GST AAR: TR-6 Challan Not Eligible Document for Availing ITC

M/s. Becton Dickinson India Private Limited is the legal applicant in this case. The applicant is a private company registered with the address 34, Assisi Nagar, West Thottam, Madhavaram, Tiruvallur – 600 051. The company is involved in the manufacturing and trading of medical equipment/devices. The company paid extra IGST on imported goods due to a true-up adjustment (to match the profit margin required under Income Tax rules). This extra IGST was paid using TR-6 challans and updated reassessed bills of entry.

The applicant now wants to know whether a business can claim credit for the tax it has actually paid or is considered to have paid on purchases. Hence, it seeks the Authority for Advance Ruling, Tamil Nadu.

Questions Asked by Applicant:

The applicant, M/s. Becton Dickinson India Private Limited has asked the following questions before the Tamil Nadu State Appellate Authority, Chennai, under Sub-Section (1) of Section 100 of the CGST Act 2017/TNGST Act 2017, seeking the advance ruling No. 20/ARA/2025, dated 09.05.2025:

“Question 1. 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 the CGST Rules?

Question 2. Whether the eligibility to avail ITC of the import IGST paid vide TR-6 Challan is subject to the time limit prescribed under Section 16(4) of the CGST Act?

Question 3. Whether the eligibility to avail ITC of the import IGST paid vide the reassessed bill of entry is subject to the time limit prescribed under Section 16(4) of the CGST Act?

Question 4. If the answer to Q.3 for the bill of entry is in the affirmative, would the time limit for availing ITC begin from the initial date of the bill of entry originally filed or from the date of reassessment of the bill of entry?”

What Did the Ruling Say?

In accordance with the Authority for Advance Ruling, Tamil Nadu, the following answer has been given to the above questions:

• Answer 1: A TR-6 challan merely, or even when combined with the SVB order and letters issued by the tax department (as claimed by the applicant, i.e., M/s. Becton Dickinson India Private Limited), cannot be treated as an eligible or valid document to claim Input Tax Credit (ITC).
• Answer 2: As TR-6 challan cannot be considered as a valid means or document to claim Input Tax Credit (ITC), there is no need to answer this question further.
• Answer 3: Claiming ITC on import IGST on the basis of a reassessed bill of entry must follow the time limit given under Section 16(4) of the CGST Act, 2017.
• Answer 4: The time limit to claim ITC on the extra IGST paid will begin from the date of the reassessment of the bill of entry.