• TCS u/s 206C(1H) on Goods supplied to Foreign Vessels (visiting Indian Ports) for their own use.

A Ship Chandler supplies goods to foreign ships visiting Indian Sea Ports or stationed in Indian Territorial waters (within the 12 Nautical miles range). The goods are intended for ship's own use/consumption.
Though this is Not an export sales form GST point of view (ref. link given below), can this be treated as export when reading the provisions of Income Tax Act u/s 206C(1H) for TCS on sale of goods, which excludes export sales from the purview TCS?

It seems that the apparent reason to exclude export sales from TCS is because they get monitored upon filing 'Shipping Bill' --the same goes for sales by a Ship Chandler.

(Link: http://www.gstcouncil.gov.in/sites/default/files/ruling-new/WB_AAR_30_2019_21.10.2019_SCPL.pdf)

Related Facts :-
1) GST is levied, collected and paid to govt. treasury. 
2) Invoice is issued to the foreign shipping co. in USD (foreign inward remittance is received from their overseas office).
3) To deliver goods to vessels, the goods pass through customs station at the sea port, and therefore the ship chandler is required file a 'Shipping Bill' but Not a 'Bill of Lading'.