Place of Supply

I think this will be considered as export by ABC.

It is goods on the vehicle the transaction covered under high sea sales

No...... it not being Export .
In term of Section 7 of IGST Act , goods neither cross the frontier of Indian Custom & As per Section 2(5) of IGST Act , export means taking goods out of India , but since the goods never came to India & hence there is no question of Export arises.

So it's is Merchant trading cover under Schedule III , neither the supply of Goods nor Supply of Services.

It is High sea transaction no gst applicable

DEAR SUNIL

ITS NOT HIGH SEA SALE. THERE IS DIFFERENCE BETWEEN MERCHANT TRADING & HIGH SEA SALE.

IN HIGH SEA SALE : THE GOODS COME TO INDIA BUT IT IS BEING SOLD BEFORE IT REACHES THE CUSTOM FRONTIERS.

MERCHANT TRADING : THE GOODS NEVER GET ENTER INTO INDIA