A Bench of the Supreme Court comprising Justices J.B. Pardiwala and N. Vinod Chandran has dismissed a Special Leave Petition filed by the Union of India, declining to revive a ₹363 crore Goods and Services Tax demand raised against Vodafone Mobile Services Limited (VMSL) — a company that had already ceased to exist following its 2018 merger into Vodafone Idea Limited.
The demand traced back to VMSL's 2017 transfer of its telecom tower business to ATC Telecom Infrastructure Private Limited. In August 2024, the Directorate General of GST Intelligence issued a show-cause notice addressed to VMSL, demanding ₹363 crore in GST along with penalty in connection with that transaction. VMSL challenged the notice, arguing that it had ceased to have any independent legal existence after its 2018 amalgamation into Vodafone Idea Limited, and that a show-cause notice could not lawfully be issued to, or proceedings maintained against, a dissolved entity.
In April 2026, a Division Bench of the Bombay High Court comprising Justices G.S. Kulkarni and Aarti Sathe accepted this challenge and quashed the show-cause notice, holding that it had been issued without jurisdiction because it was addressed to an entity that no longer existed in the eyes of law. The Union of India appealed that ruling to the Supreme Court, which — on or around 7 September 2026 — dismissed the appeal, upholding the High Court's reasoning and effectively closing off the Centre's attempt to revive the demand against the merged entity.