The import leg uses the location of the importer
Section 11(a) of the Integrated Goods and Services Tax Act, 2017 sets the place of supply for goods imported into India at the location of the importer. A port in another State, the broker's office or the ultimate warehouse does not, by itself, change that location. Section 7(2) treats the supply of imported goods as inter-State until the goods cross the customs frontiers. The ordinary domestic movement rule in section 10 is not the rule for the import leg.
Read the applicable text: India Code: IGST Act sections 5(1), 7(2), 10 and 11 India Code: Customs Tariff Act section 3(7), (8) and (8A) CGST Rules: Rule 36(1)(d) import document CBIC: CGST Act, section 16 receipt and document conditions GST Portal: Bill of Entry search and GSTR-3B mapping GSTN advisory: Bill of Entry and GSTIN amendments in IMS.
Establish the importer before entering a GSTIN
Match the commercial order, customs declaration, legal importer and relevant registration. Record the port code and final delivery location separately. A central buying function, a direct-to-customer delivery or a shared broker can put several addresses on the documents. Do not choose the registration from the port or delivery address alone. Where the declaration and the facts conflict, investigate the identity and the proper customs amendment route before taking credit in a different registration.
Reperform the customs tax base
The proviso to IGST Act section 5(1) ordinarily routes import IGST through customs under section 3 of the Customs Tariff Act, 1975; check whether a notified exception applies. For a normal home-consumption example under section 3(7) and (8), start with customs assessable value and add applicable includible customs duties and sums chargeable as additions to customs duty. Exclude import IGST itself and the cess referred to in section 3(9) from this base. Use the actual tariff and exemption evidence for the consignment. A sale of warehoused goods before clearance can require a separate section 3(8A) analysis.
Trace payment, eligibility and the return separately
A Bill of Entry is a prescribed credit document under rule 36(1)(d) of the CGST Rules. Check actual import IGST, the recipient registration, actual or deemed receipt under section 16, business use and other applicable credit restrictions. Basic customs duty is not import IGST credit. Use the GST portal's Search BoE procedure to investigate missing entries and reconcile the import of goods figure to GSTR-3B Table 4(A)(1). GSTN's import IMS advisory explains that a GSTIN amendment can create a reversal at the old GSTIN and a record at the amended GSTIN. Check prior credit actually taken and reversals already made so neither registration claims a duplicate amount.
Follow any domestic leg on its own facts
A subsequent domestic supply after clearance requires its own supplier, recipient and place-of-supply analysis. A Bill of Entry supporting customs payment cannot substitute for the local supply's records. Where a different establishment receives goods, document whether the movement is part of the import logistics or a separate transaction; do not infer tax treatment from a delivery note alone. Keep import of services and special transactions such as sales of warehoused goods outside this ordinary import working.
Six worked illustrations
All facts and amounts are fictional. Calculations illustrate the stated assumptions, not a predetermined legal outcome.
Illustrative example 1: Different port and importer State
Assume the importer for this purchase is located in Karnataka and the goods clear in Maharashtra. Customs assessable value is ₹10,00,000, includible customs additions ₹1,00,000 and the assumed IGST rate 18%. The base is ₹11,00,000 and import IGST ₹1,98,000. The port does not change the importer location.
Illustrative example 2: Missing duties in the worksheet
An analyst applies the assumed 18% to ₹8,00,000 but omits ₹80,000 of includible customs duty. Correct import IGST is ₹1,58,400 instead of ₹1,44,000. The shortfall in the worksheet is ₹14,400.
Illustrative example 3: Separate non-creditable duty from tax
On an ordinary assessed base of ₹5,50,000, including ₹50,000 basic customs duty, an assumed 18% import IGST is ₹99,000. These two cash components total ₹1,49,000. Subject to eligibility, the credit candidate is ₹99,000.
Illustrative example 4: Match the assessed amount to receipt records
A BoE shows ₹72,000 import IGST on a single lot with 200 identical units. If 150 units have physically arrived and 50 are in transit, the arrival control shows 75% received and 25% pending. These percentages flag the receipt check; they do not prescribe a proportional credit claim or override the last-lot condition where applicable.
