Roaming Services Qualify as Export for GST if Recipient Is Foreign Operator, Not Subscriber: Bombay HC

Vodafone Idea Limited Vs Union of India (Bombay High Court)

The Bombay High Court considered cross writ petitions concerning refund of Integrated GST (IGST) paid on export of telecom services. Vodafone Idea Limited sought implementation of an order-in-appeal dated 18.08.2021 granting refund of ₹1,02,74,14,843 for the period April to September 2019. The Revenue challenged the appellate order, contending that the services—International Inbound Roaming (IIR) and International Long Distance (ILD)—were consumed in Maharashtra and did not qualify as “export of services” under S

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