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2026 (2) TMI 474

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....of the case are that the appellant M/s. Vodafone Mobile Services Ltd. are engaged in providing telecommunication services which are provided in terms of telecom licenses granted by the Telecom Regulatory Authority. On verification of the records by the audit, it was noticed that the appellant had paid an amount of Rs.4,18,16,455/- to their foreign service providers on account of international outbound roaming facility under the category of 'Telecommunication Services' from April 2009 to June 2012. Accordingly, show-cause notice was issued to them demanding service tax of Rs.43,41,102/- on the amounts received with interest and proposed for penalty. On adjudication, the same was confirmed with the interest and various penalties. Aggrieved by....

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....d on the decision in the case of M/s. Vodafone Idea Ltd. vs. Commissioner of GST and CE: 2023 (10) TMI 432 and Vodafone Cellular Ltd. vs. CCE, Pune [2017 (12) TMI 1205]. It is also submitted that the entire demand is barred by limitation, since no grounds have been made out for invoking the extended period of limitation. Reliance was also placed on the following decisions: * M/s. Mega Trends Advertising Ltd. vs. CCE & ST: 2020 (38) GSTL 57 (Tri. - All.) * M/s. Gannon Dunkerly and Co., vs. CST - 2020-VIL-518-CESTAT-DEL-ST. 5. The learned Authorized Representative (AR) for the Revenue has submitted that appellant is liable to pay service tax on international roaming services as held by the Commissioner (A) in the impugned....

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....of India Ministry of Finance (Department of Revenue) Central Board of Excise & Customs, New Delhi Subject : Tarability in respect of international Private Leased Circat (IPCL) changes and amendment in the definition al Telegraph Authority tv's 55(11 1) ol'the Finance Acl, 1994 - Rlagaming Representations have been received segling cherfication ieganen tarahilly of IPCA, chargen innmed in furien currency by BPO/MNCs against receipt of services from the service provider situated outside India/group companies under reverse charge mechanism |Section 66A of the Finance Act, 1994 read with Rule 201)(G)(M) ci ite Service Tax Rules, 1994L 2 The matter has been examined. The activities are in the nature of Leased Circuit services presently ....

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....ent personnel to handle messages, secretarial services. internet and telecom facilities, partry and security. 4. It is clarified that the above activity of receiving IPCL service from abroad is chargeable to Service Tax under Business Support Service [Section 65(105)(zzzq) bidj at the hands of recipients situated in India in terms of Section 66A of the Finance Act, 1994, read with Rufe 2(1)(d)(iv) of the Service Tax Rules, 1994 and provisions of Taxation of Services (Provided) From Outside India and Received in india Rules, 2006 apply. All pending issues may be decided accordingly. Document 2 Circular - Service Tax Telecommunication service - Clarification on taxability in respect of International Private Leased Circuit (IPL....