Retain the filed undertaking for the relevant financial year
An Indian exporter using the Letter of Undertaking route should connect each relevant export to the filed LUT and its financial year. Retrieve the acknowledgment and application reference, rather than treating a saved draft as evidence of filing. The GST Portal's RFD-11 process requires selection of the financial year and generates an acknowledgment after signing and filing.
Have the tax adviser confirm that the supplier, supply and chosen route qualify for the intended GST treatment. A customer outside India or an invoice denominated in foreign currency does not by itself establish every condition for an export. Keep that eligibility assessment with the contract and the specific registration making the supply.
References: GST Portal: Filing a Letter of Undertaking, Form GST RFD-11
Keep goods and service evidence in different columns
For goods, connect the commercial invoice to the shipment and customs evidence identifying what left India. Record quantities, shipment dates and amendments. If one invoice is fulfilled through several shipments, retain the allocation; a shipping reference on the invoice header can otherwise conceal an unshipped balance.
For services, preserve the agreement, deliverables, recipient details and payment evidence needed for the export review. Ask the adviser to identify the relevant place-of-supply and realization questions. A project completion email establishes different facts from a bank remittance, and both may be needed to explain the transaction.
Keep cancellations, replacements and credit notes attached to the original export. An invoice replaced for a clerical correction should not create two export amounts in the register or leave the original amount open indefinitely.
Track realization without rewriting the original invoice
Maintain the invoiced currency and amount, each receipt, bank reference, fees and any remaining balance. Ask the bank or payment provider for the relevant remittance evidence where the payer name or purpose is unclear. Separate exchange differences from commercial short payments so the reviewer can see what the customer actually settled.
As an illustrative record, a foreign-currency invoice may be paid in two installments, with the bank deducting a fee from the second transfer. The register should show both gross remittances and the fee separately. It should not reduce the invoice value to the net bank deposit simply to make the reconciliation disappear.
CBIC's export clarification distinguishes the rule 96A timeframes for goods leaving India and for service payments, including permitted extensions and qualifying receipt in Indian rupees. Have the reviewer record the applicable deadline and any documented extension for each affected item. A general accounts-receivable due date is not a substitute for that statutory assessment.
References: CBIC Circular 197/09/2023: Export and refund clarifications
Resolve late or incomplete exports with an explicit tax decision
Create exceptions for missing shipment proof, incomplete receipts, unmatched payments and transactions outside the expected period. Give the adviser the dates and documents needed to assess tax, interest, extension or refund consequences. The CBIC clarification addresses later completion and realization; it does not justify assuming that every late item produces the same outcome.
Reconcile the reviewed export register to the relevant GST return and any refund working papers. Retain filing references and subsequent corrections against the same invoice. A later receipt should update the existing evidence trail so finance can identify which unresolved tax question it closes and which still requires a decision.
References: CBIC Circular 197/09/2023: Export and refund clarifications
Sources
Requirements and product details can change. Check the linked guidance for the facts that apply to your situation.
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