Post on 25-Jan-2023
Report of theComptroller and Auditor General
of India
Sharing of Revenue by Private Telecom Service Providers
during the years 2006-07 to 2009-10
Union Government(Communications and IT Sector)
No. 4 of 2016
Report No. 4 of 2016
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CONTENTS
Description Paragraph Page
Preface xi
Executive Summary xiii
Chapter – I : Introduction
Genesis of revenue sharing regime in the Indian Telecom Sector 1.1 1
New Telecom Policy-1999 1.2 1
Unified Access Service Licence (UASL) and Unified Licences (UL) 1.3 2
Provisions in the Licence agreements on definition of Gross Revenue (GR)/Adjusted Gross Revenue (AGR)
1.4 2
Stipulations in UASL Agreements on reporting revenue and payment of LF
1.5 4
Rates of licence fee 1.6 6
Allocation of Spectrum and Spectrum Usage Charges 1.7 6
Revenue share collected by DoT 1.8 7
Arrangements in DoT for collection and accounting of licence fee and SUC
1.9 8
Chapter – II : Audit Approach
Scope of Audit 2.1 9
Audit methodology 2.2 10
Audit criteria 2.3 11
Acknowledgement 2.4 11
Chapter-III: Revenue shared by M/s Bharti Airtel Limited and M/s Bharti HexacomLimited
Brief Profile of M/s Bharti Airtel Limited and M/s Bharti Hexacom Limited
3.1 13
Licenses granted to M/s Bharti Airtel Limited and M/s Bharti Hexacom Limited
3.1.1 13
Spectrum allotted to M/s BAL/BHL 3.1.2 14
Subscriber base of BAL/BHL 3.1.3 15
Gross Revenue, Deduction, Adjusted Gross Revenue reported and revenue share paid by BAL/BHL
3.1.4 15
Under reporting of revenue by BAL/BHL 3.2 15
Under reporting of revenue due to netting off of revenue pertaining to Commission/offers/discounts to dealers/subscribers for prepaid services
3.2.1 16
Under reporting of revenue due to netting off of discounts/waivers granted to post-paid subscribers
3.2.2 20
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Description Paragraph Page
Under reporting of Roaming Revenue due to set off of Inter Operator traffic (IOT) Discounts paid/credited to other Operators
3.2.3 22
Under reporting of revenue from Infrastructure sharing with other telecom operators for GR/AGR by BAL/BHL
3.2.4 23
Under reporting of revenue from Forex gain for GR/AGR by BAL/ BHL
3.2.5 25
Under reporting of revenue in the Statements of Revenue and LF (AGR Statements) though reported in the books of accounts
3.3 27
Non consideration of Interest Income for GR/AGR 3.3.1 27
BAL’s interest free loan to subsidiary resulted in avoidance of payment of LF/SUC
3.3.2 29
Non consideration of Profit on sale of Investment for GR/AGR for payment of revenue Share by BAL
3.3.3 29
Different standards for payment of dividends 3.3.4 30
Non Consideration of revenue accounted under Global Operations (BILGO) for LF
3.3.5 30
Non Consideration of revenue of erstwhile SBEL 3.3.6 32
Non consideration of revenue accounted under Infrastructure Provider (IP)-1 service for computation of revenue share by BAL
3.3.7 33
Non consideration of miscellaneous income for AGR for computation of LF/SUC by BAL
3.3.8 34
Non consideration of Income from profit on sale of fixed assets for AGR for payment of revenue Share by M/s BAL
3.3.9 35
Short/ non-payment of revenue share due to other issues 3.4 36
Irregular Deduction of Bad debts written off from GR to arrive at AGR by BAL/BHL
3.4.1 36
PSTN Deduction claimed against Leased Line Charges in 2006-07 3.4.2 37
Non consideration of revenue from sale/lease of bandwidth charges for AGR for payment of SUC
3.4.3 37
Transfers of telecom infrastructure assets by BAL to its subsidiary (BIL) at NIL value
3.5 38
Interest on short/non-payment of LF and SUC 3.6 39
DoT’s response to the audit observations 3.7 39
Chapter – IV : Revenue shared by Vodafone India Limited
Brief Profile of M/s Vodafone India Ltd 4.1 43
Licenses held by Vodafone Group 4.1.1 43
Radio frequency spectrum held by M/s Vodafone 4.1.2 43
Subscriber base growth - 2006-07 to 2009-10 4.1.3 44
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Description Paragraph Page
Financial data on GR/Deductions/AGR and revenue share paid by Vodafone India Limited
4.1.4 44
Audit verification of accounting and reporting of GR by Vodafone 4.2 44
Commission/discounts to dealers netted of from pre-paid and post-paid revenue
4.2.1 45
Airtime Discounts to customers 4.2.2 46
Roaming revenue understated due to netting of Inter Operator traffic (IOT) Discounts paid/credited to other Operators
4.2.3 46
Understatement of GR due to Service Tax being set off from revenue on schemes like ‘Full Pe Full’, ‘Full Talk Time’ etc.
4.2.4 47
Understatement of GR due to non-inclusion of revenue from Infrastructure sharing in full
4.2.5 48
Under reporting of revenue from FOREX gains for GR/AGR 4.2.6 49
Debits from revenue as Waiver- Goodwill waiver, rebates etc. 4.2.7 51
Other Income not included in Gross Revenue 4.3 51
Interest Income 4.3.1 52
Income received on profit of Sale of fixed assets not included in GR 4.3.2 52
Bad debts deducted from GR 4.4 53
Transfer of assets to subsidiary Company 4.5 54
Interest on revenue share short paid 4.6 54
DoT’s response to the audit observations 4.7 55
Chapter – V : Revenue shared by M/s Reliance Communications Limited and M/s Reliance Telecom Limited
Brief Profile of M/s Reliance Communications Limited (RCL) and Reliance Telecom Limited (RTL)
5.1 57
Licences granted to RCL and RTL 5.1.1 57
Spectrum allotted to RCL/RTL 5.1.2 57
Subscriber base of RCL/RTL 5.1.3 58
Gross Revenue (GR), Deduction, Adjusted Gross Revenue (AGR) reported and revenue share paid by RCL/RTL
5.1.4 58
Arrangement between RCL and its subsidiary RCIL for Value added Services, Selling/ Marketing and Billing
5.1.5 59
Under reporting of Gross Revenue in the books of accounts of RCL/RTL
5.2 60
Booking of Prepaid revenue net of Free Air Time/Commission by RCL/RTL
5.2.1 60
Booking of revenue by RCL net of commission given to its subsidiary (RCIL) and booking of revenue in the subsidiary (RCIL) books of accounts instead of RCL’s accounts
5.2.2 61
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Description Paragraph Page
Netting of commission from the revenue by RCL for computation of GR/AGR
5.2.3 68
Netting of revenue earned from channel partners/Franchisees from expenses for computation of GR/AGR by RCL
5.2.4 68
Netting of revenue by discount given to distributors/dealers/franchisees on sale on prepaid products for computation of GR/AGR by RTL
5.2.5 68
Non - inclusion of value of Free of Charge (FOC) recharge vouchers given to distributors for computation of GR/AGR by RTL
5.2.6 70
Under reporting of revenue in the Statements of Revenue and LF (AGR Statements) though reported in the books of accounts
5.3 71
Non consideration of forex gain in GR/AGR by RCL and RTL 5.3.1 71
Non consideration of Interest/Other income for computation of GR/AGR by RCL/RTL
5.3.2 72
Interest free loan to subsidiary by RCL resulted in avoidance of payment of LF/SUC
5.3.3 74
Netting off of loss on sale of investment and non - inclusion of balance profit on sale of investment for computation of GR/AGR by RTL
5.3.4 74
Different standards for payment of dividends – RCL 5.3.5 75
Revenue considered for Licence Fee but not considered for Spectrum Usage Charges (SUC)
5.4 75
Non consideration of revenue from sale/lease of bandwidth for computation of SUC
5.4.1 75
Non consideration of income from investment for computation of SUC
5.4.2 76
Transfer of infrastructure assets by RCL/RTL to its subsidiary Reliance Infratel Ltd (RITL)
5.5 77
Transfer of Optic Fibre Undertaking (OFU) by RCL to RITL 5.5.1 77
Transfer of passive infrastructure by RCL/RTL to its subsidiary (RITL) at “nil’ value
5.5.2 78
Non-consideration of Refund of Service Tax for GR during the year 2009-10
5.6 79
Interest on short/non - payment of LF and SUC 5.7 80
Reply from DoT on issues raised above 5.8 80
Chapter – VI : Revenue shared by Idea Cellular Limited (ICL) and Aditya Birla Telecom Limited (ABTL)
Brief profile of the company 6.1 83
Licences granted to Idea Cellular Ltd (ICL) & Aditya Birla Telecom Ltd. (ABTL)
6.1.1 83
Spectrum allotted to ICL / ABTL 6.1.2 84
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Description Paragraph Page
Subscriber base of ICL/ ABTL 6.1.3 84
Gross Revenue, Deduction and Adjusted Gross Revenue reported and revenue share paid by ICL/ ABTL
6.1.4 84
Under reporting of revenue by ICL/ ABTL 6.2 84
Under reporting of revenue due to netting off of revenue pertaining to Commission/offers/discounts to dealers/subscribers for prepaid services
6.2.1 85
Under reporting of revenue due to netting off of discounts granted to post-paid subscribers
6.2.2 88
Under reporting of Roaming Revenue due to set off of Inter Operator traffic discounts paid/credited to other Operators
6.2.3 89
Under reporting of revenue from Infrastructure sharing revenue from other telecom operators for GR/AGR by ICL/ABTL
6.2.4 90
Non consideration of revenue from Switch sharing between Idea (NLD) and Idea (LSAs) for GR/AGR
6.2.5 92
Non consideration of revenue by ICL from assets given on Indefeasible Right to Use (IRU) for GR/AGR
6.2.6 93
Under reporting of revenue from Forex gain (revenue) for GR/AGR by ICL/ ABTL
6.2.7 94
Under reporting of revenue in the Statements of Revenue and LF (AGR Statements) though reported in the books of accounts
6.3 95
Non consideration of Interest Income for GR/AGR by ICL/ ABTL 6.3.1 95
Non consideration of profit on sale of Investment for GR/AGR for payment of revenue Share by ICL/ ABTL
6.3.2 96
Non consideration of miscellaneous income for AGR for computation of LF/SUC by M/s ICL
6.3.3 98
Non consideration of Income from profit on sale of fixed assets for AGR for payment of revenue Share by ICL/ABTL
6.3.4 99
Short/ non-payment of revenue share due to other issues 6.4 100
Irregular Deduction of Bad debts written off from GR to arrive at AGR by ICL
6.4.1 100
Other issues 6.5 101
Transfer of infrastructure assets by Idea Cellular Ltd to its subsidiary at NIL consideration for ultimate transfer to a Joint Venture
6.5.1 101
Interest on short/non-payment of LF and SUC 6.6 102
DoT’s response to the audit observations 6.7 102
Chapter–VII: Revenue shared by Tata Teleservices Limited and Tata Teleservices (Maharashtra) Limited
Brief profile of the company 7.1 103
Licenses granted to TTSL and TTML 7.1.1 103
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Description Paragraph Page
Spectrum allotted to TTSL and TTML 7.1.2 103
Subscriber base of TTSL and TTML 7.1.3 104
Gross Revenue, Deduction, Adjusted Gross Revenue reported and revenue share paid by TTSL and TTML
7.1.4 104
Under reporting of revenue by TTSL and TTML 7.2 104
Commission paid to Distributors/Franchisees/Agents/Dealers etc. debited from the Revenue in respect of TTSL
7.2.1 105
Revenue understated due to netting of discounts allowed to subscribers etc. by TTSL and TTML
7.2.2 105
Netting of adjustments offered to customers from the Gross Revenue in respect of TTSL and TTML
7.2.3 106
Netting of the revenue from Startup Kit, recharge vouchers etc. by TTSL and TTML
7.2.4 107
Non consideration of income received from infrastructure sharing in GR by TTSL
