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For imported services, the Indian recipient—not the overseas supplier—handles the Indian GST documentation, reverse-charge payment and return reporting. The transaction is outside India’s e-invoice (IRP/IRN) mandate, so neither party should upload the imported-service document to an Invoice Registration Portal merely because the recipient is a large or otherwise notified taxpayer. The foreign supplier issues its commercial invoice under its own jurisdiction; the Indian recipient keeps that invoice, issues a reverse-charge document when required, pays IGST and reports the transaction in its GST returns.
Does an imported service need an Indian e-invoice?
No. An import of services is excluded from the Indian e-invoicing requirement. The IRP FAQ expressly says that when supplies are received from an unregistered person or through import of services, e-invoicing is not applicable. That means there is no Indian IRN to generate for the foreign supplier’s invoice and no recipient-created IRP document.
This exclusion applies even when the Indian recipient’s aggregate annual turnover (AATO) would otherwise place it in the e-invoice system. E-invoicing thresholds determine whether a taxpayer must authenticate covered domestic business-to-business and other notified documents; they do not convert an import of services into an IRP-reportable transaction.
The IRP also states that an e-invoice can be generated only by the supplier. A recipient or transporter cannot create one on behalf of a foreign supplier. In an imported-service transaction, the overseas supplier is not issuing an Indian GST e-invoice, and the recipient’s reverse-charge document is not an IRP e-invoice.
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Who issues each document?
The foreign supplier’s commercial invoice
The overseas provider sends its ordinary commercial invoice or equivalent billing document. Retain the original invoice, currency and conversion details, contract or statement of work, and proof of payment. That document supports the value, service description and supplier identity but does not carry an Indian IRN.
The Indian recipient’s reverse-charge document
Where the import is liable to reverse charge and the recipient-invoice rule applies, the registered Indian recipient issues the invoice required for a supply received from an unregistered supplier. Under Section 31(3)(f) of the CGST framework, applied to the relevant import transaction, the recipient issues it on the date of receipt of the service. This is often called a self-invoice in business practice, but it is a recipient-side GST invoice, not an IRP e-invoice.
Whether reverse charge applies, the correct place of supply, valuation, tax rate and input-tax-credit eligibility depend on the service and the facts. Establish those points before deciding that the payment is an import of services subject to IGST.
When is GST payable on an imported service?
Invoice issuance and the reverse-charge time of supply are related but separate controls. For services received under reverse charge, the CBIC sectoral FAQ describes the time of supply as the earlier of:
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- the date on which payment is recorded in, or debited from, the recipient’s books; or
- the day immediately following 60 days from the date of the foreign supplier’s invoice.
For an overseas associated enterprise, the special rule is different: the earlier of the date the recipient enters the transaction in its books or the date of payment is used. Do not apply the ordinary 60-day trigger to that associated-enterprise case without checking the specific facts.
Example: payment before the 60-day point
A foreign supplier issues an invoice and the Indian company records the payment before 60 days have elapsed. The payment-booking date becomes the time of supply. The recipient should calculate IGST under reverse charge using the applicable exchange-rate and valuation rules, issue its required recipient invoice on receipt of the service, and include the liability in the return period dictated by the time-of-supply date.
Example: no payment within 60 days
If no payment is recorded by the end of the 60-day period, the time of supply is the day immediately following those 60 days. That date drives the reverse-charge tax period even if the supplier’s invoice remains unpaid.
Example: overseas associated enterprise
If the foreign provider is an associated enterprise and the recipient books the expense before making payment, the earlier book-entry date controls. The associated-enterprise exception is why the accounting-entry date must be captured in the compliance file.
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Is the 30-day rule an IRN deadline for imported services?
No. Two different 30-day references are often confused.
- Rule 47 invoice period: CBIC’s CGST Rules amendment effective 1 January 2022 provides a 30-day period for issuing an invoice for a taxable service in the circumstances covered by that rule. This is an invoice-issuance requirement, not permission or an instruction to obtain an IRN for an import of services.
