Answer

GST

Filing LUT in the middle of the year

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  1. Facts

    Yes. You can file RFD-11 at any time in the financial year, and it covers exports from the date of filing. Exports made before it may need condonation under Circular 37/11/2018-GST.

  2. Provisions and law

    • Circular 8/2017-GSTLUT available to all exporters except those prosecuted for evasion above ₹250 lakh; valid for the financial year; deemed accepted if not accepted within 3 working days
    • Circular 37/11/2018-GSTDelay in furnishing LUT may be condoned and the LUT accepted after the event
  3. Analysis

    If your first export invoice is on 10 September, file the LUT on or before that date. Practitioners differ on whether an LUT covers earlier invoices in the same year, so check the live portal and keep the condonation route ready if needed.

  4. Conclusion

    1. File the LUT before raising the first export invoice.
    2. If invoices were raised earlier, list them.
    3. Request condonation for those invoices.
    4. Use the LUT for all later exports.

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