The Tamil Nadu Appellate Authority for Advance Ruling (AAAR) has held that GST paid through TR-6 challans cannot be used to claim input tax credit (ITC) under the GST law.
The bench of Madan Mohan and S. Nagarajan while dismissing the appeal filed by a registered importer affirmed that such challans are not recognized as eligible documents for ITC purposes, even when linked with Special Valuation Branch (SVB) orders or letters from customs authorities.
Under the GST framework, importers often pay Integrated GST (IGST) at the time of clearance of goods. In certain cases involving related-party transactions, the value of imports is re-determined based on Special Valuation Branch (SVB) orders issued by customs authorities. The differential IGST arising from these SVB assessments is paid using TR-6 challans, which serve as manual payment instruments for customs duty and related taxes.
The issue raised was whether the Applicant can avail the ITC of the import IGST paid through TR-6 Challan in terms of Section 16(2) of the CGST Act read with rule 36 of CGST Rules?
The AAR held that neither a TR-6 challan as such, nor a TR-6 challan read with the SVB order and letters issued by the tax authorities, as claimed by the applicant in the instant case can be considered as an eligible document for the purpose of availment of ITC. As TR-6 challan cannot be considered as an eligible document for the purpose of availment of ITC, the question of answering this query does not arise. Availment of ITC on import IGST on the basis of a re-assessed bill of entry, is very much governed by the time limit as prescribed under Section 16(4) of the CGST Act, 2017. The time limit for availing ITC on the differential IGST paid would begin from the date of re-assessment of bill of entry.
The appellant, Becton Dickinson, a leading medical technology company, had argued that since the TR-6 challan represents tax paid to the government under lawful authority, the ITC benefit should be available. It was further contended that the time limit prescribed under Section 16(4) of the CGST Act, which restricts the period for availing ITC, should not apply to such payments made through TR-6 challans.
The appellant had argued that the time limit under Section 16(4) of the CGST Act for availing ITC should not apply to import GST paid via TR-6 challans, claiming that such payments are made directly to the government and therefore should qualify for credit.
However, the appellate authority rejected this view, observing that TR-6 challans are not listed among the prescribed documents under Rule 36(1) of the CGST Rules that entitle a taxpayer to claim ITC. It further held that once the basic eligibility document is not recognized, the question of applying or relaxing the time limit under Section 16(4) does not arise.
By reaffirming the AAR’s earlier decision, the AAAR clarified that only tax invoices, debit notes, or similar prescribed instruments issued by registered suppliers can be used to claim ITC.
Ruling Details
Applicant’s Name: Becton Dickinson India Private Limited
Ruling Date: 08/10/2025
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