7.2.5 108
Non- inclusion of realized forex gain for computation of GR by TTSL and TTML
7.2.6 109
Under reporting of revenue in the Statements of Revenue and LF (AGR Statements) though reported in the books of accounts
7.3 110
Non consideration of interest income in GR/AGR by TTSL 7.3.1 110
Profit on sale of Investment not considered in GR/AGR 7.3.2 111
Non consideration of profit on sale of assets for GR/AGR 7.3.3 111
Short/ non-payment of revenue share due to other issues 7.4 112
Bad debts written off adjusted from the revenue by TTSL resulting in understatement of AGR
7.4.1 112
Lease line and Port Charges included in deductions claimed by TTSL and TTML resulting in understatement of AGR
7.4.2 112
Non consideration of revenue from sharing/leasing of infrastructure/bandwidth links for payment of SUC by TTSL
7.4.3 113
Non-consideration of Rental Income 7.4.4 114
Interest on short/non-payment of LF and SUC 7.5 114
DoT’s response to the audit observations 7.6 114
Chapter–VIII: Revenue shared by Aircel Group (Dishnet Wireless Ltd, Aircel Ltd and Aircel Cellular Ltd)
Brief Profile of Aircel Group 8.1 115
Licenses granted to Aircel Group 8.1.1 115
Spectrum allotted to Aircel group of companies 8.1.2 115
Subscriber base of AL/ACL/DWL 8.1.3 116
Gross Revenue (GR), Adjusted Gross Revenue (AGR) and Revenue share paid by the Aircel Group
8.1.4 116
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Description Paragraph Page
Under reporting of revenue by Aircel Group 8.2 116
Under reporting of Prepaid/Post-paid revenue due to netting off of revenue relating to various offers given to subscribers
8.2.1 116
Short accounting of revenue due to upfront debit in the revenue heads
8.2.2 120
Under reporting of prepaid revenue due to set off of revenue pertaining to Commission/Discount allowed to the distributors
8.2.3 120
Under reporting of revenue due to set off on account of “Impact of Market stock”
8.2.4 121
Non consideration of revenue from Infrastructure sharing from other telecom operators for GR/AGR
8.2.5 122
Short/Non-consideration of revenue from Forex gain in GR/AGR 8.2.6 123
Non/Short consideration of Interest Income for GR/AGR 8.2.7 124
Non consideration of Income from Investment for GR/AGR for payment of revenue Share
8.2.8 125
Non consideration of Miscellaneous income for GR/AGR 8.2.9 126
Non consideration of Income from profit on sale of fixed assets for payment of revenue share
8.2.10 127
Non Inclusion of Profit on revaluation of assets in GR 8.2.11 129
Short/non-payment of revenue share due irregular/excess deductions claimed in the AGR Statements
8.3 129
Irregular deduction of bad debts written off from GR to arrive at AGR
8.3.1 129
Excess Deductions claimed in ISP (IT) AGR 8.3.2 130
Interest on short/non-payment of LF and SUC 8.4 132
DoT’s response to the audit observations 8.5 132
Chapter–IX: Verification of deduction claims in the Offices of the Controllers of Communications Accounts
Introduction 9.1 133
Audit Observations 9.2 133
Deductions allowed in absence of required proof 9.2.1 133
Ineligible deductions allowed from GR 9.2.2 134
Inadmissible deduction on account of Service Tax 9.2.3 135
Allowing deduction twice on same claim 9.2.4 136
Excess deduction allowed by Pr. CCA Andhra Pradesh while restricting deduction claims not supported by proof documents for TDS
9.2.5 137
Allowance of deduction on account of TDS despite non-submission of TDS certificate
9.2.6 137
Claims disallowed despite submission of proof documents 9.2.7 138
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Description Paragraph Page
CsCA permitted irregular deductions on inter-divisional adjustments of ` 432.64 crore
9.2.8 139
Miscellaneous Observations 9.2.9 140
DoT’s response 9.3 143
Chapter–X: Assessment of Licence Fee and Spectrum Usage Charges
Introduction 10.1 145
Audit Findings 10.2 145
Under assessment of GR due to omission of revenues disclosed in reconciliation statements
10.2.1 145
Lack of coordination between LF and WPF Wing 10.2.2 146
Issue of demand notes based on Special Audit and provisional assessment without proper due diligence
10.2.3 147
Delay in submission of documents by service providers and absence of proper policy on time schedule leading to delay in verification of deductions by CsCA
10.2.4 148
Non assessment of LF of NLD, ILD and ISP for the year 2006-07 to 2009-10
10.2.5 149
Non recovery of LF and SUC on international roaming claimed by the Telecom Service Providers
10.2.6 149
Lack of appellate mechanism resulting in high number of litigations 10.2.7 151
ANNEXURES
Annexure No. Chapter No. Page No.
1.01 Chapter I 157
3.01 to 3.24 Chapter III 158
4.01 to 4.10 Chapter IV 184
5.01 to 5.21 Chapter V 194
6.01 to 6.17 Chapter VI 220
7.01 to 7.21 Chapter VII 236
8.01 to 8.20 Chapter VIII 258
9.01 to 9.02 Chapter IX 278
10.01 to 10.03 Chapter X 280
Glossary 285
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PREFACE
This Report has been prepared for submission to the President under Article 151 of the Constitution of India.
The audit report aims to bring out the deficiencies noticed in the sharing of revenue by the Private Service Providers (PSPs) in telecom sector with the Government. Article 266 of the Constitution of India and Sections 13, 16 and 18 of Comptroller and Auditor General’s (Duties, Powers and Conditions of Service) Act, 1971 make it obligatory on the part of Comptroller and Auditor General of India to satisfy himself that the Government of India has received its complete and correct share of revenue. Accordingly, the books of accounts and other related records maintained by the Department of Telecommunication and PSPs were examined by the audit with the sole objective of ensuring that the revenue earned by the PSPs is shared with the Government in the spirit intended by agreements signed by the PSPs with the Government.
This audit has been conducted in conformity with the Auditing Standards issued by the Comptroller and Auditor General of India.
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EXECUTIVE SUMMARY
1. Revenue share model in Indian Telecom Sector
With a view to ensure availability of state of the art technology and services in the
communication market, the Government in 1999 introduced the New Telecom Policy
(NTP 99). NTP - 99 introduced the revenue sharing regime in which telecom licensees were
required to share a percentage of their Adjusted Gross Revenue (AGR) with the Government
as License Fee (LF). Mobile operators were also required to pay Spectrum Usage Charges
(SUC) for the use of the radio frequency spectrum allotted to them. To revive the slowing
down in the telecom sector and to help the financially constrained telecom service providers,
a bailout package was offered to them. All the existing service providers were permitted
to migrate to the new revenue share regime from the fixed license fee regime of National
Telecom Policy 1994 (NTP-94). All of the licensees accepted the bailout package and
moved over to the new regime. New licenses conditions were framed in 2001 defining the
revenue of the licensee companies and other terms and conditions for computation of the
AGR and payment of LF. These were accepted by all the service providers.
2. Rationale for audit by CAG of India on the correctness of revenue share paid
by private telecom operators
The revenue shared by Private Service Providers (PSPs) with Government of India (GOI) as
LF and SUC forms part of the Consolidated Fund of India. Article 266 of the Constitution
of India and Sections 13, 16 & 18 of Comptroller and Auditor General’s (Duties, Powers
and Conditions of Service) Act, 1971 make it obligatory on the part of CAG of India to
satisfy himself that the Government of India has received its complete and correct share.
Further, the ‘Telecom Regulatory Authority of India, Service Providers (Maintenance of
Books of Accounts and other Documents) Rules, 2002’, promulgated by the Government in
November 2002 contains enabling provisions for verification of all the accounting records
and documents maintained by the service providers that has a bearing on the Gross Revenue
(GR) of the service providers by the CAG of India. As the correctness of revenue share
is directly linked to the correctness of the GR of the service provider, it was imperative
to verify the accounting records of all the service providers to ensure that revenue due to
the Government was reported correctly. Consequently, it was decided to take up the audit
verification of the revenue shared by six major telecom service providers, in the first phase,
covering the accounts of four years from 2006-07 to 2009-10 and to conduct similar audit
of all the service providers every year in future.
3. Structure of the Report
This report consists of ten chapters and annexures. Chapter-I gives an overview of the genesis
of revenue sharing regime in the telecom sector and also presents important conditions
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stipulated by the Government, through the licence agreements with the service providers,
for reporting their revenue and payment of revenue share. It also covers the arrangements
in Department of Telecommunication (DoT) for collection of LF and SUC and their final
assessment. Chapter-II explains the audit scope, methodology and reasons for selecting
the operators covered in the first phase of audit. PSP wise audit findings are narrated in
Chapters-III to VIII. Chapter-IX deals with audit findings on process of verification of
deductions at the offices of the Controllers of Communication Accounts (CsCA). Chapter-X
deals with audit observations on assessment of LF and SUC by DoT.
4. Summary of important audit findings
(i) GR/AGR understated by all the PSPs by the amount of commission/discount
paid to their distributors/dealers/agents
PSPs employ distributors/dealers/agents/franchisees to sell their prepaid products and for
customer acquisition and pay commission/discounts etc. to them. All the six PSPs have
reduced the GR/AGR reported to DoT by the amount of commission/discounts etc. paid
to distributors/dealers/agents/franchisees. However, different PSPs have accounted these
transactions in different ways. While Airtel and Tata Teleservices Limited (TTSL) have
booked the amount of commission/discounts etc. as a debit entry to revenue, Reliance and
Aircel have booked the revenue per se after netting of discounts/commission. Different
LSAs of Vodafone and Idea have accounted it in either of the ways mentioned above
whereas Tata Teleservices Maharashtra Limited (TTML) has booked it as expenses. Since
commission/discounts etc. paid to distributors/dealers/agents/franchisees is in the nature of
business expense (marketing expense), netting off or reducing the revenue for the purpose
of reporting GR/AGR for computation of revenue share to GOI is against the license
agreement. Amount of discount/commission etc. netted off from revenue worked out by
audit comes out to be ` 5672.66 crore resulting in short payment of LF and SUC by
` 487.09 crore and ` 203.38 crore respectively.
