GST Refund for Amazon Sellers: LUT vs IGST Route, Step by Step

What does zero-rated mean for Amazon exports?

Under Section 16 of the IGST Act , an export of goods or services is a zero-rated supply . Every order you ship out of India through Amazon Global Selling (whether it goes FBA to a US warehouse or direct-to-customer by courier) is a zero-rated supply.

Sellers routinely confuse zero-rated with exempt. They are not the same thing, and the difference is worth lakhs a year.

The practical consequence: because your outward supply carries no tax but your inputs do, GST accumulates in your favour every month. That accumulation is not a rounding error for an Amazon seller. Referral fees alone run 8. 17% of order value, and Amazon charges 18% GST on top of them. On a Rs 50 lakh export year, that is typically Rs 3. 5 lakh of credit sitting in your electronic credit ledger doing nothing.

LUT route vs IGST route compared

Section 16(3) of the IGST Act gives exporters exactly two routes. You pick one per GSTIN, and in practice you should stay on it for the whole financial year rather than switching mid-stream.

The two routes in one line each

• Route A. Export under Bond/LUT. You file Form RFD-11 once a year, ship without charging IGST on your export invoice, and then claim a refund of the accumulated input tax credit by filing RFD-01.
• Route B. Export with payment of IGST. You charge IGST on your export invoice, pay it in GSTR-3B, and the same IGST comes back to you automatically once GSTR-1 Table 6A matches the shipping bill on ICEGATE. No RFD-01 is filed.

Which route should an Amazon seller pick?

Run the numbers rather than following advice. Here is a realistic Amazon Global Selling profile for a full financial year.

The seller profile

• Export turnover (zero-rated, FOB): Rs 50,00,000
• Domestic turnover: Nil. Pure exporter, so Adjusted Total Turnover = Rs 50,00,000
• Input GST for the year: Rs 4,00,000. Approximately Rs 2.6 lakh on Amazon referral, FBA, storage and ad invoices, and Rs 1.4 lakh on domestic goods procurement and freight
• Applicable GST rate on the goods if sold domestically: 18%

Both routes end at the same place: Rs 4,00,000 back in your hands . The difference is entirely about timing and effort. Under Route B you push roughly Rs 75,000 of IGST out in cash every month and wait 2. 6 weeks for it to return, so at any given moment about Rs 1.5 lakh of your cash is with the government instead of buying inventory. Under Route A that number is zero, but you have to actually file RFD-01.

Recommendation

File the LUT and take Route A. But only if you commit to filing RFD-01 quarterly. An Amazon seller's cost base is dominated by 18% GST on platform services, so Route A protects cash flow where it hurts most, during the inventory-buying cycle.

Take Route B instead if any of these are true: your input GST is under roughly 3% of export turnover, you have large domestic sales absorbing your credit anyway, or you have no reliable person to prepare Statement 3 each period. A Route B refund you actually receive beats a Route A refund you never file for.

How to file your LUT (Form RFD-11)

An LUT is a Letter of Undertaking. A declaration to the department that you will export the goods and bring the proceeds back, and that if you fail to, you will pay the tax with interest. It is filed in Form GST RFD-11 , online, free, and usually accepted the same day.

Who can file an LUT

• Any registered person exporting goods or services, including supplies to an SEZ unit or developer.
• Except a person who has been prosecuted for any offence under the GST Acts or any earlier law where the tax evaded exceeds Rs 250 lakh . Such a person must furnish a bond with bank guarantee instead of an LUT.
• No turnover threshold and no export-performance condition. A first-month Amazon seller with one shipment qualifies.

Step-by-step: filing RFD-11 on the GST portal

1. 1 Log in and open the LUT form gst.gov.in → Services → User Services → Furnish Letter of Undertaking (LUT). You must be logged in with the authorised signatory's credentials.
2. 2 Select the correct financial year Pick the year you are exporting in, not the previous one. The form defaults to the current year, and sellers filing in late March routinely file for the wrong year and leave 1 April uncovered.
3. 3 Upload the previous year's LUT, if you have one If an LUT was accepted for the prior year, attach that PDF here. First-time filers skip this. Accepted formats are PDF or JPEG, up to 2 MB.
4. 4 Tick the three undertakings You are undertaking to: complete the export within three months of the invoice date (or such extended period as permitted), observe all GST provisions, and pay IGST with interest at 18% per annum if the export does not happen. All three must be checked.
5. 5 Enter two independent witnesses Name, occupation and full address of two witnesses are mandatory fields. They are not verified, but they cannot be left blank and cannot be the authorised signatory.
6. 6 Sign and submit with DSC or EVC Companies and LLPs must use DSC. Proprietors and partnerships may use EVC (OTP to the registered mobile and email). On submission you get an ARN immediately.
7. 7 Download the acknowledgement and store it Services → User Services → View My Submitted LUTs. Save the PDF. You will need it next year as the prior-year attachment, and buyers and CHAs sometimes ask for the LUT ARN.
8. 8 Put the LUT reference on every export invoice Each export invoice must carry the endorsement: "Supply meant for export under LUT without payment of integrated tax" along with the LUT ARN. Amazon's invoicing tools will not do this for you.