- IRP reporting restriction: From 1 April 2025, taxpayers with AATO of ₹10 crore or more face a 30-day limit for reporting covered e-invoices to the IRP, according to the IRP mandate page. Imported services remain outside the covered e-invoice mandate, so that restriction does not create an import-services deadline.
For a reverse-charge import, follow the recipient-invoice and time-of-supply rules applicable to the transaction. Do not delay tax payment while waiting for an IRN, and do not upload the foreign invoice simply to satisfy a domestic 30-day IRP rule.
Step-by-step process for an Indian recipient
- Classify the transaction. Confirm that the supplier is outside India, the recipient is in India and the service meets the applicable import-of-services and place-of-supply conditions. Check whether the supplier is an associated enterprise and whether any special exemption or reverse-charge exception applies.
- Determine reverse-charge liability. Identify the legal provision that shifts IGST liability to the Indian recipient. Confirm the taxable value, currency conversion, rate and whether the recipient is registered or otherwise required to account for the tax.
- Capture the controlling dates. Record the foreign invoice date, service-receipt date, payment date, date the payment is entered or debited in the books, and—if relevant—the associated-enterprise book-entry date. Apply the earlier-of-payment-or-60-days rule, or the associated-enterprise rule, to establish the time of supply.
- Issue the recipient-side invoice. Where Section 31(3)(f) and the corresponding IGST application require it, issue the reverse-charge invoice on receipt of the service. Identify the foreign supplier, describe the service, show the taxable value and IGST, and mark the document as reverse charge according to your invoice controls. This document is not sent to the IRP for an IRN.
- Pay IGST in cash. Reverse-charge tax must be paid; input-tax credit cannot be used as a substitute for the initial reverse-charge payment. Use the tax period determined by the time of supply and reconcile the liability to the accounting entry and payment challan.
- Report the transaction in GSTR-3B. Report the reverse-charge inward supply and tax in the applicable liability table of the current GSTR-3B instructions. After paying the tax and satisfying the normal credit conditions, report the eligible credit in Table 4(A)(2), the table GSTN identifies for reverse-charge credit on import of services.
- Reconcile and retain evidence. Match the recipient invoice, foreign invoice, ledger entry, bank advice, tax payment and return figures. Keep the documents needed to establish supplier status, place of supply, valuation, exchange rate, payment and the basis for any input-tax credit.
Where does reverse-charge credit appear in GSTR-3B?
Import-of-services reverse charge is not populated through GSTR-2B. GSTN’s advisory states that reverse-charge credit on import of services is not part of that statement and continues to be entered by taxpayers in Table 4(A)(2) of Form GSTR-3B. The recipient therefore has to calculate and claim the credit itself, rather than waiting for an auto-drafted invoice from the foreign supplier.
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The tax liability itself must also be reported in the reverse-charge section of the current GSTR-3B and paid in cash. Return layouts and instructions can change, so use the version applicable to the filing period for the liability table while preserving the specific Table 4(A)(2) treatment for eligible import-of-services credit.
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E-invoice thresholds: useful context, not an import trigger
The IRP mandate was expanded in stages by AATO. The historical thresholds below explain why a recipient may be familiar with IRP reporting, but none of them brings imported services into scope.
| AATO threshold | Effective date | What it changed |
|---|---|---|
| ₹500 crore | 1 October 2020 | Initial broad e-invoice rollout for covered documents |
| ₹100 crore | 1 January 2021 | Threshold expansion |
| ₹50 crore | 1 April 2021 | Threshold expansion |
| ₹20 crore | 1 April 2022 | Threshold expansion |
| ₹10 crore | 1 October 2022 | Threshold expansion |
| ₹5 crore | 1 August 2023 | Current threshold listed on the IRP timeline for covered taxpayers |
AATO is only one scope test. The document and transaction type must also be covered. An Indian company above the ₹5 crore threshold may need IRPs for its eligible domestic B2B invoices while still issuing no IRN for an imported service.
