TMI Blog2015 (1) TMI 226X X X X Extracts X X X X X X X X Extracts X X X X ..... dl. Commissioner (AR), for the Respondent. ORDER The appellant M/s. Vodafone Essar South Ltd. are providing in-roaming services from five circles i.e. Chennai, Andhra Pradesh, Punjab, Uttar Pradesh and West Bengal. Whenever a customer of other circles visits Bangalore circle, the assessee provides service and payment for the same is received from that circle from where the customer originates an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , the said charges are adjusted between the centres and in reality, according to the appellants there is no service provided and services received in this case. All the circles belong to the same company and therefore when one circle provides in-roaming service to another circle, there is no service element involved. Further, as far as the subscriber is concerned, the circle in which he has been a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... we also find that the claim by the appellants that once Service Tax is paid on the amount collected for roaming service from a subscriber by the home circle, amounts charged to each circle by the other circle does not attract levy of Service Tax. We also find ourselves in agreement with the submission that it cannot be said that there are service provider and service receiver in this case. In this ..... X X X X Extracts X X X X X X X X Extracts X X X X
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