Explaining the case, Rastogi said a provision in the Central GST Act permitted levy of both basic Customs duty and IGST
on the cost, insurance and freight (CIF) value of goods brought into India, as well as an additional IGST
component on ocean freight between two foreign parties for movement of such goods.
For instance, if goods come from Washington to London and are shipped further to Mumbai, there is an element of ocean freight between the parties in Washington and London. This could include steamship costs, broker commissions, duties and tariffs, vessel and port maintenance costs, and labour costs, etc.
The petitioners have raised questions on the additional tax levied on the ocean freight element, when the basic customs duty and IGST
are already paid on the CIF value. This indicates double taxation, given the ocean freight element already includes CIF.