If your LUT has already lapsed mid-year, do not backdate anything. File the fresh RFD-11 immediately so the gap stops widening. For the exports already made during the gap, the clean remedy is to treat them as Route B exports: pay the IGST on those invoices through GSTR-3B, report them in Table 6A as exports with payment of tax, and let the automatic refund return the money. You lose the float on those invoices; you do not lose the tax.

How to claim the refund

The two routes have completely different mechanics. Read only the one that applies to you.

Route A. Refund of accumulated ITC via RFD-01

This is the LUT route. Nothing happens automatically. The amount you can claim is capped by a formula in Rule 89(4) of the CGST Rules :

Rule 89(4) refund formula

Refund Amount = (Turnover of zero-rated supply of goods + zero-rated supply of services) × Net ITC ÷ Adjusted Total Turnover

• Net ITC is the input tax credit availed on inputs and input services during the period. It excludes credit on capital goods.
• Turnover of zero-rated supply of goods is capped at 1.5 times the value of like goods supplied domestically by you or a similarly placed supplier, where such a domestic value exists.
• Adjusted Total Turnover is your total turnover excluding exempt supplies, computed for the same period.

For a pure exporter with no domestic sales, zero-rated turnover equals adjusted total turnover, the ratio is 1, and the refund is simply the whole Net ITC. Using the seller profile above: (50,00,000 × 4,00,000) ÷ 50,00,000 = Rs 4,00,000 .

If the same seller also had Rs 20 lakh of domestic sales, the adjusted total turnover becomes Rs 70 lakh and the refund falls to (50,00,000 × 4,00,000) ÷ 70,00,000 = Rs 2,85,714 . The balance Rs 1,14,286 is not lost. It stays in the credit ledger to offset domestic output tax.

Step-by-step: filing RFD-01

1. 1 File GSTR-1 and GSTR-3B for the period first RFD-01 cannot be filed for a period whose returns are pending. Exports go in Table 6A of GSTR-1 with WPAY = "Without Payment of Tax" , and the same values in Table 3.1(b) of GSTR-3B.
2. 2 Open the refund application gst.gov.in → Services → Refunds → Application for Refund → select Refund of ITC on Export of Goods & Services without Payment of Tax . Select the tax period range.
3. 3 Upload Statement 3. Invoice-level export detail Download the offline utility, fill one row per export invoice with invoice number and date, FOB value, port code, shipping bill number and shipping bill date, plus the eBRC/FIRC reference. Upload the generated JSON. Every row must reconcile to a Table 6A entry.
4. 4 Enter Net ITC in Annexure B and compute the claim Annexure B is the inward-supply statement supporting Net ITC, listing each purchase invoice with GSTIN, invoice number, tax heads and whether it is an input, input service or capital good. Capital goods must be flagged and excluded from Net ITC. The portal then applies the Rule 89(4) formula.
5. 5 Attach declarations and supporting documents A declaration under Rule 89(2)(l) that no drawback of the central tax was claimed, an undertaking under Section 54(3), the LUT copy, and shipping bills and FIRC/eBRCs. The portal caps uploads at 10 files.
6. 6 Select the validated bank account and submit Only bank accounts validated with PFMS appear in the dropdown. Submit with DSC or EVC. The claimed amount is immediately debited from your electronic credit ledger.
7. 7 Track RFD-02, RFD-03, RFD-04 and RFD-06 RFD-02 is the acknowledgement. RFD-03 is a deficiency memo. It means the application is dead and you must file afresh, so respond fast. RFD-04 is the 90% provisional sanction, due within 7 days of RFD-02. RFD-06 is the final order, due within 60 days.

Route B. Automatic refund of IGST paid

Under this route there is no RFD-01 . The shipping bill itself is deemed to be the refund application under Rule 96 of the CGST Rules. That single sentence explains why Table 6A accuracy matters more here than anywhere else in GST: the refund is a machine matching two datasets, and it has no way to ask you a question.

Step-by-step: the automatic route

1. 1 Raise the export invoice with IGST Charge IGST at the rate applicable to the goods. The endorsement on the invoice reads "Supply meant for export on payment of integrated tax" .
2. 2 File the shipping bill with matching data Your GST invoice number, invoice date and taxable value on the shipping bill must be identical to what you will report in GSTR-1. The IEC and GSTIN on the shipping bill must be the same legal entity.
3. 3 Report in GSTR-1 Table 6A Set WPAY = "With Payment of Tax" and enter the port code, shipping bill number and shipping bill date. These three fields are what the system matches against ICEGATE.
4. 4 Pay the IGST in GSTR-3B Table 3.1(b) The IGST declared in Table 3.1(b) must be at least the IGST claimed in Table 6A. If 3.1(b) is short, the whole period's refund is held back, not just the shortfall.
5. 5 GSTN transmits to ICEGATE and the scroll generates Customs matches the data, generates an IGST refund scroll, and credits your bank account directly. Nothing is required from you.
6. 6 Verify on ICEGATE every month icegate.gov.in → Enquiry → IGST Scroll Sanctioned Status. Enter the location code and shipping bill number. If nothing shows, the data never transmitted and the mismatch is on you to fix.

