Answer

1. F

   Facts

   Circular 37/11/2018-GST says that if exports were made before filing the LUT, the delay can be condoned and the LUT accepted after the event. Otherwise the officer may treat the exports as made without paying IGST that was due.

2. P

   Provisions and law

   • Circular 37/11/2018-GSTDelay in furnishing LUT may be condoned and the LUT accepted after the event
   • Sec 16(3), IGST Act 2017Zero-rated supply can be made under bond or LUT without paying IGST, with refund of unused ITC
   • Rule 96A, CGST Rules 2017Export under LUT or bond: goods to be exported within 3 months of invoice and payment for services received within 1 year, else tax with interest
3. A

   Analysis

   File the LUT for the year at once and keep a written request explaining the gap. Refund officers often accept ex post facto LUT under the circular, particularly where the exports are genuine and documented. The other route is to pay IGST with interest on those invoices and claim refund of that IGST. Which route is better depends on the amount and your officer's view.

4. C

   Conclusion

   1. 1File the LUT for the current year today.
   2. 2Write to the jurisdictional officer asking for condonation under Circular 37/11/2018-GST.
   3. 3Keep invoices, bank realisation and shipping or service proof ready.
   4. 4If the officer refuses, pay IGST with interest and claim refund.

Do not back-date invoices to fit the LUT date; that creates a bigger problem.

General guidance from TaxSavvy’s library of money processes. Laws change; your Savvy confirms the answer on your exact case before anything is filed.