Abhishek Raja
Aug 23 โ€ข 17 tweets โ€ข 5 min read โ€ข Read on X
High Sea Sales under GST ๐ŸŒŠโš“
A concept in international trade that every importer/exporter should know.
Hereโ€™s a simple guide explained slide by slide ๐Ÿงต๐Ÿ‘‡ Image
A High Sea Sale (HSS) is when goods are sold while still on the high seas, before they arrive at an Indian port and before customs clearance. Image
The key feature of HSS is that ownership of goods is transferred before they cross Indian customs frontiers. Image
In practice, the original importer sells goods to a new buyer by endorsing the Bill of Lading.
The new buyer then becomes the importer for customs purposes. Image
The final buyer, who files the Bill of Entry, is treated as the actual importer and is responsible for duties and taxes. Image
High Sea Sales are recognized under Customs law and clarified under GST to avoid confusion on taxability. Image
Under GST, HSS is considered outside the scope of supply.
This means the sale itself is not subject to GST. Image
Tax is levied only when goods are finally cleared for home consumption.
Thatโ€™s when Customs Duty + IGST are collected from the final buyer. Image
Without this rule, multiple sales in transit could attract tax at every stage.
HSS ensures only the final buyer pays GST + duty โœ… Image
Key documents in HSS include:

High Sea Sale Agreement

Endorsed Bill of Lading

Invoice from seller to buyer

Bill of Entry filed by final buyer Image
Itโ€™s important that the HSS agreement and endorsement of the Bill of Lading are done before goods enter Indian territorial waters. Image
High Sea Sales are typically used by:

Importers who sell goods mid-transit

Traders who donโ€™t want goods entering their stock

Businesses optimizing costs and logistics Image
Example:
Importer A orders goods from China.
While goods are at sea, A sells them to B via a High Sea Sale.
B files Bill of Entry โ†’ B pays Customs duty + IGST. Image
Benefits of HSS include:

Avoidance of double taxation

Flexibility in trade

Lower costs

Efficient inventory management Image
The CBIC has clarified that IGST on HSS is collected only onceโ€”at the time of import clearance by the final buyer. Image
Some believed that every HSS transaction would attract GST.
Thatโ€™s not trueโ€”the sale is outside GST. Only the final clearance attracts IGST. Image
High Sea Sales are a legitimate and GST-compliant way to transfer goods before they arrive in India.
For global traders, itโ€™s an essential tool to stay flexible, compliant, and cost-effective. ๐ŸŒ Image

โ€ข โ€ข โ€ข

Missing some Tweet in this thread? You can try to force a refresh
ใ€€

Keep Current with Abhishek Raja "Ram"

Abhishek Raja

Stay in touch and get notified when new unrolls are available from this author!

Read all threads

This Thread may be Removed Anytime!

PDF

Twitter may remove this content at anytime! Save it as PDF for later use!

Try unrolling a thread yourself!

how to unroll video
  1. Follow @ThreadReaderApp to mention us!

  2. From a Twitter thread mention us with a keyword "unroll"
@threadreaderapp unroll

Practice here first or read more on our help page!

More from @abhishekrajaram

Jul 27
Is the bunching of notices allowed? by Abhishek Raja Ram

1. The Madras HC recently held that the Bunching of Show Cause notices for Multiple Years is Not Permissible in the GST Law. The provisions for limitation U/s 73(10) and S.74(10) specify that the time limit of three or five years, respectively, is calculated from the due date for furnishing the annual return for the โ€˜Financial Yearโ€™ to which the tax relates, making each year is a separate unit with its own independent limitation period.Image
Title: Smt. R. Ashaarajaa, Partner of M/s JRD Realtors vs The Senior Intelligence Officer, DGGI Coimbatore
Court: Madras High Court
Citation: W. P. Nos. 29716
Dated: 21-Jul-2025
2. Titan Company Ltd. vs Joint Commissioner of GST and Central Excise - Madras High Court
(2024) 15 CENTAX 118

Where bunching of show cause notices for multiple assessment years under Section 73 of CGST Act had exceeded individual three-year limitation period for each year, High Court held such bunching invalid, directing separate adjudication for each year.
Read 4 tweets
Jul 24
I am sharing important judgments on the ITC mismatch between GSTR-2A and GSTR-3B.

Please bookmark the tweet/post and follow me.

Research by: Abhishek Raja Ram; 9810638155

1. ITI Ltd. vs Joint Commissioner Central Tax & Central Excise, Kozhikode - Kerala High Court
(2025) 29 CENTAX 341Image
Where impugned order was passed raising demand for mismatch in GSTR-3B and auto populated GSTR-2A return while according to petitioner, input tax credit availed in GSTR-3B returns includes input tax credit pertaining to invoices reflected in GSTR-2A, since reply and documents were not considered by authorities while passing said order, matter was to be readjudicated.
2. OCL Iron and Steel Ltd. vs State of West Bengal - Calcutta High Court
(2025) 30 CENTAX 371

Where opportunity of personal hearing was not offered and proceedings were initiated on account of difference in liability declared in GSTR-2A and that in GSTR-3B, since discrepancy was explained, matter was to be remanded back for fresh decision.
Read 7 tweets
Jun 13
Top-10 GST ITC Cases where the allegations are that the Supplier has not made the payment or their registration has been cancelled retrospectively.

These landmark cases are from IDT and GST Era.

Research by: Abhishek Raja Ram; 9810638155

Please save the post for future.