(Para 3.2.1A, 4.2.1, 5.2.2 A, 5.2.3, 5.2.5, 5.2.6, 6.2.1A, 7.2.1, 7.2.4, 8.2.3)
(ii) GR/AGR understated by all the PSPs by the amount of promotional schemes
like Free Talk Time/Free Air Time
Tariff has been defined in the Unified Access Services License (UASL) agreement. PSPs
submit quarterly tariff plans to Telecom Regulatory Authority of India (TRAI). Audit
noticed that PSPs provide various offers like Free Talk Time/Free Air Time (FTT/FAT) to
their prepaid subscribers on different occasions. These are basically promotional schemes
by various names, over and above the tariff plans submitted to TRAI. UASL agreements
provide that service revenue (amount billable) shall be shown gross and details of discount/
rebate indicated separately. It was noticed by audit that promotional offers have not been
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recognised as revenue by all the six PSPs and they have accounted it differently in their
books of accounts. In the books of accounts of Airtel, Idea, Tata and Aircel, amount of
promotional FAT/FTT given to subscribers could be identified by audit as it had been
accounted as debit entries to revenue heads. No such information could be ascertained from
the books of accounts of Reliance as it has eliminated the value of promotional FAT/FTT
at the technical system (mediation level) itself without reflecting it in the financial systems
and the books of accounts. In respect of Vodafone, it could not be segregated as it has
booked such promotional offers, on both the prepaid & post-paid services, in one account.
Similarly, in case of Aircel, waivers to both prepaid and postpaid customers were accounted
together, the impact of such waivers on LF and SUC was calculated in entirety and included
here. Since such promotional offers are in the nature of business expenses, in accordance
with UASL agreements, they should be recognised as revenue for the purpose of GR/AGR
for computation of revenue share to GOI. Audit worked out understatement of GR/AGR
on this account by ` 8960.81 crore resulting in short payment of LF and SUC by ` 784.28
crore and ` 271.29 crore respectively.
(Para 3.2.1 B, 4.2.2, 4.2.4, 5.2.1, 6.2.1B, 7.2.2, 8.2.1)
(iii) Understatement of GR/AGR by netting-off of discounts/waivers given to
postpaid subscriber
Audit noticed that discounts/waivers given to post-paid subscribers by Airtel, Vodafone,
Idea, Tata and Aircel was deducted from their revenue. Such discounts/waivers, over and
above the tariff plan submitted to TRAI, granted to post paid subscribers are in nature of
business expense and their deduction from revenue for reporting GR/AGR for computation
of revenue share is not in accordance with the license agreements. Audit worked out
understatement of GR/AGR on this account as ` 1622.18 crore resulting in short payment
of LF and SUC by ` 148.94 crore and ` 66.66 crore respectively.
(Para 3.2.2, 4.2.7, 6.2.2, 7.2.3, 8.2.1A)
(iv) Understatement of GR/AGR by netting of discounts from revenue pertaining to
roaming services.
PSPs have arrangements with other International Operators for roaming services. It has
been noticed that the Inter Operator traffic (IOT) discounts paid/credited to the accounts of
these Operators were debited/deducted from the roaming revenue by Airtel, Vodafone and
Idea. Having roaming arrangement with other national/ international operators is a matter
of mutual agreement between two operators and giving discounts over and above the agreed
charges for roaming is part of overall commercial strategy to enhance business between the
two operators. As such, these discounts are in the nature of expenses and hence, in terms of
license agreements, should not be deduced from revenue. Audit worked out understatement
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of GR/AGR for computation of revenue share on this account as ` 437.02 crore resulting
in short payment of LF and SUC by ` 41.41 crore and ` 18.66 crore respectively.
(Para 3.2.3, 4.2.3, 6.2.3)
(v) Understatement of GR/AGR by netting of revenue from infrastructure sharing
UASL agreements provide that GR shall be inclusive of revenue from infrastructure sharing
without setting off of any related item of expenses. PSPs have arrangements with other
PSPs for sharing of their passive infrastructure. Audit has noticed that amount received
towards infrastructure sharing in the case of Airtel, Vodafone, Idea, Tata and Aircel has
not been taken to revenue in full, instead, part of it has been credited to expenses. This
has resulted in understatement of revenue from infrastructure sharing for computation of
GR/AGR for the purpose of revenue share. Understatement of GR/AGR on this account
was worked out by audit as ` 1175.45 crore resulting in short payment of LF and SUC by
` 101.60 crore and ` 46.36 crore respectively.
(Para 3.2.4, 4.2.5, 6.2.4, 7.2.5, 8.2.5)
(vi) Understatement of GR/AGR due to short/non-inclusion of forex gain by all
PSPs
In terms of definition of GR, forex gain should be included in GR/AGR for computation of
revenue share. Audit noticed that all the six PSPs have included forex gain in GR/AGR for
computation of revenue share in initial years. However, subsequently all the six PSPs either
stopped including forex gain in GR/AGR for computation of revenue share or partially
included forex gain in GR/AGR for computation of revenue share. Audit worked out
amount of non-inclusion of forex gain (realized) in GR/AGR as ` 2095.86 crore resulting
in short payment of LF and SUC by ` 174.48 crore and ` 51.19 crore respectively.
(Para 3.2.5, 4.2.6, 5.3.1, 6.2.7, 7.2.6, 8.2.6)
(vii) Understatement of GR/AGR by all PSPs by non- inclusion of interest income
License agreements expressly provide that interest income should be included in GR/
AGR for computation of revenue share. Audit noticed that the six PSPs have included
interest income in GR/AGR for computation of revenue share in initial years. However,
subsequently all PSPs either stopped including interest income in GR/AGR for computation
of revenue share or partially included interest income in GR/AGR for computation of
revenue share. Audit worked out amount of non-inclusion of interest income in GR/AGR
as ` 6299. 90 crore resulting in short payment of LF and SUC by ` 535.23 crore and
` 204.32 crore respectively.
(Para 3.3.1, 4.3.1, 5.3.2, 6.3.1, 7.3.1, 8.2.7)
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(viii) Understatement of GR/AGR by all PSPs by non-inclusion of profit from sale of
investment
License agreements provide that income from investments should be included in GR/AGR
for computation of revenue share. Audit noticed that Airtel, Reliance, Idea, Tata and Aircel
have not included income earned from investments in GR/AGR for computation of revenue
share. Audit worked out amount of non-inclusion of income from investments in GR/
AGR as ` 3111.45 crore resulting in short payment of LF and SUC by ` 271.70 crore and
` 93.20 crore respectively.
(Para 3.3.3, 5.3.4, 6.3.2, 7.3.2, 8.2.8)
(ix) Understatement of GR/AGR by Reliance Communications Limited (RCL)
through an arrangement with its subsidiary
RCL is a Unified Access Service (UAS) Licensee. Reliance Communications Infrastructure
Limited (RCIL) which had got Category “A” ISP license, was a wholly owned subsidiary
of RCL during 2006-07 to 2009-10. RCL and RCIL entered into agreements for providing
Value Added Services (VAS) to RCL’s subscribers and selling/marketing products of RCL
by RCIL. Consequent to the agreements between RCL and RCIL, revenue from VAS was
accounted in the books of RCIL and only a portion of the total revenue was passed on to
RCL. Also the revenue earned towards sale of handsets, SIM cards and installation charges
from subscribers which should have been accounted in RCL’s books of accounts was
booked in RCIL accounts. Thus revenue that should be the revenue of RCL as per UASL
agreement had been accounted in the books of RCIL. Consequently, RCL did not pay the
correct amount of the revenue share to the Government. Total understatement of GR/AGR
by RCL owing to its arrangement with its subsidiary (RCIL) comes out to be ` 4424.12
crore. Its impact on short payment of LF and SUC comes out to be ` 405.08 crore and
` 114.86 crore respectively.
(Para 5.2.2 B to 5.2.2 F)
(x) Understatement of GR/AGR due to non-inclusion of miscellaneous revenue and
profit on sale of fixed assets
License agreements provide that GR shall be inclusive of any other miscellaneous revenue,
without any set-off for related item of expense, etc. Audit noticed that five PSPs (Airtel,
Vodafone, Idea, Tata and Aircel) have included miscellaneous income/profit on sale of fixed
assets in GR/AGR for computation of revenue share in initial years. However, subsequently
they stopped including miscellaneous income/profit on sale of fixed assets in GR/AGR for
computation of revenue share. Audit worked out amount of non/short inclusion of such
income in GR/AGR as 640.76 crore resulting in short payment of LF and SUC by 54.99
crore and ` 20.44 crore respectively.
(Para 3.3.8, 3.3.9, 4.3.2, 6.3.3, 6.3.4, 7.3.3, 8.2.9, 8.2.10)
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(xi) Understatement of AGR by claiming ineligible deductions from GR
UASL agreements provide specific deduction that can be made from GR to arrive at AGR.
Accordingly, deduction of lease line charges and port charges is not permissible. However,
Airtel claimed deduction for lease line charges in 2006-07 and Tata claimed deduction
of lease line charges and port charges in the years 2006-07 to 2009-10. Amount of such
ineligible deductions claimed came out to be 669.76 crore having impact on short payment
of LF and SUC comes out to be ` 58.86 crore and ` 22.43 crore respectively.
(Para 3.4.2, 7.4.2)
(xii) Understatement of AGR by amount of bad debts written off claimed as deduction
Bad debts written off are not an eligible deduction to be claimed from GR to arrive at AGR.
However, PSPs (Airtel, Vodafone, Idea, Tata and Aircel) have claimed deduction of bad
debts written off from GR to arrive at AGR. Amount of such ineligible deduction comes
out to be `1068.80 crore having impact on short payment of LF and SUC of ` 101.10 crore
and ` 40.15 crore respectively.
(Para 3.4.1, 4.4, 6.4.1, 7.4.1, 8.3.1)
(xiii) Understatement of AGR for computation of SUC
In terms of UASL agreements, revenue from sale/lease of bandwidth should be considered
in AGR for computation of SUC. Audit noticed that Bharti, Reliance and Tata, providing
wireline services in addition to wireless services, have not included revenue from sale/lease
of bandwidth for computation of SUC though the same was included for computation of
LF. No such exclusion has been made for PSPs providing wireless services only. Amount
of revenue not included in AGR for computation of SUC comes out to be ` 3092.14 crore
having impact on short payment of SUC of ` 89.41 crore.
(Para 3.4.3, 5.4.1, 7.4.3)
(xiv) Inconsistency in verification of deductions claimed by PSPs by Controllers of
Communications Accounts
UASL agreements specify the deductions to be made from GR to arrive at AGR that
includes Public Switched Telecom Network (PSTN) related call charges (Access Charges)
actually paid to other eligible/entitled telecommunication service providers within India,
Roaming revenues actually passed on to other eligible/entitled telecommunication service
providers and Service Tax on provision of service and Sales Tax actually paid to the
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Government if GR had included as component of Sales Tax and Service Tax. Verification
of deductions claimed by PSPs was delegated to the CsCA from 2006-07 and on completion
of the verification exercise, the CsCA convey their findings through ‘verification reports’
to the LF Wing of DoT. DoT has issued several sets of instruction to CsCA for verification
of deductions.
