunds.

Primary: File or renew your GST LUT

Also relevant:

  • GST refund for export / ITC claims
  • GST return filing for outward zero-rated tables
  • GST registration if you are still unregistered
  • Bookkeeping that supports refund working papers

Questions about your facts before you file? Contact the Kanoons team.

Disclaimer

General information only — not legal or tax advice. Kanoons is not a law firm or accounting firm. LUT eligibility, bond / bank-guarantee quantum, SEZ procedural endorsements and refund timelines are fact-specific; confirm against the live notifications, Circular 8 and the GST portal before exporting without IGST. See our Disclaimer.

Frequently asked questions

What is a GST LUT?

A Letter of Undertaking in Form GST RFD-11 under Rule 96A of the CGST Rules. It lets an eligible registered person make zero-rated supplies (exports of goods/services or supplies to SEZ units/developers) without payment of integrated tax, subject to the conditions in the LUT and the IGST Act.

Who can file LUT instead of a bond?

Notification No. 37/2017-Central Tax (read with Circular No. 8/8/2017-GST) extends LUT facility to all registered exporters under Rule 96A except persons who have been prosecuted for tax evasion involving an amount of ₹2.5 crore or more under the CGST Act, IGST Act or existing law. Those prosecuted persons must furnish a bond (with bank guarantee as prescribed).

How long is an LUT valid?

LUT is furnished for a financial year (portal flow: Services → User Services → Furnish Letter of Undertaking). File it before making zero-rated supplies without IGST in that FY, and renew for each new financial year before the first such supply.

Do supplies to EOUs qualify as zero-rated under LUT?

No. Circular 8/8/2017-GST clarifies that zero rating does not apply to supplies to EOUs; those supplies are taxable like other domestic supplies. EOUs themselves can zero-rate their own exports like any other exporter.

Can I export on payment of IGST instead of using LUT?

Yes. Zero-rated supplies may be made on payment of IGST with a subsequent refund claim, or without payment of IGST under bond/LUT. Choose the path that matches your working-capital and refund timeline — LUT avoids locking IGST into the refund queue on every shipment.

Home / Knowledge / …
Verified

GST LUT for Exports: Bond vs LUT, Filing and Zero-Rated Supplies

On this page

    Related guides

      How Kanoons can help

      Filing, objections and compliance calendars — get a clear next step from the team.

      Talk to Kanoons Browse services
      Related

      More on this topic

      Article not found. Browse the knowledge centre.

      Kanoons.®

      Kanoons Law and Tax Consultants Private Limited — advisory, documentation, business registration, taxation, compliance management and IP filings for Indian businesses.

      Due-date reminders by email.

      Practice Areas
      Startup & Compliances GST, tax & notices IP Rights Industries
      Resources
      Resource Center Knowledge Centre Calculators Due Date Reminders FAQs Client Portal
      Company
      Contact Us Client Portal Disclaimer Privacy Policy Terms & Conditions Refund & Returns Policy
      Contact us

      #404, MQ Splendor, Above HDFC Bank, Pillar No. 210, Airport Road, Upperpally, Hyderabad, Telangana, India

      +91 90000 13560 / 90 support@kanoons.com
      © 2026 Kanoons Law and Tax Consultants Private Limited. All rights reserved.

      Kanoons.com is owned and operated by Kanoons Law and Tax Consultants Private Limited, a registered consultancy providing services in advisory, documentation, business registration, taxation, compliance management and intellectual property filings across India. Kanoons is not a law firm or accounting firm and does not offer legal representation, statutory audits, attestation or certification services — all specialised professional work is coordinated through authorised, independently qualified professionals in accordance with applicable Indian laws.

      All content on this website is intended for general informational purposes only and should not be interpreted as legal, financial or tax advice. Use of this website or communication through it does not create any attorney–client, accountant–client or other professional relationship with the company. Users are encouraged to seek independent professional advice before making decisions based on content or services provided herein. We are committed to safeguarding user information in accordance with applicable data protection laws, including the Information Technology Act, 2000, and rules thereunder.

      Your access to and use of this website is subject to our Terms & Conditions, Privacy Policy, Refund and Returns Policy and Disclaimer. By continuing to browse or interact with the site, you acknowledge and agree to these terms. The wordmark “Kanoons®”, its logo and all related brand assets are the exclusive intellectual property of Kanoons Law and Tax Consultants Private Limited; unauthorised use, imitation or reproduction is strictly prohibited and may lead to civil or criminal action.