GST Input Tax Credit on TR-6 Challans and Import Time Limits
The Appellate Authority for Advance Ruling confirmed that TR-6 challans are invalid for claiming GST input tax credit on import duty payments.
- Ruling
- Order-in-Appeal No. AAAR/06/2025 (AR) dated 08.10.2025
- Dated
- 08 Oct 2025
- Authority
- Appellate Authority for Advance Ruling
This page was written by Patron Accounting’s AI from the official release and reviewed before publishing. It explains the document in plain language. It is not the document itself. Where this page and the original differ, the original governs.
The short version
- TR-6 challans are not valid documents for claiming input tax credit.
- Input tax credit on imports is subject to Section 16(4) time limits.
- Time limits apply to both original and re-assessed bills of entry.
- The Appellate Authority for Advance Ruling dismissed the appeal.
In short
The company asked if they could claim input tax credit (ITC) on extra customs duties paid using a TR-6 challan and whether the standard time limits for claiming credit apply to these import payments. The authority decided that a TR-6 challan is just a payment receipt, not a tax document, and that all import-related credit claims must follow the strict deadlines set by law.
What has changed
How it worked before
Businesses were uncertain if TR-6 challans, which are used to pay differential customs duties after transfer pricing adjustments, could serve as valid documents to claim input tax credit.
What has changed
The authority ruled that only specific documents like bills of entry qualify for input tax credit, excluding TR-6 challans. It also confirmed that the deadline for claiming credit on imports is tied to the original or re-assessed bill of entry date, meaning you cannot claim credit indefinitely.
Who this affects
Importers who pay differential customs duties or IGST after the initial import clearance, particularly those dealing with transfer pricing adjustments.
An example
A medical device importer pays extra IGST after a transfer pricing audit using a TR-6 challan. They try to claim this as input tax credit in their next return. Based on this ruling, the tax department would likely deny the credit because the TR-6 challan is not a valid document for this purpose.
What you should do
Do not rely on TR-6 challans to claim input tax credit, as they will likely be rejected. Remember that this ruling only binds the company that asked; your local tax officer may have a different view, so consult your tax advisor before changing your filing process.
If you do nothing
If you claim credit based on a TR-6 challan, you risk a formal notice from the tax department demanding the money back plus interest and penalties. Assuming this ruling applies to you could lead to costly litigation if your local officer disagrees with your interpretation.
The terms explained
- TR-6 challan
- A standard government treasury form used to deposit money into the bank, which does not contain the specific tax details required to claim a credit.
- Input tax credit
- The tax a business pays on its purchases that it can use to reduce the tax it owes on its own sales.
- Section 16(4)
- A specific part of the GST law that sets the final deadline for claiming tax credits, usually by November following the end of the financial year.
The ruling in detail
Appellate Authority for Advance Ruling
M/s. Becton Dickinson India Private Limited
Order-in-Appeal No. AAAR/06/2025 (AR) dated 08.10.2025 · Tamil Nadu
Questions before the authority
- 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?
- 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?
- Whether the eligibility to avail ITC of the import IGST paid vide re-assessed bill of entry is subject to the time limit prescribed under Section 16(4) of the CGST Act?
- If the answer to Q.3 for bill of entry is in affirmative, whether the time limit for availing ITC would begin from the initial date of bill of entry originally filed or from the date of re-assessment of bill of entry.
Facts
The applicant imports medical equipment from overseas group companies and pays customs duties, including IGST. Due to transfer pricing adjustments, the applicant periodically pays differential customs duties, sometimes via re-assessed bills of entry and sometimes via TR-6 challans. The applicant sought to claim Input Tax Credit (ITC) on these differential payments, leading to a dispute regarding the validity of TR-6 challans as tax-paying documents and the applicability of time limits under Section 16(4).
