MISSED LUT (RFD-11) FILING
A GST-registered Indian company exported consulting services worth approx. ₹80 lakh over the last two FYs to its separately incorporated foreign associate company. Payment was received through banking channels, but LUT was inadvertently not filed for either FY.
Can the company now regularise the omission through retrospective/ex-post-facto LUT or condonation, and continue to treat the supplies as zero-rated exports without payment of IGST? What is the practical procedure and GST/interest/penalty exposure, if any?