Imported services versus an ordinary domestic reverse-charge purchase
The two transactions can both require recipient-side tax accounting, but their documentation and evidence differ.
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| Compliance question | Ordinary domestic reverse-charge supply | Import of services |
|---|---|---|
| Is an IRP e-invoice required? | Only if the supplier’s document is a covered transaction and the supplier falls within the mandate; scope and exemptions must be checked. | No Indian IRP e-invoice or IRN arises merely because the recipient is a notified or high-turnover taxpayer. |
| Who issues the invoice? | The supplier normally issues its invoice; the registered recipient issues a reverse-charge invoice where the recipient-invoice rule applies. | The foreign supplier issues its commercial invoice; the Indian recipient issues the required reverse-charge document where Section 31(3)(f) and the applicable IGST rule require it. |
| Time-of-supply trigger | Use the reverse-charge rule applicable to the domestic supply. | For services, generally the earlier of payment recorded/debited or the day after 60 days from the foreign invoice; an overseas associated enterprise uses the earlier of book entry or payment. |
| Return and payment mechanics | Report and pay reverse charge in GSTR-3B and claim eligible credit under the current return instructions. | Pay IGST in cash, report the liability in the applicable GSTR-3B reverse-charge table, and enter eligible credit in Table 4(A)(2). The amount is not supplied through GSTR-2B. |
| Evidence to retain | Supplier invoice, reverse-charge classification and payment or receipt records. | Foreign invoice, contract and service-receipt evidence, supplier location and status, place-of-supply analysis, exchange-rate calculation, payment and book-entry records, recipient invoice, tax payment and return reconciliation. |
Controls that prevent common errors
Do not create a dummy IRN
Generating an IRN for an imported service can produce a document that has no legal role in the transaction and can confuse reconciliations. Keep the foreign invoice and your recipient-side GST invoice in the accounting system without sending either to the IRP.
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Do not wait for GSTR-2B
Because the import-of-services reverse-charge credit is excluded from GSTR-2B, a missing auto-drafted entry is expected. Build a monthly schedule from the general ledger, payment register and recipient invoices instead.
Separate service receipt from payment date
The date the service is received supports recipient-invoice timing, while payment or the 60-day rule determines reverse-charge time of supply. Recording only the supplier-invoice date can lead to a late tax period or an incorrect invoice date.
Flag associated enterprises
Route cross-border payments to related parties for a separate time-of-supply check. The book-entry exception can accelerate tax compared with the ordinary 60-day calculation.
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Payment of IGST under reverse charge does not automatically make the entire amount creditable. Apply the normal conditions, restrictions and business-use tests for input tax credit and retain the supporting records.
What to verify before filing
- Supplier is genuinely outside India and the transaction satisfies the import-of-services and place-of-supply conditions.
- Reverse-charge liability, valuation, rate and currency conversion are documented.
- Foreign invoice date, receipt date, payment date, book-entry date and associated-enterprise status are captured.
- Recipient-side invoice is issued when the applicable rule requires it.
- IGST is paid in cash in the correct period.
- Liability is reported in the current GSTR-3B reverse-charge table.
- Eligible credit is entered in Table 4(A)(2), not awaited through GSTR-2B.
- No IRP upload or IRN is attempted for the imported-service document.
- Contracts, invoices, payment evidence, place-of-supply analysis and reconciliations are retained for audit.
Rules can change with the transaction and filing period
Reverse-charge applicability, place of supply, valuation, rates, exemptions, turnover thresholds and input-tax-credit eligibility are fact-specific and subject to notification changes. Before filing, check the latest CBIC and GSTN notifications, return instructions and IRP guidance for the relevant period. The stable principle for the question asked here is that an imported service does not require an Indian IRN; the Indian recipient remains responsible for the reverse-charge invoice, tax payment and return reporting when those rules apply.
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