1/14 Image
The GST Department may reject your ITC claim due to your Supplier's retrospective cancellation. However, just canceling your Supplier Registration does not render your legitimate ITC ineligible.

The documentation and specific facts of each case, along with any allegations and investigations, matters.

2/14Image
Himalaya Communication Pvt Ltd vs Union of India
Himachal Pradesh High Court
[CWP No. 8809 of 2025; 06-Jun-2025]

The petitioner filed a writ petition seeking to quash the orders that denied Input Tax Credit (ITC) on the ground that the supplierโ€™s GST registration was retrospectively cancelled.

The petitioner argued that the ITC was validly claimed since tax was paid to the supplier, relevant documents were available, and the supplier had discharged its tax liability.

The Court found that neither the Assessing Officer nor the Appellate Authority had verified the genuineness of the transaction or examined supporting documents before denying the ITC.

Hence, the Court set aside the impugned orders and remanded the matter to the Adjudicating Authority for reconsideration after evaluating all relevant documents.

3/14Image
Read 14 tweets
Apr 8
๐Ÿ”ฅ GST & Restaurant Services: A Fresh Take with Swiggy, Zomato & Compliance! ๐Ÿ”

โœ… What constitutes 'Restaurant Service'?
๐ŸŸข As per Notification No. 20/2019-CT (Rate), โ€˜Restaurant Serviceโ€™ refers to the offering of food and beverages for consumption on the premises or taken away, including services provided by restaurants, messes, canteens, etc.
โœ… GST Rates for Restaurant Services

โžก๏ธ 5% without ITC - Standard case for regular restaurant services
โžก๏ธ 18% with ITC - Applied when the restaurant operates in specified premises (e.g., hotels with room tariffs exceeding โ‚น7,500 per day)
โœ… Who is Responsible for GST When Using Swiggy/Zomato?
๐ŸŸข Clarifying the GST payer
โžก๏ธ If the restaurant is not in specified premises:
๐Ÿ”น The E-Commerce Operator (ECO) is responsible for collecting GST under Section 9(5)
โžก๏ธ If the restaurant is in specified premises:
๐Ÿ”น The restaurant itself must pay GST directly (the ECO does not assume liability)
Read 9 tweets
Apr 1
FAQ's on ISD Issue..!!

โ€ข From April 1, 2025, offices receiving tax invoices for common input services must register as Input Service Distributors (ISDs) under Indian GST, as per the Finance Act, 2024.

โ€ข It seems likely that not every office needs to register, only those receiving invoices for multiple branches, with no clear exceptions noted.

Here are few FAQ's that could be helpful to reduce the confusion.

Please bookmark/save this post.Image
Q1: We currently distribute common expenses through cross-charge. Do we need to register as an ISD after April 1st, 2025?

A: Yes. The option to distribute ITC through cross-charge will no longer be available for input services received on behalf of distinct persons. You will need to register each office receiving such invoices as an ISD and distribute the ITC as per Section 20 of the CGST Act.
Q2: We have a head office that receives invoices for marketing services that benefit all our branches across India. Does our head office need to register as an ISD?

A: Yes. Since the marketing services benefit multiple branches (which are distinct persons with separate GSTINs), the head office receiving the invoices must register as an ISD.
Read 10 tweets
Mar 16
๐—ฆ๐˜๐—ฒ๐—ฝ ๐—ฏ๐˜† ๐—ฆ๐˜๐—ฒ๐—ฝ ๐—š๐˜‚๐—ถ๐—ฑ๐—ฒ ๐˜๐—ผ ๐—ฏ๐—ฒ๐—ฐ๐—ผ๐—บ๐—ฒ ๐—ฎ๐—ป๐—ฑ ๐—˜๐˜…๐—ฝ๐—ฒ๐—ฟ๐˜ ๐—ถ๐—ป ๐—œ๐—ป๐—ฐ๐—ผ๐—บ๐—ฒ ๐—ง๐—ฎ๐˜…

Seeking to become an expert in Indian Income Tax Laws requires a structured approach and sustained effort. Image
๐Ÿญ. ๐—™๐—ผ๐˜‚๐—ป๐—ฑ๐—ฎ๐˜๐—ถ๐—ผ๐—ป ๐—™๐—ถ๐—ฟ๐˜€๐˜
๐Ÿ”นBegin with a comprehensive understanding of the foundational principles.
๐Ÿ”นDelve deep into the Income Tax Act, 1961, making sure to grasp its core concepts thoroughly.
๐Ÿ”นPay attention to the schedules and amendments, as they often carry crucial details.Image
๐Ÿฎ. ๐—ฆ๐˜๐—ฎ๐˜† ๐—จ๐—ฝ๐—ฑ๐—ฎ๐˜๐—ฒ๐—ฑ
๐Ÿ”นKeep abreast of changes introduced by the Finance Act each year.
๐Ÿ”นThis will ensure that your knowledge remains current and applicable to real-world scenarios.
Read 9 tweets

Did Thread Reader help you today?

Support us! We are indie developers!


This site is made by just two indie developers on a laptop doing marketing, support and development! Read more about the story.

Become a Premium Member ($3/month or $30/year) and get exclusive features!

Become Premium

Don't want to be a Premium member but still want to support us?

Make a small donation by buying us coffee ($5) or help with server cost ($10)

Donate via Paypal

Or Donate anonymously using crypto!

Ethereum

0xfe58350B80634f60Fa6Dc149a72b4DFbc17D341E copy

Bitcoin

3ATGMxNzCUFzxpMCHL5sWSt4DVtS8UqXpi copy

Thank you for your support!

Follow Us!

:(