Audit noticed that there was no uniformity amongst CsCA while making allowance/
disallowance of deduction claims submitted by the PSPs. During the course of audit of
records maintained by CsCA for verification of deduction claims, discrepancies on various
issues were noticed among CsCA and also within the same CsCA. It was noticed that
different yardsticks were adopted for different operators due to failure in co-ordination
within CsCA/absence of proper monitoring of CsCA by DoT. It was also noticed that in
some cases whole amount of deductions claimed have been disallowed by CsCA without
proper justification. In a multi operator scenario, payment of access charges to other
operators is a reality and disallowance of whole/substantial amount of deductions claimed
by CsCA without proper analysis is not justified. Also, DoT’s instruction on disallowing
roaming deductions paid to international operators is not justified.
(Para 9.3, 10.2.6)
(xv) Discrepancies in assessment of revenue share by DoT and non-existence of
appellate mechanism leading to high number of litigations
LF wing of DoT carries out assessment of license fee based on audited annual accounts,
audited AGR statements, reconciliation statements submitted by the PSPs and verification
reports received from CsCA. Audit noticed that certain items of revenue though disclosed
by Vodafone were overlooked by DoT while assessing the GR of the Company. It was
also noticed that certain items of revenue reported by Airtel were included in Delhi LSA
alone instead of apportioning it among other LSAs while raising demands for 2006-07 and
2007-08.
Assessment of SUC is carried out by Wireless Finance Division of DoT based on
Assessment of GR finalized by LF wing of DoT. However, audit noticed that there is
lack of coordination among these two wings of DoT. Though the communications revenue
collected by DoT contributes significantly to the total Non Tax revenue of GOI, there is no
mechanism for appeal in the DoT which has led to increasing number of litigations by the
PSPs. Consequently, demands raised by DoT remained unpaid for years together.
(Para 10.2.1, 10.2.2, 10.2.3, 10.2.7)
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5. Consolidated statement of non-realisation of revenue noticed by Audit
Short/non-payment of LF as per the licence agreements is given in the following table:-
Audit observationsNon-realisation of LF (` in crore)
Airtel Vodafone Reliance Idea Tata Aircel
Revenue netted off by the amount of commission/discount etc. paid to distributors/ dealers/ agents
89.79 119.59 138.39 59.93 57.08 22.31
Promotional Free Airtime given to subscribers not recognized as revenue for revenue share
90.27 18.45 * 57.62 591.82
26.12Revenue netted off by the amount of waivers/discount given to post paid subscribers
104.54 0.63 - 17.80 25.97
Roaming revenue netted off by discount given to other operators
15.62 23.07 - 2.72 - -
Infrastructure sharing revenue netted off
19.30 46.90 - 27.69 2.26 5.45
Non-inclusion of forex gain 17.46 14.19 107.63 4.45 29.52 1.23
Non/short inclusion of interest income
28.51 250.73 153.44 44.59 51.22 6.74
Non-inclusion of profit on sale of investment
42.45 - 7.30 33.36 187.69 0.90
Revenue booked in subsidiary’s accounts instead of its own books of accounts by RCL
- - 405.08 - - -
Non-inclusion of miscellaneous revenue and profit on sale of assets
8.85 19.45 - 2.24 14.52 9.93
Ineligible deduction on account of lease line/port charges claimed
28.03 - - - 30.83 -
Ineligible deduction on account of bad debts written off claimed
25.55 29.55 - 16.89 26.64 2.47
Other issues 249.09 - 313.56 22.70 1.61 0.65
Total 719.46 522.56 1125.40 289.99 1019.16 75.80
*Not captured in financial system, eliminated at mediation level itself.
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Short/non-payment of SUC as per the licence agreements is given in the following table:-
Audit observationsNon-realisation of SUC (` in crore)
Airtel Vodafone Reliance Idea Tata Aircel
Revenue netted off by the amount of commission/discount etc. paid to distributors/dealers/agents
45.40 53.30 47.95 29.74 17.35 9.64
Promotional Free Airtime given to subscribers not recognized as revenue for revenue share
44.29 9.27 * 25.82 180.19
11.72Revenue netted off by the amount of waivers/discount given to post paid subscribers
49.65 0.31 - 8.37 8.33
Roaming revenue netted off by discount given to other operators
7.22 10.23 - 1.21 - -
Infrastructure sharing revenue netted off
9.08 21.02 - 13.35 0.65 2.26
Non-inclusion of forex gain 6.74 6.12 26.93 2.00 9.09 0.31
Non/short inclusion of interest income
11.80 105.30 48.56 20.47 15.53 2.66
Non-inclusion of profit on sale of investment
17.45 - 3.94 14.49 56.95 0.37
Revenue booked in subsidiary’s accounts instead of its own books of accounts by RCL
- - 114.86 - - -
Non-inclusion of miscellaneous revenue and profit on sale of assets
2.57 8.72 - 1.01 4.48 3.66
Ineligible deduction on account of lease line/port charges claimed
12.63 - - - 9.80 -
Ineligible deduction on account of bad debts written off claimed
11.44 13.02 - 7.03 7.61 1.05
Revenue included in AGR for LF but not for SUC
20.70 - 40.66 - 28.05 -
Other issues 108.52 - 98.95 9.78 0.49 0.14
Total 347.49 227.29 381.85 133.27 338.52 31.81
* Not captured in financial system, eliminated at mediation level itself.
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Short/non-payment of LF, SUC and interest due thereon as on 31 March 2015 as per the
licence agreements is given in the following table:-
Bharti Airtel Vodafone Reliance Idea Tata Aircel Total
LF 719.46 522.56 1125.40 289.99 1019.16 75.80 3752.37
SUC 347.49 227.29 381.85 133.27 338.52 31.81 1460.23
Total (LF+SUC) 1066.95 749.85 1507.25 423.26 1357.68 107.61 5212.60
Interest 1584.94 915.54 2221.29 541.63 1857.71 155.22 7276.33
Total (LF + SUC+Interest)
2651.89 1665.39 3728.54 964.89 3215.39 262.83 12488.93
Thus, the verification of records of six PSPs by audit indicated total understatement of AGR
of ` 46045.75 crore for the period from 2006-07 to 2009-10. Government of India was
deprived of a total revenue of ` 12488.93 crore on account of short/non-payment of LF
(` 3752.37 crore), SUC (` 1460.23 crore) and interest (` 7276.33 crore) due from the six
PSPs for the years 2006-07 to 2009-10.
6. Summary of recommendations:
(i) It was noticed that verification of deduction claims at CsCA level was not done
uniformly and CsCA have taken different approach in allowing/disallowing deduction
claims submitted by the PSPs. During the course of audit of records maintained
by CsCA for verification of deduction claims, discrepancies on various issues were
noticed among CsCA and also within CsCA it was noticed that different yard stick
was adopted for different operators due to failure in co-ordination within CsCA/
absence of proper monitoring of CsCA by DoT. Hence it is recommended that
proper monitoring of CsCA by DoT is required for uniform/systematic verification
of deduction claims at CsCA level. DOT also needs to strengthen its internal audit
mechanism to ensure that verification of deductions by CsCA are checked regularly.
(ii) Though DoT had revised the rates of LF and SUC from time to time as detailed in
Chapter I, the definition of GR/AGR was not reviewed despite disputes/litigation. It
is recommended that the definition of GR/AGR be revisited considering the drastic
change in the scenario since 1999 when spectrum was allocated administratively
to the present era where spectrum is allocated through bidding process and where
the PSPs have to pay considerable amount as one - time payment at the time of
allocation of spectrum.
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(iii) To minimize the litigations on the demands raised by DoT, it is recommended that
an appellate mechanism should be instituted to address the dispute between DoT
and the PSPs on demands raised by DoT. The absence of an appellate/redress
mechanism within DoT to address disputes with operators also contributes to the
increasing number of litigations.
7. Response of DoT to the audit observations
Audit observations on the sharing of revenue by the six selected PSPs, after the verification
of the accounting records at their premises, along with findings on the process followed at
the various offices of CsCA for verification of proof documents submitted by the PSPs and
the final assessment done by DoT, were communicated to DoT during the period May 2015
to November 2015. Response of the Ministry on the audit observations on Airtel, Vodafone
and Reliance was received in January 2016.
DoT in its reply to audit observations on understatement of GR/AGR due to netting off
related expenditures from prepaid and post paid revenues, netting of roaming revenue
by inter-operator traffic discount paid to other operators, non inclusion of infrastructure
sharing revenue in full, non inclusion of revenue/income from Forex gain, interest, sale of
investment, miscellaneous revenue and profit on sale assets stated that, based on the report
of Special Audit conducted in 2009, demands were raised on the three PSPs in 2012 for
the years 2006-07 and 2007-08 . However, the demands were challenged by the PSPs in
TDSAT/High Courts and action would be taken as and when the final court judgment would
be pronounced. It was also stated that some of the licensees had filed (2012) writ petitions
before various High Courts challenging the Section-4 of Indian Telegraph Act, 1885, as
violative of the Art.14 and 19(1) (g) of the Constitution of India. In respect of observations
not reported in the Special Audit but brought out in this Report, it was stated that responses
of the PSPs on them were under examination.
The response of DoT agreed, in general with the audit findings that the PSPs were deviating
from the conditions of mutually agreed licence agreement, in reporting their GR. The
prolonged litigations at different Courts was given as the reason for the Department’s
inability to collect the correct revenue share as envisaged in the license agreement. It would
be pertinent to mention here that when the Government decided to reduce the licence fee for
all operators by two per cent effective from April 2004, DoT expected that the reduction
would prompt operators to withdraw the legal litigation against the Government. However,
the reduction in the rates of LF did not have the expected impact and the operators continue
to institute litigations against the Government challenging the definition of GR/AGR and
demand notes. Thus the PSPs got the benefit of reduction in rate of LF but the Government
did not get the reciprocal benefit of reduction in litigations and receipt of full revenue due
to it from PSPs.
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The response of DoT on the audit observations pertaining to Idea, Tata and Aircel was
awaited (January 2016).
In conclusion, audit found that even after 16 years of the introduction of the revenue share
regime, the correctness and completeness of revenue flowing into the Consolidated Fund of
India could not be assured by DoT.
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CHAPTER – IIntroduction
1.1. Genesis of revenue sharing regime in the Indian Telecom Sector
National Telecom Policy-1994 (NTP-94) introduced competition in the telecom sector as
private telecom service providers were permitted to set up communication networks. In the
first phase of NTP-94, eight licences for Cellular Mobile Telephone Service (CMTS) were
issued in the four Metro cities of Delhi, Mumbai, Kolkata and Chennai in November 1994.
Subsequently (during 1995 to 1998), 34 licences were issued for 18 telecom circles to 14
private companies. These licensees were selected through a bidding process and were to pay
to the Government a fixed amount as annual licence fee agreed during the bidding process.
