IGST on imports: how a bill of entry reaches your return

Finance treats import IGST as recoverable and operations treats it as paid, and the gap between those two views is where the working capital sits. The tax is charged under one statute at a port, and the credit is taken under a different statute in a monthly return, using a document that no supplier issues. Nothing in that chain is difficult. It fails for the ordinary reason that the two ends are reconciled by nobody in particular.

Under which law is IGST charged at the border?

Not under the IGST Act directly. Section 3(7) of the Customs Tariff Act 1975 provides that any article imported into India shall in addition be liable to integrated tax at such rate, not exceeding forty percent, as is leviable under Section 5 of the Integrated Goods and Services Tax Act 2017 on a like article on its supply in India, on the value of the imported article as determined under Section 3(8) of that Act. The rate is borrowed from the GST law; the levy and the collection sit inside the customs machinery.

That structure explains two things a finance owner will meet. The tax is assessed and paid through the customs system alongside the duties, on the bill of entry rather than on a tax invoice, and the value it is charged on is not the invoice value but the grossed-up figure defined by Section 3(8). How import duty stacks takes that base apart layer by layer.

What is the document that carries the credit?

The bill of entry, named as such. Rule 36(1) of the Central Goods and Services Tax Rules 2017 lists the documents on which input tax credit may be availed, and clause (d) of that sub-rule is a bill of entry or any similar document prescribed under the Customs Act 1962 or rules made thereunder for the assessment of integrated tax on imports. That clause is what Section 16(2)(a) of the CGST Act 2017 is pointing at when it allows credit on such other tax paying documents as may be prescribed.

The practical implication is that your credit document is generated by a customs filing your broker made, not by an invoice a supplier sent. Nobody in your accounts payable process will receive it in the ordinary course. If the bill of entry number and date are not captured against the consignment at the time of clearance, the credit has no key, and finding it later means reconciling backwards from a portal statement.

How does the bill of entry reach your return?

Electronically, from the customs system to the GST common portal. Rule 60(6) of the CGST Rules provides that the details of the integrated tax paid on the import of goods, or on goods brought into the domestic tariff area from a special economic zone unit or developer, on a bill of entry shall be made available in Part D of FORM GSTR-2A. Rule 60(7)(iii) provides that the auto-generated statement in FORM GSTR-2B, made available for every month, shall consist of, among other things, the details of the integrated tax paid on the import of goods on a bill of entry in the month.

So the reconciliation has a defined shape: your own record of consignments cleared, against Part D of GSTR-2A and the import table of GSTR-2B, against what you claim in the return. Three registers, one key, which is the bill of entry number with its date and port. A consignment that is missing from any one of them is either a capture failure at your end or a transmission issue at the portal end, and telling those apart is the entire exercise.

Which Section 16 conditions bite on an import, and which do not?

Section 16(1) of the CGST Act 2017 entitles a registered person to take credit of input tax charged on supplies used or intended to be used in the course or furtherance of business, subject to the prescribed conditions and the manner specified in Section 49, with the amount credited to the electronic credit ledger. Section 16(2) then imposes four conditions that plainly do apply to an import: possession of the prescribed tax paying document under clause (a), receipt of the goods under clause (b), the tax having been actually paid to the Government under clause (c), and the return under Section 39 having been furnished under clause (d).

Two conditions that dominate domestic credit do not attach the same way. Section 16(2)(aa) is framed by reference to the invoice or debit note in clause (a) being furnished by the supplier in the statement of outward supplies under Section 37, and Rule 36(4) of the CGST Rules is framed by reference to invoices or debit notes whose details are required to be furnished under Section 37(1) and communicated in GSTR-2B under Rule 60(7). A bill of entry is not a supplier's outward supply document, so import credit does not turn on a counterparty's filing behaviour. It turns on your own record agreeing with the customs record.

What actually breaks the reconciliation?

Identity, timing and revision, roughly in that order. Identity is the GSTIN declared on the bill of entry: a consignment cleared under the wrong registration of a multi-state group produces a credit that appears in the wrong entity's statement, and it is a customs record correction rather than a GST one. Timing is the month boundary: goods assessed at the end of one month can surface in the following month's statement, so a month by month match without a rolling view will show a gap that is not a gap.

Revision is the one that costs most. CBIC's National Time Release Study 2025 reports that 51 percent of seaport bills of entry are amended after filing, so on roughly half of consignments the document underlying the credit is not the document first generated. Provisional assessment under Section 18 of the Customs Act 1962 has the same effect on a longer horizon, with the final figure moving after the credit was taken. Half of India's bills of entry get amended covers why that rate is what it is.

