GST Refunds for Exporters in 2026: LUT, Inverted Duty & the 60-Day Clock

For exporters, GST is meant to be a pass-through — your supplies are zero-rated, so the tax on your inputs should come back to you. In practice, refunds get delayed, short-sanctioned, or never claimed because the paperwork does not line up. This guide covers the two export routes, inverted-duty refunds, and exactly what the RFD-01 file needs to clear without queries.

What “zero-rated” really means

Exports (and supplies to SEZ) are zero-rated — not exempt. The difference is the whole point:

  • Exempt supplies carry no output tax and block the related input credit.
  • Zero-rated supplies carry no output tax but preserve input credit — which you can claim back as a refund.

So an exporter should rarely be sitting on accumulated credit. If you are, money is stuck that belongs in your working capital.

LUT vs paying IGST: which route

There are two ways to export under GST:

  • Under LUT (Letter of Undertaking) — export without paying IGST, then claim refund of the unutilised input tax credit. Best for most exporters; no cash blocked in IGST.
  • On payment of IGST — pay IGST on the export, then claim it back (often auto-processed via the shipping bill). Simpler operationally but blocks cash until refunded.

A valid LUT, filed at the start of each financial year, is the foundation. Exporting without it forces you down the pay-IGST route and ties up cash.

The refund clock the law gives you

RFD-01filed90%provisional, 7 daysSANCTIONby day 60+6% interest if late

For a complete zero-rated refund claim: 90% sanctioned provisionally within 7 days, the balance within 60 days; interest at 6% runs if the department is late. Source: CGST Act s.54 (refunds) & s.56 (interest).
HGFounder’s note

Exporters quietly carry the government’s money for months because nobody chases the refund. Here is the part most miss: the law is on your side — there is a 60-day clock, and interest if they miss it — but only if your claim is complete on day one. Nine times out of ten the delay is a deficiency memo for a document that should have been attached. File it clean, track the RFD series, and a refund stops being a favour you wait for and becomes a deadline they owe you.

— Hardik Garg, Founder & Senior Advisor

Sitting on accumulated credit?

We file and chase GST refunds end-to-end — LUT, exports and inverted duty — so the money the department owes you stops gathering dust.

Inverted duty structure refunds

An inverted duty structure is where your inputs are taxed at a higher rate than your outputs — so credit accumulates even on domestic sales. Common in textiles, footwear, EV components and several manufacturing lines.

  • You can claim refund of the accumulated ITC attributable to the inversion, under a prescribed formula.
  • The formula and the treatment of input services have changed over time, so the computation must follow the current rule.
  • Getting the formula and the turnover figures right is where most inverted-duty refunds are won or lost.

The RFD-01 process, step by step

1. Confirm eligibility and route

LUT in place, supplies correctly classified as exports/SEZ or inverted, period selected.

2. Compute the eligible refund

Apply the correct formula; reconcile with GSTR-1, 3B and 2B for the period.

3. File Form RFD-01 with annexures

Upload the statement of invoices, shipping bills/FIRC, and the computation.

4. Respond to deficiency memos

If the officer issues RFD-03 (deficiency), fix and re-file promptly — the clock restarts, so speed matters.

5. Track sanction and interest

Refunds delayed beyond the statutory period carry interest; track it rather than leaving it on the table.

Documents that get refunds sanctioned

  • Valid LUT for the year.
  • Shipping bills and EGM matched to invoices (for goods).
  • FIRC / BRC evidencing receipt of foreign exchange (for services).
  • Clean GSTR-1 vs 3B vs 2B reconciliation for the period.
  • A refund computation the officer can verify line by line.

Why refunds get rejected

  • Invoice-to-shipping-bill mismatches.
  • Wrong refund formula or period.
  • Missing FIRC/BRC for export of services.
  • Letting a deficiency memo lapse instead of re-filing.
  • ITC claimed that is not reflected in 2B.

RoDTEP, drawback and GST refund — all in one place

We handle the full export incentive stack and keep your export costing current under the latest rates.

The bottom line

Export refunds are not discretionary — they run on a statutory clock with interest attached. The exporters who get paid fast aren’t lucky; they file complete claims, pick the right route (LUT versus paying IGST), and reconcile every shipping bill so nothing snags. Whether it is unutilised ITC, an inverted-duty structure or an IGST-paid export, the money is yours and there is a deadline on it. Claim it cleanly, track it, and stop financing the department for free.

Frequently asked questions

Should I export under LUT or pay IGST?
For most exporters, LUT is better because it avoids blocking cash in IGST. You then claim refund of unutilised ITC. Paying IGST is simpler but ties up working capital until refunded.
What is an inverted duty structure refund?
It is a refund of input tax credit that accumulates because your inputs are taxed higher than your outputs. It is claimed under a prescribed formula, even on domestic sales.
How long does a GST refund take?
The law sets an outer timeline, and refunds delayed beyond it attract interest. In practice, a clean file with matched documents clears far faster than one that triggers a deficiency memo.
Do I need a fresh LUT every year?
Yes. The LUT is filed for each financial year. Exporting without a valid LUT pushes you to the pay-IGST route.
Can exporters of services claim GST refunds?
Yes, where the supply qualifies as export of services and foreign exchange is received with FIRC/BRC evidence. The documentation is what gets it sanctioned.

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