They added the following sentence to the latest deliveries report: "
We count a produced but undelivered vehicle to be in transit if the related customer has placed an order or paid the full purchase price for such vehicle."
They also didn't state when in-transit cars would be delivered. Previously Tesla always said that "in-transit" cars would be delivered in the beginning of the next quarter. Now this part is missing.
Bears say that these changes are important because this way Tesla can count rejected, canceled orders as "in-transit". Also in certain cases Tesla might count excess inventory vehicles as "in-transit". Let's say that there is an excess inventory red LR M3 sitting in a Norwegian parking lot. If there is an order for this model / trim in the US they can count it as in-transit. Even if there is minimal chance that Tesla will ship the car back to the US to sell it and there is no current buyer for this trim in Norway.
You can decide yourself how sensible his argument. Personally I don't know, sounds like splitting hairs. ¯\_(ツ)_/¯
2018 Q4 delivery report:
Tesla Q4 2018 Vehicle Production & Deliveries, Also Announcing $2,000 Price Reduction in US | Tesla, Inc.
2019 Q1 delivery report:
Tesla Q1 2019 Vehicle Production & Deliveries | Tesla, Inc.