1.2. New Telecom Policy-1999
Private sector participation in telecom sector did not take off as envisaged in NTP-94 as
the private telecom service providers complained of financial constraints and defaulted on
payment of the agreed licence fees. New Telecom Policy-1999 (NTP-99) introduced the
revenue share regime in which telecom service providers were required to pay a percentage
of their Adjusted Gross Revenue (AGR) as licence fee in place of the fixed licence fee.
The Government offered a migration package to existing licensee to migrate from fixed
licence fee regime to revenue sharing regime with effect from 1 August 19991 and 21
licensee companies2 migrated to the new regime (Annexure - 1.01). As per the migration
package, the licensees were to pay a one-time entry fee and licence fee (LF) at a percentage
of the AGR which was to be determined later on. Pending the finalisation of quantum of
revenue share and other terms and conditions, based on the recommendations of Telecom
Regulatory Authority of India (TRAI), the licence fee was initially fixed at 15 per cent of
the Gross Revenue (GR).
The country was divided into 233(presently 22) Licenced Service Areas (LSAs) categorised
into ‘A’, ‘B’ and ‘C’ LSAs as shown below:
Table 1.1Category of LSAs Names
A Delhi, Mumbai, Kolkata, Tamil Nadu (including Chennai), Andhra Pradesh, Gujarat, Karnataka, Maharashtra,
B Haryana, Kerala, Madhya Pradesh, Punjab, Rajasthan, Uttar Pradesh (E), Uttar Pradesh (W), West Bengal,
C Assam, Bihar, Himachal Pradesh, Jammu and Kashmir, North East, Odisha.
1 ThebenefitsextendedtotheprivateserviceprovidersthroughthemigrationpackagewasauditedbyCAGandfindingswerereportedinReportNo6of2000
2 20privatecompaniesandonePSU-MahanagarTelephoneNigamLimited3 Thecountrywasdividedinto23serviceareasconsistingof19telecomcirclesand4metrocircles.Subsequently,Chen-
naiserviceareawasmergedwithTamilNaduserviceareaw.e.f15September2005andhencethenumberofserviceareasis22atpresent.
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In 2001, the Government finalised the terms and conditions including the definition of GR
and AGR and fresh licences were issued. Further, the rate of licence fee was also reduced
from provisional rate of 15 per cent across all circles to 12 per cent, 10 per cent and 8 per
cent for Category A, B and C LSAs respectively.
In addition, the National Long Distance (NLD) services and International Long Distance
(ILD) services were also opened up for private sector from August 2000 and April 2002
respectively.
1.3. Unified Access Service Licence (UASL) and Unified Licences (UL)
Under NTP-94 and NTP-99, separate licences were issued for providing Basic and CMTS
services in a LSA. In 2001, “Basic Service Operators” (BSOs) in India were permitted to
offer “limited-mobility” services over Wireless in Local Loop (Mobile) (WLL(M)) using
Code Division Multiple Access (CDMA) technology in their coverage areas.
As the popularity of WLL (M) services offered by BSOs grew, a dispute emerged involving
the BSOs and Global System for Mobile communication (GSM) based CMTS operators. On
11 November 2003, the Government approved Unified Access Services Licensing (UASL)
regime mooted by the TRAI that called for a single licence for Basic and Cellular services.
A Unified Access Services licensee can provide wireline as well as wireless services in a
service area using any technology.
Existing BSOs and CMTS operators were given option (November 2003) to continue with
the existing licences or to migrate to UASL regime4. Henceforth only UAS Licences were
issued for access services. From August 2013 onwards, Unified Licences regime was
introduced under which a licensee could provide all telecom services (Access Services,
Carrier Service and Data Services).
1.4. Provisions in the Licence agreements on definition of Gross Revenue (GR)/
Adjusted Gross Revenue (AGR)
Prior to introduction of Unified licences, separate licences were issued for different telecom
services viz. Unified Access Services (UAS), National Long Distance (NLD) services,
International Long Distance (ILD) services, Very Small Aperture Terminal (VSAT) services
and Internet Services. Definition of Gross Revenue (GR), Deductions and Adjusted Gross
Revenue (AGR) as provided in related licences are as follows:-
a) GR and permissible deductions to arrive at AGR were defined under clause 19
of the UASL Agreement. In terms of clause 19.1, the GR shall be inclusive of
installation charges, late fees, sale proceeds of handsets (or any other terminal
equipment etc.), revenue on account of interest, dividend, value added services,
4 AlltheCMTSlicenseesdidnotmigratetoUASLregime.Further,theconditionsforrevenuesharingwereidenticalforbothUASLandCMTSlicences.
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supplementary services, access or interconnection charges, roaming charges, revenue
from permissible sharing of infrastructure and any other miscellaneous revenue,
without any set-off for related item of expense, etc.
Further, to arrive at AGR, following shall be excluded from the GR as mentioned
in clause 19.2 of the agreement-
i) PSTN5 related call charges (Access Charges) actually paid to other eligible /
entitled telecommunication service providers within India;
ii) Roaming revenues actually passed on to other eligible/entitled
telecommunication service providers, and
iii) Service Tax on provision of service and Sales Tax actually paid to the
Government, if GR had included Sales Tax and Service Tax.
b) The GR/AGR for NLD services was defined under clause 31 of Annexure-II of the
NLD Agreement which provides that “Revenue for the purpose of levying Licence
Fee as a percentage of revenue shall mean the Gross total revenue income accruing to
the licensee by way of providing NLD service under the licence including the revenue
on account of supplementary/value added services and leasing of infrastructure,
interest, dividend, etc. as reduced by the component part of a pass through nature
payable to other service providers to whose network licensee’s NLD network is
interconnected for carriage of calls”.
c) The GR/AGR for ILD services was defined under clause 36 of definition and
interpretation forming part of ILD Agreement which provides that “Gross Revenue
shall include all revenue accruing to the licensee on account of goods supplied,
services provided, leasing of infrastructure, use of its resources by others, application
fee, installation charges, call charges, late fees, sale proceeds of instruments (or any
terminal equipment including accessories), handsets, bandwidth, income from value
added service, supplementary services, access or interconnection charges, any lease
or rent charges for hiring of infrastructure etc, and any other miscellaneous items
including interest, dividend, etc. without any set-off for related item of expense,
etc”.
AGR for the purpose of levying LF as a percentage of revenue shall mean the GR
as reduced by:
i) Call charges (Access charges) actually paid to other telecom service providers for carriage of calls.
ii) Service tax for provision of service and sales tax actually paid to the Government, if Gross Revenue had included the component of service tax and sales tax.
5 PublicSwitchedTelephoneNetwork
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d) Definition of GR for Internet Services including Internet Telephony (ISP-IT) as per licence agreement provides that “GR shall be inclusive of Internet Access service, Internet Content service, Internet Telephony service, installation charges, late fees, sale proceeds of terminal equipment, revenue on account of interest, dividend, value added services, supplementary services, revenue from permissible sharing of infrastructure and any other miscellaneous revenue, without any set-off for related item of expense, etc”.
For the purpose of arriving AGR, the following shall be excluded from the GR-
i) Charges from Internet access, Internet content and Internet access related installation charges.
ii) Service tax for provision of service and sales tax actually paid to the Government, if GR had included the component of service tax and sales tax.
e) In terms of the definition of GR specified in the VSAT Licence agreement, “The Gross Revenue shall include all revenues accruing to the LICENSEE on account of goods supplied, services provided, leasing/hiring of infrastructure, use of its resources by others, application fees, installation charges, call charges, late fees, sale proceeds of instruments (or any terminal equipment including accessories), VSAT hardware/software, fees on account of Annual Maintenance Contract/Annual Comprehensive Maintenance Contract, income from value added services, supplementary services, access or interconnection charges, etc. and any other miscellaneous item including interest, dividend, etc. without any set-off of related item of expense, etc.”
Revenue for the purpose of levying licence fee as a percentage of revenue shall include the gross total revenue accruing to the licensee by way of providing VSAT service under this licence but excluding:-
i) Charges of pass through nature actually paid to other Telecom service provider to whose network, the licensee’s network is interconnected for carriage of data.
ii) Service tax paid to the Government, if gross revenue had included the
component of service tax.
1.5. Stipulations in UASL Agreements on reporting revenue and payment of LF
The licence agreement between Department of Telecommunications (DoT) and the service providers contained distinct and specific clauses/norms for the preparation of the accounts of the licensee companies, their reporting and payment of licence fee to the Government. These clauses/norms underlined that while it was the prerogative of the licensee company to prepare their accounts complying with the provisions of the Companies Act, Accounting Standards etc., the provisions of licence agreement would be central for the purpose of computing the LF payable to Government. Appendix – II to Annexure – II of UAS Licence agreement prescribed the format of Statement of Revenue and Licence Fee while Annexure – III
Report No. 4 of 2016
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specified the norms for preparation of the Statement. The licence agreement also stipulated that reconciliation between the figures appearing in the quarterly statements with those appearing in annual accounts to be submitted along with a copy of the published annual accounts, audit report and duly audited quarterly statements. The licence conditions also envisaged that the Statement of Revenue and LF, also referred as AGR statements of the licensee, should disclose all the adjustments made in recording the revenues offered for revenue share.
Important clauses in the agreements in this regard are shown in the below tables:
Table 1.2
Preparation of accountsStipulations Clause
While calculating AGR for limited purpose of levying Spectrum Usage Charges based on revenue share, revenue from Wireline Subscribers shall not be taken into account.
18.3
Computation of revenue and Licence fee payable should be shown in a prescribed Statement (AGR Statement) and should be audited by the Auditors of the Licensee appointed under Section 224 of the Companies Act, 1956.
20.4
Final adjustment of the Licence fee for the year shall be made based on the GR figures duly certified by the Auditors in accordance with the provisions of the Companies Act, 1956.
20.6
A reconciliation between the figures appearing in the quarterly statements with those appearing in annual accounts to be submitted along with a copy of the published annual accounts, audit report and duly audited quarterly statements.
20.7
• Service revenue (amount billable) should be shown gross and details of discount/rebate indicated separately.
• ServiceTaxandSalesTaxbilled,collectedandremittedtotheGovernmentshallbe shown separately.
• Sales to be shown gross and details of discount/rebate allowed and of salesreturns be shown separately.
• Incomefrominterestanddividendtobeshownseparatelywithoutanyrelatedexpenses being set-off against them.
• Item-wise details of income that has been set-off against correspondingexpenditure.
• Roaming charges should indicate operator-wise receivables and payables,roaming commission received and paid and any other variable charges collected/passed on to other operators.
Annexure-III of UASL agreement (Norms for preparation of annual financial statements)
Accounts should be maintained separately for each telecom service operated by the licensee company.
22.1
The licensor may, on forming an opinion that the statements or accounts submitted are inaccurate or misleading, order audit of the accounts of the licensee by appointing auditor at the cost of the licensee and such auditor(s) shall have the same powers which the statutory auditors of the company enjoy under Section 227 of the Companies Act, 1956. The licensor may also get conducted a ‘Special Audit’ of the licensee company’s accounts/records.
