While cellular towers uniformly use a GPS time source for TDMA reasons (which is exactly synchronized to the Naval time minus a known offset), they are surprisingly inconsistent about how time information is delivered to handsets. CDMA requires that towers rebroadcast exactly the GPS time, but GSM generally does not. As a result, GSM handsets may have less accurate time sync depending on how the time service is actually provided.
It's somewhat common for CDMA cellular equipment to be used as a stratum-1 time source in lieu of GPS, since CDMA is easier to receive inside buildings. But GSM is unsuitable for this purpose, and since the long-term prognosis for CDMA seems perhaps less than optimistic, some operators may be forced to run a GPA antenna to the roof.
It's somewhat common for CDMA cellular equipment to be used as a stratum-1 time source in lieu of GPS, since CDMA is easier to receive inside buildings. But GSM is unsuitable for this purpose, and since the long-term prognosis for CDMA seems perhaps less than optimistic, some operators may be forced to run a GPA antenna to the roof.