Dialog Broadband Networks (Private) Limited vs Commissioner General of Inland Revenue – CA TAX/0017/2019-2023

In the case between Dialog Broadband Networks (Private) Limited (Appellant) and the Commissioner General of Inland Revenue (Respondent), the court addressed whether a disbursement made by the Telecommunication Regulatory Commission (TRC) from the Telecommunications Developing Charge (TDC) fund constitutes a taxable supply of services under the Value Added Tax Act or is instead a refund of a fiscal levy. The court determined that such disbursement is a refund of a fiscal levy upon fulfillment of an eligibility criterion, and not consideration for a taxable supply of services. This holding reaffirmed the principle that for a transaction to qualify as a taxable supply under the VAT regime, there must be consideration for a service provided—a condition not satisfied by the TRC disbursement mec