High Sea Sale tax treatment: IGST levied at importation, not on pre-import document transfers; ITC reversal unsettled.
Schedule III of the CGST Act excludes transfers by endorsement of documents of title before clearance for home consumption from the definition of supply, so IGST is not leviable at the high sea sale stage; IGST is instead imposed at importation when the importer of record clears the goods, with customs assessable value capturing cumulative value additions from successive high sea sales to prevent cascading taxation. (AI Summary)