Duty and import IGST are not the CHA's income
Customs duty and IGST on imports are the importer's own liabilities. When the CHA pays them on the importer's behalf and recovers the exact amount, they meet the pure agent conditions in Rule 33 if shown separately and backed by challans. The importer takes credit of import IGST from the bill of entry, not from the CHA invoice, so charging GST on the CHA invoice for these amounts creates a cost with no credit.
Port, CFS and shipping line charges
Terminal handling, CFS ground rent and shipping line delivery order charges are invoiced by those service providers. If they are billed in the importer's name, the CHA only passes the invoices through. If they are billed in the CHA's name, the CHA has received the service itself and must charge GST on recovering it, because it is no longer a pure agent. Ask CFS and shipping lines to bill the importer's GSTIN wherever possible.
The 18% rate and credit
Customs house agent services under 996712 are taxed at 18% with credit, and the rate was not changed in 2025. Importers registered under GST can take credit of the CHA's GST. For exporters using LUT, the CHA's service to an Indian exporter is still a domestic supply with GST, even though the goods leave India.
Advances and running accounts
CHAs often take advances to pay duty. An advance for duty is not consideration for the CHA's service and does not need a receipt voucher with tax. Advances towards the agency fee do. Maintain separate ledgers so that, at year end, duty advances are not treated as fee income.
Transport arranged by the CHA
Many CHAs also arrange the truck from port to factory. If the CHA issues its own consignment note, it is acting as a GTA for that leg and the GTA rules on rate and reverse charge apply. If it only books a transporter who bills the importer, the CHA's coordination fee is part of its 18% agency service. Billing transport inside the CHA fee at 18%, or at 5% without being a GTA, both create problems, so keep transport on its own document.
Export clearance and drawback claims
For exports, CHAs file shipping bills, attend examination and often help exporters with drawback and RoDTEP claims. The CHA's fee for this work is a domestic taxable service even though it relates to exports. The shipping bill number, port code and LEO date on the CHA invoice help the exporter link the cost to each shipment when claiming benefits.