22.5 and 22.6
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Table 1.3
Payment of licence fee
Stipulations ClauseLF shall be payable in four quarterly instalments during each financial year. This fee
shall be paid on the basis of actual revenue (on accrual basis).
20.2
Any difference between the payment made and actual amount duly payable (on
accrual basis) for the last quarter of financial year should be adjusted and difference
paid within 15 days of the end of the quarter.
20.3
Any delay in payment of LF payable beyond the stipulated period will attract interest
at a rate which will be two per cent above the Prime Lending Rate (PLR) of State
Bank of India existing as on the beginning of the Financial Year.
The interest would be compounded monthly and a part of the month would be
reckoned as a full month for the purposes of calculation of interest. A month shall be
reckoned as an English calendar month.
20.5
The Fee/royalty payable towards Wireless Planning and Co-ordination (WPC)
Charges (SUC etc.) should be payable at such time(s) and in such manner as the
WPC Wing of the DoT may prescribe from time to time.
20.9
1.6. Rates of licence fee
The rate of licence fee prevailing during the period from 2006-07 to 2009-10 for various
kinds of services is detailed below:
Table 1.4
Access Services NLD ILD VSAT ISP -IT ISPService Area
Cat A Cat B Cat C (in per cent) (in ` per annum)
10 8 6 6 6 6 6 1
Note: The rates of LF for Access Services are inclusive of Universal Service Obligation (USO) levy of five per cent across the LSAs. Further, with effect from 01 April 2004, the first two cellular operators were granted rebate of two per cent in LF for four years in telecom circles subject to minimum rate of LF being equivalent to USO levy i.e. five per cent.
However, no licence was required for Infrastructure Provider Category I (IP I) services and
only registration with the DoT was sufficient.
1.7. Allocation of Spectrum and Spectrum Usage Charges
Initially, with the grant of UASL/CMTS Licence start up spectrum of 2x4.4 MHz to GSM
operators and 2x2.5 MHz to CDMA operators was to be allotted by the DoT. Additional
allotment of spectrum beyond this start up spectrum was linked to subscriber base. This
process of allotment was termed as administrative allocation and continued till 2010.
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In addition to the LF, licensees offering mobile (wireless) services are required to pay
Spectrum Usage Charges (SUC) to the DoT. The rates of SUC payable are linked to the
type and quantity of Spectrum allotted. Rates in force upto 31 March 2010 were as shown
below:
Table 1.5
SUC as percentage of AGR (excluding Revenue from Wireline Subscriber)
GSM services CDMA services
From 1 August 1999 to 31 March 2010 From 25 January 2001 to 31 March 2010
Spectrum Rate (in per cent) Spectrum Rate (in per cent)
2x4.4 MHz 2 2x5.0 MHz 2
2x6.2 MHz 3 2x6.25 MHz 3
2x10.0 MHz 4 2x10.0 MHz 4
In addition to above main spectrum, Microwave Access and Microwave Backbone spectrum6
was also allotted to Cellular operators. Rate of SUC for Microwave Access and Microwave
Backbone spectrum were revised with effect from 3 November 2006, but the same was
challenged by GSM operators whereas it was accepted by CDMA operators and the matter
was sub-judice.
1.8. Revenue share collected by DoT
Year wise details of revenue share collected by DoT from 2002-03 to 2009-10 are given
below:
(Source: DoT Annual Reports)
6 Microwavetransmissionreferstothetechnologyoftransmittinginformationusingradiowaves.Microwavetechnologyiswidelydeployedinmobilecommunicationstoprovidepoint-to-point(PTP)RadioFrequency(R.F.)linksinmobilebackhaulaswellasinthebackbonenetwork.Mobilebackhaulisthatportionofthenetworkinfrastructurethatprovidesinterconnectivitybetweentheaccessandcorenetworks.Thebackbonenetworkisusedtointerconnectdifferentnodessituatedatdifferentgeographicallocations.
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1.9. Arrangements in DoT for collection and accounting of licence fee and SUC
The process of revenue share realization from telecom service providers involves the
following important activities:
• Collection of licence fee and spectrum charges - deposit at Controllers of
Communication Accounts (CsCA) office.
• Verificationofproofdocumentssubmittedbytelecomserviceprovidersforclaiming
deductions from Gross Revenue by the CsCA.
• AssessmentofRevenueShare(RS)andissueofdemandnotesbyDoTbasedonthe
annual audited accounts of the operator and the verification reports submitted by
CsCA.
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CHAPTER - IIAudit Approach
2.1 Scope of Audit
Revenue share payment is linked to the GR earned by service providers. The correctness
and completeness of the revenue share paid to Government entails that the computation of
GR/AGR by the operator was as per the licence conditions and the systems put in place by
DoT was conducive for verifying/assessing the correctness of the same.
Comptroller and Auditor General of India took up verification of the basic accounting
records and documents of six telecom service providers in 2014-15 covering the accounts
of four years from 2006-07 to 2009-10 as mandated under Section 16 of the Comptroller
and Auditor General’s (Duties, Powers and Conditions of Service) Act, 1971 and Rule 5
(ii) of Telecom Regulatory Authority of India, Service Providers (Maintenance of Books
of Accounts and other Documents) Rules, 2002 as upheld by Hon’ble Supreme Court of
India’s Judgement dated 17 April 2014. The service providers selected were:
• M/sBhartiAirtelLimitedanditssubsidiaryBhartiHexacomLimited
• M/sVodafoneIndiaLimitedanditssubsidiaries
• M/sRelianceCommunicationsLimited and its subsidiaryM/sRelianceTelecom
Limited
• M/sIdeaCellularLimitedanditssubsidiaryAdityaBirlaTelecomLimited
• M/sTataTeleServicesLimitedanditsassociatedcompanyM/sTataTeleservices
(Maharashtra) Limited
• M/sAircelLimitedanditssubsidiariesAircelCellularLimitedandDishnetWireless
Limited
The primary consideration in selecting the above mentioned six operators for this phase of
audit was the fact that they were the early entrants into the telecom business after the sector
was opened up for private participation. Again, these operators are the dominant players
in the market and account for a significant share of the total licence fee receipts of the
Government. Market shares of these Companies as of March 2007 and March 2010 were
as shown below:
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March 2007 March 2010
(Sourtce: TRAI/COAI)
Further, audit of M/s Bharti Airtel Limited and M/s Bharti Hexacom Limited (BAL/BHL)
was taken up first while commencing the audit of telecom revenue paid by private service
providers considering their highest market share/revenue share. While preparing the report,
audit view on the common issues identified has been deliberated in detail in the Chapter –III
on BAL/BHL. To avoid repetition of the audit’s view in the other chapters, reference has
been made to the detailed view of the audit given in Chapter-III.
The scope of audit also included examination of the process of verification of deduction to
arrive at AGR, collection of Revenue Share (LF and SUC) and assessment of GR done by
DoT.
2.2 Audit methodology
A) Prior to the commencement of audit, meetings were held with all the service
providers separately wherein the scope and coverage of audit were explained. Company
representatives explained to Audit their revenue recognition policies, system of recording
revenue and preparation of AGR statements.
Audit at premises of these Private Telecom service providers was basically an IT system
based audit. Access to General Ledger (GL) Enquiry Module of their financial system
(Oracle Financial or SAP) was provided to audit. Audit scrutinized the account codes which
had a bearing on the Gross Revenue on test check basis and the deductions for revenue share
purpose in terms of the licence agreement to identify the issue for detailed examination. The
licensee also provided reconciliations between AGR statements and Service Revenue, Other
income and Finance income of Profit and Loss Accounts duly mapped with Trial Balances
(TBs). Additional data, information and clarifications, if required, were obtained through
issue of Audit queries and discussion with the respective operators.
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B) The corporate income has been apportioned among the licences on the basis of
percentage of GR as corporate income pertains to all service areas at the rates applicable
to UAS Licence. LF and SUC has been calculated on the basis of rates applicable for
respective services.
Audit considers this to be the most suitable and conservative method of determining the
under reporting of revenue share.
In terms of clause 20.2 and 20.5 of Licence conditions, calculation of interest on unpaid
amount of LF and SUC is due from next quarter. However, audit has calculated unpaid
dues from beginning of next financial year and therefore; interest figures indicated in this
report are lower than actual interest due as per licence conditions.
2.3 Audit criteria
Important criteria used in audit are:
Provisions of Licence agreements as amended from time to time
Various instructions issued by DoT on collection of licence fee and spectrum
usage charges
2.4 Acknowledgement
We place our sincere appreciation for the cooperation extended by the Management of all
the six telecom service providers and the Department of Telecommunications in facilitating
this audit.
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CHAPTER – IIIRevenue shared by M/s Bharti Airtel Limited and
M/s Bharti Hexacom Limited
3.1 Brief Profile of M/s Bharti Airtel Limited and M/s Bharti Hexacom Limited
Bharti Airtel Limited (BAL), formerly known as Bharti Televenture Limited (BTVL), was
one of the first private telecom companies who was awarded licences for providing cellular
services in November 1994 (licence was issued to the then entity named as “Bharti Cellular
Limited). BAL had only two CMTS licences till January 2000. By the year 2004 the
company was having a pan India presence with licences in all 23 LSAs. BAL was the first
Indian Telecom service provider (TSP) to obtain the Pan India CMTS/UAS licence. The
turnover of the company also grew continuously. BAL maintained its leadership position in
Indian private telecom sector.
3.1.1 Licences granted to M/s Bharti Airtel Limited and M/s Bharti Hexacom Limited
BAL was awarded licences for providing cellular services in metro Licenced Service Area
(LSA) of Delhi in November 19941 and later on for Himachal Pradesh LSA in December
1995.
BAL further acquired CMTS licences as detailed below:
Table 3.1
Period Details of licences acquired
1999-2002 CMTS licences in five service areas by acquiring three companies2
2001 CMTS licences in eight3 service areas
2004 UASL licences in six4 service areas
M/s Bharti Hexcom Limited (BHL), a subsidiary of BAL, acquired CMTS licences in
North East and Rajasthan service areas in 2004. Hence, by the year 2004, BAL/BHL was
having a pan India presence with licences in all 23 LSAs.234
1 Licencewasissuedtothethenentitynamedas“BhartiCellularLimited”2 JTMobile(Punjab,AP,Karnataka),Skycell(Chennai)andSpiceCell(Kolkata)3 UP(W),,Maharashtra,Haryana,Gujarat,Kerala,Mumbai,MPandTamilNadu4 Orissa,J&K,Bihar,UP(E),WestBengalandAssam
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The details of other licences held by BAL and its subsidiaries are as on 1 April 2006 as
given in Table below:
Table 3.2
Sl No Services Remark
1 NLD Original licence issued to Bharti Telesonic Limited (BTSOL) which merged with BAL.
2 ILD Original licence issued to Bharti Telesonic Limited (BTSOL) which merged with BAL.
3 ISP-IT Original licence issued to Bharti BT Internet Limited which merged with BAL. 4 VSAT Original licence issued to M/s Wipro Infotech Limited which merged with
BAL.5 ISP Original licence issued to Comsat Max which was taken over by Bharti
Broadband Limited (BBL). BBL was merged with BAL.Original licence issued to M/s Bharti Acquanet Limited (BAqL)which merged with BAL.