Ruling
| Question | What the authority ruled |
|---|---|
| Validity of TR-6 challan for ITC | Not an eligible document Neither a TR-6 challan alone nor one read with SVB orders and tax authority letters qualifies as a valid document for ITC. |
| Time limit for ITC on TR-6 challan | Question does not arise Since the document is not eligible for ITC, the question of time limit applicability is moot. |
| Time limit for ITC on re-assessed bill of entry | Subject to Section 16(4) time limit ITC on imports via bill of entry is governed by the time limit prescribed under Section 16(4). |
| Commencement of time limit for re-assessed bill of entry | From the date of re-assessment The time limit for availing ITC on differential IGST paid begins from the date of re-assessment of the bill of entry. |
The Appellate Authority upheld the original Advance Ruling, confirming that a TR-6 challan is not a valid document for availing ITC under the GST framework. Furthermore, it held that ITC on imports, whether based on an original or re-assessed bill of entry, is subject to the time limit prescribed under Section 16(4) of the CGST Act. The appeal filed by the applicant was dismissed.
Reasoning
The authority reasoned that a TR-6 challan is merely a treasury document for transferring money and lacks the essential details of a tax invoice or bill of entry required for ITC. It relied on Section 16(2) and Rule 36(1)(d) of the CGST Rules, noting that only documents prescribed for the assessment of integrated tax qualify. Regarding the time limit, it applied Section 16(4) of the CGST Act, interpreting it through the doctrine of mutatis mutandis as applicable to IGST on imports. It concluded that the legislative intent is to restrict ITC claims to the timeline linked to the annual return or the thirtieth day of November following the end of the financial year.
Provisions relied on
- Section 16(2) of the CGST Act
- Section 16(4) of the CGST Act
- Section 20 of the IGST Act
- Rule 36(1)(d) of the CGST Rules
- Section 2(2) of the Customs Act
For the practitioner
This ruling clarifies that **TR-6 challans are not valid documents** for claiming ITC on differential customs duty payments. It reinforces that **Section 16(4) time limits apply to imports** and that taxpayers should ensure re-assessment of bills of entry rather than relying on alternative payment methods to secure their ITC eligibility. It does not provide relief for past claims made via TR-6 challans.
Source
This is a summary prepared from the published order, which is a scanned document. It is a reading aid and not the authority: where the two differ, the order governs. Verify every provision against the original before relying on it.
Original order: https://www.gstcouncil.gov.in/sites/default/files/2026-02/becton_dickinson_aaar_order_1.pdf
Legibility of the scan, as read: high.
Prepared 15-10-2026.
About Patron Accounting LLP
Patron Accounting LLP is a CA and CS-led accounting and compliance firm that has been working with businesses across India since 2019. We handle the work that keeps a company correct with every department it answers to: day-to-day bookkeeping and accounting, GST registration and returns, income tax filing and assessments, TDS, payroll and PF/ESI, company and LLP incorporation, ROC and MCA compliance, statutory and internal audit, physical stock and inventory audits, trademark and other registrations, and the certificates and reports that banks, buyers and regulators ask for.
Our clients range from a first proprietorship registering for GST to established companies running operations across several states. Much of our work is exactly this: reading what a department has published and telling a business, in plain terms, whether it changes anything for them.
We operate from five offices and serve clients across the rest of India remotely:
- Pune (HQ): RTC Silver, B4-708, Sai Satyam Park, Wagholi, Pune, Maharashtra 412207
- Mumbai: 104, Rajshila Building, 597 J.S.S. Road, Marine Lines, Mumbai 400002
- Delhi: 3rd Floor, B-6/154-155, Sector 5, Rohini, Delhi 110085
- Gurugram: Pioneer Urban Square, B109, Golf Course Ext Road, Sector 62, Gurugram 122098
- Ahmedabad: Phoenix Tower, 1107, near Commerce Six Road, Drive In Road, Navrangpura, Ahmedabad, Gujarat 380009
If anything on this page affects you and you would like somebody to look at your own position, we are glad to help. Call +91 94594 56700, write to sales@patronaccounting.com, or visit patronaccounting.com. The first conversation costs nothing.