Can I file an LUT in the middle of the financial year?

Many exporters do not start the financial year with an LUT. A motion designer may register for GST in August after crossing the threshold, or a two-person agency may sign its first overseas client in December. In both cases the question is the same: is it too late to file?

Is there a deadline for filing an LUT in the year?

No fixed calendar deadline applies. Rule 96A(1) of the CGST Rules says a registered person who wants to export without paying integrated tax must furnish a bond or LUT in FORM GST RFD-11 "prior to export".¹ The trigger is your first export invoice without IGST, not 1 April.

When you file, the portal asks you to select the financial year the LUT is for.⁵ The LUT is valid for the whole financial year in which it is tendered, under para 2(b) of CBIC Circular No. 8/8/2017-GST.² In practice, an LUT filed on 10 September 2026 lets you invoice without IGST from that day until 31 March 2027.²³

When is a mid-year LUT effective?

A mid-year LUT is effective as soon as the portal generates the Application Reference Number (ARN). CBIC Circular No. 40/14/2018-GST says the LUT is deemed accepted at that point, with no physical submission.³ Quote the ARN and date on your invoice template from then on. The steps are in how to file an LUT on the GST portal.

What about export invoices raised before the LUT?

Invoices raised before the LUT are the tricky part. If you were registered and issued export invoices without IGST before filing, those invoices were not covered when issued.¹ CBIC Circular No. 125/44/2019-GST, para 44, says the substantive benefit of zero rating should not be denied where exports are established, and that the delay in furnishing the LUT may be condoned and allowed on an ex post facto basis, depending on the facts.⁴ That is discretionary. The other route is to pay IGST on those invoices and claim it back; see export of services without an LUT and the answer on forgetting to file an LUT.

If you were not registered when you issued those invoices, you were not charging GST at all, so the LUT question starts from your registration date.

What should I do next April?

File a fresh LUT for the new financial year before the first export invoice of April, because the mid-year LUT expires on 31 March.² The LUT renewal guide covers the routine. If several invoices fall into a gap, confirm the treatment with a chartered accountant (CA).