6 VSAT Original licence issued to Comsat Max which was taken over by Bharti Broadband Limited (BBL). BBL merged with BAL.
7 IP I Originally registered with Bharti Telesonic Limited (BTSOL) which merged with BAL.Originally registered with Bharti Telenet Limited which merged with BAL.Registered with M/s Bharti Infratel Limited, a subsidiary of BAL.
3.1.2 Spectrum allotted to BAL/BHL
BAL/BHL are Global System for Mobile communication (GSM) operators. Initial start-up
spectrum for subscriber access (Main Radio Spectrum) to a GSM operator was 2x4.4 MHz.
LSA wise spectrum allotted to BAL/BHL as on 31 March 2010 were as follows-
Table 3.3
LSA wise spectrum allotted
Sl.No. Spectrum Licenced Service Area
1 2×10 MHz Andhra Pradesh, Delhi, Karnataka
2 2×9.2 MHz Bihar, Mumbai, Tamil Nadu (including Chennai)
3 2×8.2 MHz Maharashtra, Rajasthan
4 2×8.0 MHz Kolkata, Orissa
5 2×7.8 MHz Punjab
6 2×7.2 MHz UP East
7 2×6.2 MHz Assam, Gujarat, Haryana, Himachal Pradesh, Jammu and Kashmir, Kerala, Madhya Pradesh, North East, UP West, West Bengal
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3.1.3 Subscriber base of BAL/BHL
The cellular subscribers of BAL and BHL grew from 3.71 crore as on 31 March 2007 to
12.76 crore as on 31 March 2010 registering a growth of 244 per cent. Wireline subscribers
increased from 0.19 crore as on 31March 2007 to 0.31 crore as on 31 March 2010. Bharti
group remained on top of all the cellular operators during the years 2006-07 to 2009-10 and
its market share was around 21 per cent as on 31 March 2010.
3.1.4 Gross Revenue, Deduction, Adjusted Gross Revenue reported and revenue
share paid by BAL/BHL
As brought out in Para 1.5, Telecom Service Providers are required to pay LF and SUC
at a percentage of AGR on quarterly basis on self-assessment basis. GR, Deductions, AGR
reported and revenue shared (LF and SUC) by BAL/BHL during these years are as follows:
Table 3.4
(` in crore)
Year GR Deductions AGRPercentage of AGR to GR
Revenue share
(LF+SUC)
2006-07 20133 5452 14681 72.92 1687
2007-08 29222 7139 22084 75.57 2516
2008-09 40997 11082 29915 72.97 3689
2009-10 43649 11357 32292 73.98 3889
Total 134001 35030 98972 73.86 11781
3.2 Under reporting of revenue by BAL/BHL
As mentioned in para 1.4 (a),the GR shall be inclusive of all types of revenue stated therein
without any set-off for related item of expense, etc. and as brought out in Para 1.5, service
revenue (amount billable) shall be shown gross and details of discount/rebate indicated
separately.
Audit examination of records/Books of accounts (Vouchers, General Ledger, Trial Balance,
Profit and Loss Accounts, Balance Sheet, etc.) of BAL/BHL revealed that these companies
had not adhered to the provisions of the Licence Agreement as brought out in the succeeding
paras:
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3.2.1 Under reporting of revenue due to netting off of revenue pertaining to
Commission/offers/discounts to dealers/subscribers for prepaid services
From the examination of data/records pertaining to prepaid services furnished by BAL/BHL
for the period from 2006-07 to 2009-10, it was observed that –
The margin/commission given to distributors/agents was netted off from revenue
pertaining to prepaid services.
Offers to the subscribers viz. Free Air Time (FAT) to customers, Free of Cost
(FOC) Coupons/Cards/SIMs to customers, Promotional offers to customers, Full
talk time offered to customers, Adjustments offered to customers, etc, were set-off
from the revenue pertaining to prepaid services.
The item wise details are furnished below-
A) Margin/Commission:
The licensee company appoints distributors/franchises/dealers for selling telecom services
on commission basis. The company supplies to the distributors/franchises/agents the
prepaid recharge coupons/e-top up for sale to subscribers and pays commission/margin to
them. During review of data/records offered by BAL/BHL for the period from 2006-07 to
2009-10, it was observed that the Primary commission/margin paid to the distributors/
franchises/dealers at the time of sale of prepaid recharge coupons/e-top up were deducted
from the revenue. This resulted in revenue getting set-off of commission/margin in the books
and as a result, Net Revenue was considered in AGR statements submitted to DoT. It was
also noticed that Post sale Commission/Incentive paid to the distributors/franchises/dealers
were booked in expenditure head under description “Sales Commission and Incentives”.
Total amount deducted from revenue on account of commission/margin to the distributors/
franchises/agents/dealers during 2006-07 to 2009-10 was ` 1070.78 crore.
Since, the commission/margin paid to the distributors/franchises/dealers is in the nature of
business expenses (marketing expenses), therefore, set-off of such expenses with revenue
was against the licence condition.
On being pointed out by audit, it was stated by Management that-
• TherelationshipbetweenthecompanyanddistributorswasonaPrincipaltoPrincipal
basis and accordingly the company was required to account for the transactions with
such distributors as such on the amount realized from the distributors.
• Further,TDSATinits judgmentdated23April2015heldthat“Inourviewthe
definition of “gross revenue” cannot be construed as to bar the licensee from fixing
a wholesale price for the service which is lower than its MRP. The test is how the
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actual transaction takes place. If the sale and invoicing is on MRP and any discount
is given separately, then in terms of clause 19.1, such discount is not deductible even
if the revenue booked in the Profit and Loss account is after netting off the discount.
On the other hand, if the sale is on a stated/agreed price, invoiced at that agreed
price and booked under the revenue in the Profit and Loss account accordingly
without netting off any discount, the actual selling price would be the revenue and
the difference between the MRP and this selling price cannot be added to “gross
revenue”.
• OutofCommission/Marginaspointedoutbyaudit,` 8.78 crore was knocked with
the corresponding credit/contra entry.
Audit’s view on the management reply is as follows-
Total amount deducted from revenue on account of commission/margin has been revised to
` 1062.00 crore (Annexure - 3.01) on the basis of the Management’s reply. Resultantly,
LF and SUC amounting to ` 89.79 crore and ` 45.40 crore respectively were not paid on
the said revenue by the Company (Annexure - 3.01).
Regarding other issues, reply of the management is not tenable as -
• BALisrenderingtheservicesultimatelyandhadBALsoldthecardsdirectlytothe
customers, revenue would have been accounted for full value of service rendered and
selling expenses would have been accounted as expenditure. On the same analogy,
discount/commission accorded to distributors would be in the nature of Marketing
Expenditure and thus, should not be deducted from Revenue. This is in accordance
with stipulation in clause 19.1. Further, Audit opines that this transaction is not
covered under Principal to Principal since the ultimate responsibility of rendering
the service to the customer rests with BAL/BHL and not with the distributors.
• While the matter is sub-judice at Hon’ble Supreme Court, Audit view is that
commission/margin paid to the distributors/franchises/dealers is in the nature of
marketing expenses, therefore, set-off of such expenses with revenue was against the
licence condition.
B) Offers/Discount/Rebates to customers/dealers: -
• FreeAirtime (FAT): Subscriber account is credited on major festivals/occasions
with extra talk time by the Company without any charge. The extra talk time so
credited was referred to as Free Air Time (FAT).
• FreeofCost(FOC)Coupons/Cards/SIMstocustomers/dealers:Similarly, free
of cost coupons/cards/SIMs were given to customers/dealers on major festivals/
occasions.
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• Promotionalofferstocustomers:Subscriber account was credited with additional/
extra talk time by the Company without any charge as promotional offers.
• Fulltalktime(FTT)offeredtocustomers:Subscriber account was credited with
full talk time by the Company as part of promotions.
• Adjustments offered to customers (Negative processing fee/Initial talk-time/
Upsize or upfront hit on talk-time/various adjustments): Subscriber account was
credited with talk time by the Company more than the face value of the RCs/
e-recharge or sometimes adjustments were made to facilitate the subscribers/dealers
to gain talk-time as part of promotions.
During review of data/records furnished by BAL/BHL for the period from 2006-07 to
2009-10, it was observed that the cost of above offers provided to the subscribers was
deducted from prepaid services revenue upfront and as and when the same was used by
subscriber, the revenue was credited by the said amount. Resultantly, the Revenue on
account of these offers to subscribers were not recognised in the GR/AGR. It was also
observed that FOC/Promotional offer/Upsize etc. were also booked in the expenditure
heads.
Since offers to customers (FAT/FTT/FOC/Extra talk time, etc.) were part of overall
commercial strategy to enhance business, the cost of such offers/discounts/rebate were in
the nature of expenses. Further, as per licence agreement, service revenue should be shown
in gross without any set-off. Thus, the action of the Management in setting off the cost
of offers/discounts/rebate from revenue was against the licence agreement and resulted in
short payment of LF and SUC as detailed below:
Table 3.5
(` in crore)
Offers/Discount/Rebates to customers
Under reporting of GR
LF Impact
SUC Impact
Remarks
Free Airtime (FAT) 598.57 54.71 26.97 Annexure – 3.02
Free of Cost (FOC) Coupons/Cards/SIMs
40.62 3.61 1.58 Annexure – 3.03
Promotional offers to customers
74.76 5.88 2.88 Annexure – 3.04
Full Talk Time (FTT) 10.63 1.35 0.63 Annexure – 3.05
Negative processing fee/ Upsize /various adjustments
282.65 24.72 12.23 Annexure – 3.06
Total 1007.23 90.27 44.29
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On being pointed out by audit, it was stated by Management that:-
• Thecompanyoffersadditionaltalktimetoitscustomersbasedonmarketdemand/
Management decision as an additional benefit over and above the normal talk time
based on various schemes run by company from time to time. Such additional talk
time is known as Free Air time. FAT is provided on Start up Kit (SUK), Recharge
Coupon (RC) or by way of Initial credit to prepaid customer. It is generally given
during festival season to popularize new rate plans, to attract new subscribers, etc.
Similarly, the amount of negative processing fee (which arises due to FAT) is in fact
discount offered to the customer.
• FATisinthenatureofPlannedDiscountandpartofTariffplanfiledwithTRAI.
It is given upfront to customers and such notional amount cannot be subject to LF.
• IntermsofAS-9,“Revenueisthegrossinflowofcash,receivableorconsideration
arising in the course of the ordinary activities of the enterprise from the sale of
goods, from the rendering of services, and …..”
• OutofFAT/FTT/FOC,etc,aspointedoutbyAudit,` 48.49 crore was knocked
with the corresponding credit/contra/duplicate entry.
