Section 21 IGST Act - Import of Services Made on or After the Appointed Day
Section 21 of the Integrated Goods and Services Tax Act, 2017 is a transitional provision dealing with import of services around the introduction of GST. It determines the tax treatment where an imported service is supplied on or after the appointed day even though the underlying transaction may have started earlier.
Updated: 27 September 2026
Text of Section 21 of the IGST Act
21. Import of services made on or after the appointed day. - Import of services made on or after the appointed day shall be liable to tax under the provisions of this Act regardless of whether the transactions for such import of services had been initiated before the appointed day:
Provided that if the tax on such import of services had been paid in full under the existing law, no tax shall be payable on such import under this Act:
Provided further that if the tax on such import of services had been paid in part under the existing law, the balance amount of tax shall be payable on such import under this Act.
Explanation. - For the purposes of this section, a transaction shall be deemed to have been initiated before the appointed day if either the invoice relating to such supply or payment, either in full or in part, has been received or made before the appointed day.
Meaning and scope of Section 21
The provision was designed to prevent uncertainty and double taxation during the transition from the pre-GST indirect tax regime to GST. Section 21 applies where the import of services occurs on or after the appointed day, even if the transaction was initiated before that date.
The appointed day relevant to Section 21 is 1 July 2017, the date on which Section 21 came into force. The section therefore principally addresses transitional transactions straddling the commencement of GST.
What is an import of services?
Under Section 2(11) of the IGST Act, an import of services is a supply of service where the supplier is located outside India, the recipient is located in India, and the place of supply is in India. These three statutory conditions must be read together.
How Section 21 operates
| Position before the appointed day | Treatment under Section 21 |
|---|---|
| No tax paid under the existing law | The import made on or after the appointed day is liable to tax under the IGST Act, subject to the other applicable provisions. |
| Tax paid in full under the existing law | No tax is payable again on that import under Section 21. |
| Tax paid only in part under the existing law | Only the balance amount of tax is payable under the IGST Act. |
When is a transaction treated as initiated before the appointed day?
The Explanation to Section 21 provides a specific test. A transaction is treated as initiated before the appointed day if, before that day, either the invoice relating to the supply was received or payment was received or made, whether in full or in part.
Related IGST Act provisions
- Section 2 - Definitions, including "import of services".
- Section 5 - Levy and collection of integrated tax.
- Section 7 - Inter-State supply, including imported services.
- Section 13 - Place of supply where the supplier or recipient is outside India.
- Section 20 - Application of provisions of the CGST Act.
- Section 22 - Power to make rules.