Demand of service tax on roaming charges - The appellant, as a...

Demand of service tax on roaming charges - The appellant, as a licencee of the domestic telecommunication regulatory regime, is not conferred with empowerment to operate in a foreign territory and can neither, conceivably, offer such service independent of the overseas entity nor avail of the equipment of overseas operator for rendering ‘telecommunication service’ to its subscribers. The activity, therefore, lies outside the ambit of ‘support service of business or commerce’ which is the ‘taxable service’ sought to be fastened on the appellant as ‘deemed provider’ under section 66A - AT