What happens if I forgot to file an LUT and already issued export invoices?
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Short answer
File the LUT for the year straight away, then deal with the invoices already issued. CBIC Circular No. 125/44/2019-GST, para 44, says the delay in furnishing an LUT may be condoned and export under LUT allowed on an ex post facto basis where the exports are established, depending on the facts.1 Because that is discretionary, the alternative is to treat those invoices as exports on payment of IGST and claim the IGST back as a refund.23
It happens often in April. An architecture studio or a SaaS founder raises invoices for March work in the first week of the new financial year, then realises last year's LUT has expired. Freelancers who register mid-year make the same slip with their first export invoice.
Why does a missing LUT matter?
A missing LUT matters because the LUT is what lets a registered person export without paying integrated tax. Section 16(3) of the IGST Act allows zero-rated supplies "under bond or Letter of Undertaking", and rule 96A(1) of the CGST Rules requires the LUT to be furnished prior to export.23 An export invoice without IGST and without an LUT is therefore not on the footing the law expects, even though the service is still an export.
What should I do first?
File the LUT for the current financial year now, in FORM GST RFD-11, so that every invoice from today onwards is covered.3 The steps are in how to file an LUT on the GST portal. Then list the invoices issued in the gap, with dates, amounts and whether the client has paid.
What are the two options for the invoices already issued?
You can rely on condonation, or pay IGST and claim it back. The table summarises para 44 of the circular, section 16 and section 54.124
| Option | How it works | Trade-off |
|---|---|---|
| Rely on condonation | 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 the LUT delay may be condoned ex post facto on the facts of each case | Discretionary; depends on your jurisdictional officer |
| Pay IGST and claim a refund | Section 16(4) of the IGST Act lets notified persons or supplies be exported on payment of IGST, with the tax refunded under section 54 of the CGST Act | Cash is blocked until the refund arrives; refund within two years of the relevant date |
The IGST-paid route guide covers the refund application, and the GST refund guide covers timelines.
Which option fits which situation?
A handful of invoices from the first days of April, all paid in foreign currency, is the kind of case para 44 was written for.1 Many months of export invoices without an LUT, or unpaid invoices, carry more risk, and some exporters prefer the certainty of paying IGST. The choice depends on your facts and your officer, so confirm it with a chartered accountant (CA) before you file the next return.
How do I stop it happening again?
Put the LUT filing in your calendar for the first working day of April, before any invoice for March work, and update the ARN on your invoice template. The LUT renewal guide has a short annual routine.
How did we verify this?
We checked this page against the sources below on 28 October 2026. Read our methodology or report an error.
Frequently asked questions
Will the GST department accept an LUT filed after the invoices?+
It may. Para 44 of Circular 125/44/2019-GST says the delay may be condoned and export under LUT allowed ex post facto, taking into account the facts and circumstances of each case. It is not automatic.1
Do I need to reissue the invoices?+
If you rely on condonation, the invoices stay as issued. If you choose to pay IGST instead, discuss with a CA how to correct the invoices and returns, because the IGST-paid route uses a different invoice endorsement.
Is there a time limit for claiming the IGST refund?+
Yes. Section 54(1) of the CGST Act requires the refund application within two years from the relevant date.4
I was not registered when I sent those invoices. Do I have a problem?+
No LUT was needed. Rule 96A applies to registered persons, and an unregistered person does not charge GST.3
This page is general information for Indian service exporters, not tax or legal advice. Rules change and outcomes depend on your facts, so confirm with a chartered accountant before acting.
Keep reading
How do you file an LUT for export of services on the GST portal?
Step-by-step guide to filing a Letter of Undertaking in FORM GST RFD-11 for export of services: eligibility, validity, late filing and the ARN on invoices.
GSTHow long is an LUT valid, and when do you renew it?
An LUT for export of services is valid only for the financial year it is filed in. When to renew, what Expired means, gaps in April, withdrawal and new GSTINs.
GSTHow do you export services by paying IGST instead of filing an LUT?
How the IGST-paid route works for service exporters without an LUT: the October 2023 change, invoice wording, GSTR-3B reporting and the RFD-01 refund with Statement 2.
GSTHow do you claim a GST refund on export of services?
The two GST refunds open to service exporters, the two-year deadline, documents, the RFD-01 steps and processing times, including rule changes from 1 November 2026.