What is the outer limit on taking the credit?

Section 16(4) of the CGST Act 2017 provides that a registered person shall not be entitled to take input tax credit in respect of any invoice or debit note for supply of goods or services after the thirtieth day of November following the end of the financial year to which the invoice or debit note pertains, or the furnishing of the relevant annual return, whichever is earlier. That is a hard outer boundary on domestic credit and it is the date most finance calendars are built around.

Here we should publish the silence rather than paper over it. Section 16(4) is framed by reference to an invoice or a debit note, and it does not name a bill of entry, while Rule 36(1)(d) treats the bill of entry as a separate class of document. We could not establish from the instruments themselves how that interaction is settled. The prudent working assumption is to treat the same cut-off as applying and to close import credit for a financial year on the same calendar as everything else, and to take a position from your own advisor before relying on anything longer.

What does a finance owner need to hold per consignment?

A short record, held from the day of clearance rather than assembled at the year end: the bill of entry number, its date and the port code, the assessed integrated tax kept separate from the non-creditable duties, the month the entry appeared in GSTR-2B, and the month it was claimed in the return under Section 39. That is enough to answer every question a reconciliation asks, and its absence is what turns a routine match into an archaeology project.

Purser Inbound holds that record against the consignment from the purchase order onward, keeps the creditable component split from the permanent cost, and flags a cleared consignment that has not appeared in a statement. Purser never submits to a government portal, and it never sends an outbound message without a recorded human approval event. Your customs broker still files the bill of entry and your accountant still files the return. What changes is that the same consignment carries one key through both.

Where to go from here

The credit is one half of a figure whose other half never comes back, and both halves are decided before the goods land.

• The base the tax is charged on. How import duty stacks shows why the integrated tax sits on a grossed-up value.
• Ranking suppliers on the net figure. Landed cost at your gate separates permanent cost from the recoverable amount and its lag.
• Why the credit document keeps moving. Half of India's bills of entry get amended after filing, which changes the figure the credit rests on.
• The document that generates it. The bill of entry, field by field covers what has to be right before the assessment is made.

Frequently asked questions

Can input tax credit be claimed on IGST paid at import?

Yes, for a registered person meeting the conditions in Section 16 of the CGST Act 2017. Rule 36(1)(d) of the CGST Rules 2017 provides that input tax credit may be availed on the basis of a bill of entry or any similar document prescribed under the Customs Act 1962 or rules made thereunder for the assessment of integrated tax on imports, so the bill of entry is itself the credit document and no supplier tax invoice is required.

Where does an import bill of entry appear in the GST portal?

Rule 60(6) of the CGST Rules 2017 provides that the details of the integrated tax paid on the import of goods on a bill of entry are made available in Part D of FORM GSTR-2A. Rule 60(7)(iii) provides that the auto-generated FORM GSTR-2B for every month includes the details of the integrated tax paid on the import of goods on a bill of entry in that month.

Does import IGST credit depend on a supplier filing a return?

No. Section 16(2)(aa) of the CGST Act 2017 is framed by reference to the invoice or debit note in clause (a) being furnished by the supplier in the statement of outward supplies under Section 37, and Rule 36(4) of the CGST Rules is framed by reference to invoices and debit notes under Section 37(1). A bill of entry is a separate class of document under Rule 36(1)(d), so import credit turns on your own record agreeing with the customs record rather than on a counterparty's filing.

What is the value that import IGST is charged on?

Section 3(8) of the Customs Tariff Act 1975 defines it as the aggregate of the value determined under Section 14(1) of the Customs Act 1962, or the tariff value fixed under Section 14(2), and any duty of customs chargeable under Section 12 of that Act, plus any sum chargeable under any law as an addition to, and in the same manner as, a duty of customs, excluding only the integrated tax itself and the compensation cess. The invoice value alone is not the base.

Is there a deadline for claiming import IGST credit?

Section 16(4) of the CGST Act 2017 bars input tax credit in respect of any invoice or debit note after the thirtieth day of November following the end of the financial year to which it pertains, or the furnishing of the relevant annual return, whichever is earlier. That sub-section is framed by reference to an invoice or debit note and does not name a bill of entry, and we could not establish from the instruments how the interaction is settled, so treat the same cut-off as the prudent working assumption and take your own advice.