One more mechanism worth knowing if you buy finished goods for export rather than manufacturing them: under Notification 40/2017-Central Tax (Rate) and 41/2017-Integrated Tax (Rate) , a registered merchant exporter can procure goods from a registered supplier at a concessional rate of 0.1% , provided the goods are exported within 90 days of the supplier's invoice, the shipping bill carries the supplier's GSTIN and invoice number, and you are registered with an Export Promotion Council or Commodity Board. This cuts the accumulation problem at source, but it also shrinks your refund claim to almost nothing. Which is the point.

Claiming ITC on Amazon's fees

This is the section Amazon will never write. Amazon charges you GST on almost everything it does for you, and for an exporter that GST is the single largest component of the refund claim. Most sellers never claim it, because Amazon's fee invoices are not in the accounting system. They are buried in Seller Central under a tab nobody opens.

The monthly reconciliation, in order

1. 1 Confirm your GSTIN is on the Seller Central account Settings → Account Info → Tax Information. If the GSTIN is missing or belongs to a different state registration than the one you file under, Amazon's invoices will not carry your GSTIN and the credit will never reach your GSTR-2B. This is unfixable retrospectively beyond Amazon's own amendment window.
2. 2 Download the monthly tax invoices Seller Central → Reports → Tax Document Library → Seller Fee Invoices. Download the fee invoice for the month. Separately pull the advertising tax invoice from the Advertising console billing page. It is a different document and is missed constantly.
3. 3 Pull the settlement report for the same period Reports → Payments → Date Range Reports. The settlement report shows fees net of your payout; the tax invoice shows them gross with GST. The two must tie, and the difference is exactly the GST you are claiming.
4. 4 Match every invoice against GSTR-2B GSTR-2B is generated on the 14th of the following month and is the statutory basis for ITC under Section 16(2)(aa). If an Amazon invoice is in your hand but not in GSTR-2B, you cannot claim it that month. Carry it forward and chase Amazon through Seller Support with the invoice number.
5. 5 Claim in GSTR-3B Table 4(A)(5) Take the credit as all other ITC. Because your outward supplies are zero-rated, it will not be consumed and will accumulate. Which is exactly what you want before an RFD-01.
6. 6 Carry the same numbers into Annexure B When you file RFD-01, each Amazon fee invoice becomes a row in Annexure B, tagged as an input service. Annexure B totals must equal the Net ITC you are claiming, and must not exceed what GSTR-2B supports.

Why your refund is stuck

Almost every stuck refund traces to one of these seven causes. None of them resolve on their own, and under Route B none of them generate a notice.

Monthly GST compliance checklist for Amazon exporters

Every month

• Download the Amazon monthly fee tax invoice from the Tax Document Library, and the advertising tax invoice from the Advertising console. Two separate documents.
• Pull the settlement report for the same period and tie fees on the settlement to fees on the tax invoice.
• On the 14th, download GSTR-2B and match every Amazon invoice line by line. Flag anything present in your records but absent from 2B.
• File GSTR-1 by the 11th with every export in Table 6A, including port code, shipping bill number and shipping bill date.
• File GSTR-3B by the 20th. Exports in Table 3.1(b); Amazon fee ITC in Table 4(A)(5).
• If on Route B, run the ICEGATE IGST Scroll Sanctioned Status enquiry for the previous month's shipping bills. Silence means a mismatch, not a delay.
• Reconcile shipping bills raised against export invoices reported. Every SB should have exactly one matching Table 6A entry.
• Track FIRC/eBRC receipt against each shipping bill; you will need the references for Statement 3.

Every quarter

• If on Route A, file RFD-01 for the quarter with Statement 3 and Annexure B.
• Reconcile the electronic credit ledger balance against your books. A growing balance with no pending RFD-01 means money is idling.
• Review any shipping bill older than 18 months with no refund received, and escalate before the two-year limitation.

Every 1 April

• File the fresh LUT in Form RFD-11 for the new financial year, attaching the previous year's accepted LUT.
• Update the LUT ARN on your export invoice template.
• Re-verify that the bank account on the GST portal is still validated with PFMS.
• Confirm the GSTIN on Seller Central still matches your active registration.

Seasaw for Exporters

Stop leaving GST refunds unclaimed

Seasaw reconciles your Amazon settlement and fee invoices against GSTR-1 and GSTR-2B, tracks which Amazon fee credits have actually landed in 2B, and flags Table 6A mismatches before they quietly block your refund. So the money comes back on schedule instead of expiring at the two-year mark.

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Update history

• 2026-08-13 First published.