Illustrative example 5: Amend the GSTIN without reversing twice
An original GSTIN claimed ₹90,000 on the BoE, then already reversed ₹35,000. After a verified GSTIN amendment, the residual reversal at the old registration is ₹55,000. Reconcile that amount to the available IMS option to declare the amount still to be reversed, rather than reversing ₹90,000 again. The amended registration separately tests eligibility for the assessed ₹90,000; it does not limit its test to ₹55,000.
Illustrative example 6: Keep the later invoice separate
A company has ₹36,000 eligible import IGST and later sells the goods in a separate domestic inter-State transaction for ₹3,00,000 plus ₹54,000 IGST at an assumed 18%. With no other credits or liabilities and assuming full utilisation is permitted, the remaining tax after that credit is ₹18,000. The ₹54,000 domestic liability is not the import levy.
Ten-step verification table
| Step | Action | Evidence |
|---|---|---|
| 1 | Identify the goods import and any later leg | Purchase, clearance and domestic supply documents |
| 2 | Confirm the legal importer | Bill of Entry, purchase contract and customs declaration |
| 3 | Validate the relevant registration | GSTIN and importer master with rationale |
| 4 | Record the three locations separately | Importer, port and final delivery details |
| 5 | Reperform customs valuation and IGST | Assessable value, duty build-up, tariff and exemption record |
| 6 | Tie assessment to customs payment | Assessed BoE and payment or clearance evidence |
| 7 | Check receipt and statutory eligibility | Goods receipts, business use and credit review |
| 8 | Match the portal record | Search BoE, IMS and GSTR-2B reconciliation |
| 9 | Resolve any amendment or prior reversal | Old and amended BoE, GSTIN history and credit ledger |
| 10 | Reconcile the filed return and domestic leg | GSTR-3B 4(A)(1) tie and separate sales invoice register |
Sixteen practitioner FAQs
1. Is the customs port the place of supply?
Section 11(a) uses importer location for the goods import. The port identifies where the entry was processed.
2. Does a broker become the importer because it filed the entry?
Filing assistance alone does not determine importer identity. Check the declaration and legal documents.
3. Does delivery to another State decide the import GSTIN?
No. Establish the importer and the appropriate registration from the facts.
4. Is this a section 10 domestic movement transaction?
Section 11(a) governs the imported goods. Analyse a later domestic supply separately.
5. Can imported goods be split into CGST and SGST at the port?
The ordinary goods import is subject to the import IGST framework, with applicable exceptions checked separately.
6. Is the foreign invoice amount the only IGST base?
No. Reconcile customs assessable value and includible customs amounts under the Customs Tariff Act.
7. Does the article set a universal 18% rate?
No. The example rates are assumptions; verify tariff, notification and consignment facts.
8. Is basic customs duty creditable as GST?
No. Distinguish customs duty from eligible import IGST.
9. Is a commercial invoice enough to claim import IGST?
Use the prescribed customs assessment document and satisfy the applicable credit conditions.
10. Does a GSTR-2B entry guarantee credit eligibility?
No. Reconcile it and independently test the credit conditions.
11. Where can a missing record be investigated?
Use the GST portal Search BoE function and, where appropriate, query ICEGATE through the portal.
12. What if both GSTINs show the amended entry?
Reconcile old and amended records and actual claims. An old claim may require reversal.
13. Can an earlier reversal be counted again after amendment?
No. Match amounts already reversed against the remaining reversal.
14. Where is eligible goods import ITC reported in GSTR-3B?
The import of goods credit line is Table 4(A)(1).
15. Does an import of services use the same Bill of Entry workflow?
No. Services are outside this goods-import process.
16. What is the main year-end reconciliation?
Match each BoE assessment, payment, credit eligibility and return entry, preserving amendments as linked versions.
Official sources
India Code: IGST Act sections 5(1), 7(2), 10 and 11 India Code: Customs Tariff Act section 3(7), (8) and (8A) CGST Rules: Rule 36(1)(d) import document CBIC: CGST Act, section 16 receipt and document conditions GST Portal: Bill of Entry search and GSTR-3B mapping GSTN advisory: Bill of Entry and GSTIN amendments in IMS
India Code: consolidated IGST Act · CBIC: CGST Rules, rule 36(1)(d)