Time of Supply on Imports: Goods and Services Diverge

Time of Supply explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.

Both are called "imports". Both bring IGST. They are governed by entirely different machinery, and the difference is not cosmetic — it determines which month the liability falls in, which document supports the credit, and whether cash or credit can be used.

Imported goods have no time of supply under the CGST Act at all. IGST on import is levied under s.3(7) of the Customs Tariff Act, 1975 and collected as a duty of customs, so the relevant date is fixed by s.15 of the Customs Act, 1962 — the date of presentation of the bill of entry for home consumption. Imported services are a supply under s.7(1)(b) of the CGST Act, taxed under reverse charge, with the time of supply under s.13(3).

Imported goods: the Customs Act governs

Section 5(1) of the IGST Act carries a proviso: integrated tax on goods imported into India shall be levied and collected in accordance with s.3 of the Customs Tariff Act, 1975, on the value determined under that Act, at the point when duties of customs are levied under s.12 of the Customs Act, 1962.

So:

• the taxable event is import, and the point of levy is customs clearance;
• the rate applicable is determined under s.15 of the Customs Act — for goods entered for home consumption, the date of presentation of the bill of entry, or the date of entry inwards of the vessel, whichever is later;
• for warehoused goods, the date of presentation of the ex-bond bill of entry for home consumption;
• the value is the transaction value under s.14 of the Customs Act plus basic customs duty and any other duty, not the invoice value alone.

None of s.12 or s.13 of the CGST Act applies. There is no invoice-based time of supply, no payment trigger, no 30-day or 60-day rule.

The credit consequence for goods

Section 16(2)(a) requires possession of a tax invoice or debit note or such other tax paying document as may be prescribed. Rule 36(1)(d) prescribes the bill of entry, or any similar document prescribed under the Customs Act or Rules for the assessment of integrated tax on imports.

Practical consequences:

• credit is available in the period in which the bill of entry is available and the tax paid, subject to s.16;
• the import appears in GSTR-2B through the ICEGATE feed, but the bill of entry — not GSTR-2B — is the primary document;
• s.16(2)(aa), which conditions credit on the supplier's reporting, has no application to imports, because there is no supplier-filed GSTR-1;
• compensation cess on import, where applicable, is credited to the cess ledger only.

Imported services: reverse charge

An import of services is a supply under s.7(1)(b) of the CGST Act whether or not in the course or furtherance of business, and an inter-State supply under s.7(4) of the IGST Act. The recipient pays under s.5(3) of the IGST Act read with the RCM notification.

The time of supply is under s.13(3) — the earliest of:

• the date of payment as entered in the recipient's books or debited from its bank account;
• the day following sixty days from the supplier's invoice, where the supplier issues one; or
• the date of the recipient's self-invoice, where the recipient must issue it.

With the second proviso overriding all of that for associated enterprises where the supplier is outside India: the time of supply is the earlier of the date of entry in the recipient's books or the date of payment. The 60-day rule →

Documents: a self-invoice under s.31(3)(f), within thirty days under Rule 47A, and a payment voucher under s.31(3)(g).

Payment: in cash. RCM cannot be discharged from the credit ledger.

The comparison

Where the confusion causes errors

Treating an imported service as an import of goods because the invoice came from abroad. Software licences, design services, technical assistance and management fees are services; the bill of entry route does not apply and RCM does.

Waiting for GSTR-2B on an imported service. It will never appear. The liability and the credit are both self-assessed.

High seas and in-bond sales. Outside GST under Schedule III paragraph 8; IGST is paid once, by whoever clears the goods. Merchant trade and out-and-out supplies →

Composite import arrangements. Equipment supplied with installation by the foreign vendor: the goods clear on a bill of entry, and the installation service may be a separate RCM supply. Whether it is one composite supply or two depends on the contract, and the answer changes the tax entirely.

Key takeaways

• Imported goods have no CGST time of supply — the Customs Act fixes the date.
• The relevant date is the bill of entry for home consumption, or the ex-bond bill of entry for warehoused goods.
• The credit document for goods is the bill of entry under Rule 36(1)(d).
• Imported services are taxed under reverse charge, with the s.13(3) time of supply.
• Services need a self-invoice within thirty days and a payment voucher, paid in cash.
• Associated enterprises with a foreign supplier: earlier of books entry or payment.

Read next

• Import of Services Under GST: Reverse Charge and ITC
• GST on Imports: IGST Mechanism and Customs
• The 60-Day Rule: Time of Supply Under Reverse Charge
• Import of Services for Personal Use

Disclaimer: Positions stated as on 5 September 2026, based on ICAI Background Material on GST, Volume I and II (2026 edition).