Context. Occultation experiments represent unique opportunities to remotely probe the physical properties of atmospheres. The data processing involved in modeling the time and frequency transfers of an electromagnetic signal requires that refractivity be properly accounted for. On theoretical grounds, little work has been done concerning the elaboration of a covariant approach for modeling occultation data. Aims. We present an original method allowing fully analytical expressions to be derived up to the appropriate order for the covariant description of time and frequency transfers during an atmospheric occultation experiment. Methods. We make use of two independent powerful relativistic theoretical tools, namely the optical metric and the ...