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Export of Services under GST

AKSHAT AGARWAL
Seeking experts guidance in the forum
In one of our case, client have received substantial amount in bank account towards ecommerce website and development services provided to clients located outside India during FY 2024-25. Client is registered taxpayer in GST and have filed nil return till Feb-25. Payment has directly been received in INR in his bank account. Billing is done in USD to clients. What happen is that client have not filed any LUT for FY 2024-25 for availment of benefit of export of services without payment of tax as he is not aware for any of such compliance.
My question is that what treatment should be done in respect of payment received during the year FY 2024-25 (till March-25) and should we pay GST on such export considering the same as export made with payment of tax @ 18% on total payment received during the year and its treatment in March-25 GSTR-1 & GSTR-3B ?
Export of Services Without LUT Filing: Procedural Lapse Only, No IGST Payment Required Under GST Rules The discussion concerns GST treatment for export of services where a client provided e-commerce website development services to foreign clients but did not file Letter of Undertaking (LUT) for FY 2024-25. Experts advise that non-filing of LUT is only a procedural lapse, referencing GST refund master Circular 125 (2019), and recommend filing LUT manually with jurisdictional authorities. They clarify that no IGST payment is required. Regarding payments received in INR rather than foreign currency, experts note this qualifies as export of services if permitted by RBI under Section 2(6) of IGST Act, suggesting verification with the bank for FIRC (Foreign Inward Remittance Certificate) and checking RBI Circular RBI/2022-2023/90 for compliance. (AI Summary)
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