Audit views on the reply of the Management are as given below:-
• Contraentriesamountingto` 48.38 crore (out of ` 48.49 crore as stated by the
management in its reply) in respect of initially commented FAT/FTT/FOC, etc. of
` 1055.60 crore have been considered and the figures have been accordingly revised
to ` 1007.23 crore. Amount of ` 0.11 crore (` 48.49 crore - ` 48.38 crore ) of
management reply was not considered by audit, as this entry were not included in
initially commented FAT/FTT/FOC, etc, of ` 1055.60 crore.
• TheManagementhasacceptedthatAdditionalTalkTime/FreeAirTimeetc.was
generally given during festival season to popularize new rate plans, to attract new
subscribers, etc. Therefore, such offers/discounts/rebate was in the nature of expenses
and hence, in terms of licence agreements should not be deducted from GR.
• ThecopyoftheprepaidtariffplanssubmittedtoTRAI(providedtoaudit),didnot
include any kind of FAT/discount etc. whether billable or otherwise.
• AuditisnotquestioningtheaccountinginaccordancewithAS-9butcontendsthat
Airtime is not a free commodity, had an intrinsic value and by giving FAT/FTT/
FOC etc, the licensees are foregoing the revenue instead of booking these as expenses
resulting in avoidance of LF and SUC.
Thus, netting off of offers/discount/rebate amounting to ` 1007.23 crore given to pre-paid
subscribers has resulted in understatement of GR/AGR, which ultimately resulted in short
payment of LF and SUC to DoT amounting to 90.27 crore and 44.29 crore respectively.
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C) Short accounting of revenue due to upfront debit in the revenue heads
As per the procedure followed by the company for accounting of revenue, while the revenue
received in advance was accounted under liability, the Margin/Commission paid/FAT/FOC
on this amount was debited to the current revenue. Due to this, the current revenue was
short accounted to the extent of Margin/Commission paid/FAT/FOC resulting in deferment
of LF and SUC on this amount.
On being pointed out by audit, the Management replied that these were already covered
under reply to set-off/upfront charges para {para 3.2.1(A) and (B)}. However, from the
accounting perspective, the revenue is being recognized on the basis of actual usage.
Audit is not questioning the accounting on the basis of actual usage. However, the fact
remains that the upfront debit of Margin/Commission paid/FAT/FOC of revenue received
in advance to the current revenue results in short payment of LF and SUC on the current
revenue to the extent of amount debited.
3.2.2 Under reporting of revenue due to netting off of discounts/waivers granted to
post-paid subscribers
From the examination of data/records pertaining to post-paid services furnished by BAL/
BHL for the period from 2006-07 to 2009-10, it was observed that –
Waivers (Installation Charges Waiver/Air Time Waiver/Other Fees and Charges
Waiver/Rental Waiver/VAS Revenue Waiver) and Rental/Airtime/other discounts
were offered to post-paid customers by the company. It was also noticed that the
company debited the cost of discounts and waivers to Post-paid revenue heads
instead of expense heads as a result of which the revenue considered for AGR was
understated by ` 180.74 crore and ` 842.12 crore respectively (Annexures- 3.07
and 3.08).
During reconciliation of revenue shown in AGR statements vis-a-vis Financial
Statements of the company (TB/reconciliation statement given to audit), it was
further observed that ` 112.93 crore was deducted from GR ab-initio to arrive at
AGR on account of waivers. Detailed analysis revealed that these amounts were
booked under expenditure heads pertaining to ‘Waivers on account of goodwill
gesture’, Customer care expenditure, etc. (Annexure - 3.09).
Further, Rental/Airtime/other discounts and Waivers were part of overall commercial
strategy to enhance business and therefore, such offers/discounts were in the nature
of expenses. Hence, in terms of licence agreements, these should not be deducted
from GR.
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On being pointed out by audit, it was replied that:-
• Servicerevenuewasrecognizedastheserviceswererenderedandstatednetoffof
billable discounts, process waivers and taxes. As per Annexure-III of the licence
agreement under the Norms of preparation of annual financial statements, accrued
revenue shall include “all amounts billable for the period”, thereby all such amounts
(billable discounts, process waivers, etc.) shall be excluded from the revenue while
computing the GR.
• Processwaiverwerebeinggranteddue toerrors inbillingandwerenotbillable
under the category of accrued revenue as per Annexure-III of the licence agreement,
as the services have not been rendered or incorrectly billed. The process waiver
(` 842.12 crore) included billable discount of ` 624.44 crore, hence the actual
process waiver was ` 217.67 crore.
• Goodwillwaiverswereinthenatureofdiscountsofferedforcustomerretentionand
maintaining relationship. Although they form part of service revenue, the company
has reduced the amount of such waivers in the nature of goodwill waivers from the
GR.
• BillablediscountarepartoftarifffilingwithTRAI,hencenotpartofrevenuefor
the purpose of AGR as per the licence agreement.
• OutofBillablediscountof` 206.55 crore as pointed out by audit, ` 25.81 crore was
knocked with the corresponding credit/contra entry.
Audit views on the reply of the Management are as given below:
• Contraentriesamountingto` 25.81 crore in respect of initially commented discount
of ` 206.55 crore, as stated by the Management in its reply have been considered
and the figure revised to ` 180.74 crore.
• NormsofpreparationofannualfinancialstatementsundertheLicenceagreement
states that Service revenue (amount billable) shall be shown gross and details of
discount/rebate indicated separately. This indicates that service revenue should be
shown in gross, however the Management netted off the discounts/rebate while
preparing the annual financial statements which was against the licence agreement.
Further, Annexure-III of the licence agreement did not indicate that discounts,
waivers, etc. shall be excluded from the revenue while computing the GR.
• Thecontentionof theManagement thatwaiver(` 842.12 crore) included billable
discount of ` 624.44 crore was not in line with the Trial Balance (TB) submitted to
audit and data extracted from Oracle Finance system as analysis of head of accounts
of TB as well as the data extracted from general ledgers pertaining to these waivers
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clearly indicated that these were Installation Charges Waiver/Air Time Waiver/
Other Fees and Charges Waiver/Rental Waiver/VAS Revenue waivers. It was not
mentioned that these entries were due to wrong billing. In respect of remaining
` 217.67 crore it was observed that in case of billing to the post-paid customers
if it is subsequently confirmed that there was a mistake in the bill, the same was
reversed/adjusted in the respective revenue codes. It was noticed that there were
several reversal and adjustment entries in the general ledger to this effect. Further,
the Management did not furnish any document in support of its contention that these
waivers were due to errors in billing.
• TheManagementacceptedthatGoodwillwaiverswereinthenatureofdiscounts
offered for customer retention and maintaining relationship and although they formed
part of service revenue, same was reduced from GR. Since this was a part of
overall commercial strategy to enhance business, therefore, they were in the nature
of expenses and set-off for related items of expenses were not allowed as per the
licence agreement. Hence these should be added back to GR.
• CopyofthetariffplanssubmittedtoTRAI(providedtoaudit)didnotincludeany
kind of discount, whether billable or otherwise.
Thus, netting off of discounts and waivers amounting to ` 1135.79 crore given to post paid
subscribers resulted in understatement of GR/AGR and short payment of LF and SUC to
Government of India of ` 104.54 crore and ` 49.65 crore respectively (Annexures - 3.07,
3.08 and 3.09).
3.2.3 Under reporting of Roaming Revenue due to set-off of Inter Operator traffic
(IOT) Discounts paid/credited to other Operators
Volume discount is a financial incentive for individuals or businesses that purchase goods/
service in multiple units or in large quantities. In telecommunications scenario, roaming
agreements between operators provide for allowing discounts in case of the subscribers
of a particular service provider using the ‘sellers’ network in bulk. Mutual allowance of
discounts results in net payment of the incentive.
BAL and BHL have arrangements with other International Operators for providing roaming
services. It was noticed that the Inter Operator Traffic (IOT) Discounts paid/credited to
these Operators accounts was debited to/deducted from the revenue heads.
Having roaming arrangement with other national/international operators was a matter of
mutual agreement between two operators and giving discounts over and above the agreed
charges for roaming was part of overall commercial strategy to enhance business between
the two operators. As such, these discounts were in the nature of expenses and hence, in
terms of licence agreements, should not be deduced from revenue.
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It was observed that Inter Operator Traffic (IOT) Discounts amounting to 165.59 crore during
the period from 2006-07 to 2009-10 were debited to roaming revenue (Annexure 3.10).
On being pointed out by audit, it was stated by BAL Management that:-
• Internationalroamingtransactionsareinnatureofagreedvolumebaseddiscounts.
• International Roaming Revenue is generated based on negotiation adopted by
business. Further, the Operators agree on volume of traffic to be provided amongst
them on any of the methodology based on volume discount. It is in the nature of
trade/volume discounts and the same should not be considered as an expense.
• OutofIOTdiscountof` 168.24 crore (initially pointed out by Audit), ` 2.58 crore
was knocked with the corresponding credit/contra entry, 0.07 crore was considered
twice and the entries pertaining to IOT amounting to ` (-50.89) crore not considered
by Audit.
Audit views on the reply of the Management are as given below:-
• Contraentriesandduplicatereflectionsamountingto` 2.58 crore and ` 0.07 crore
respectively as stated by the Management in its reply have been considered and the
figures have been revised from ` 168.24 crore to ` 165.59 crore (` 168.24 crore -
` 2.58 crore - ` 0.07 crore).
• As alreadybrought out in the para, givingdiscounts over and above the agreed
charges for roaming was part of overall commercial strategy to enhance business
between the two operators; hence these discounts were in the nature of expenses.
Since the licence agreement does not permit any netting off, such expenditure cannot
be deducted and therefore, have to be included in the GR.
• RegardingnonconsiderationofentriespertainingtoIOTamountingto` (-50.89)
crore as mentioned in the Management reply, it was observed that these entries
were of the nature of IOT receipts (viz. Vodafone IOT compensatory receipt, etc.)
and not in the nature of IOT discount paid to the other operators. They were not
considered by audit, as no netting off was permissible under clause 19.1 of the
licence agreement.
Netting off of IOT discounts amounting to ` 165.59 crore (Annexure - 3.10) given to in-
ternational roaming operators resulted in reduction of GR/AGR and short payment of LF
and SUC of ` 15.62 crore and ` 7.22 crore respectively.
3.2.4 Under reporting of revenue from Infrastructure sharing with other telecom
operators for GR/AGR by BAL/BHL
As mentioned in para 1.4 (a),the GR shall be inclusive of revenue from permissible sharing
of infrastructure and any other miscellaneous revenue without any set-off for related item
of expense, etc.
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Telecom infrastructure (towers, network equipment’s etc.) owned by BAL/BHL were being
shared with other telecom companies. BAL/BHL entered into agreements with other telecom
companies for infrastructure (cell site) sharing. In terms of the agreements entered with the
other operators, charges for sharing sites recoverable from other operators was based on a
percentage of CAPEX5 cost of the sites and OPEX6 cost incurred by BAL/BHL.
Review of data/records pertaining to Infrastructure sharing charges furnished by BAL/BHL
for the period from 2006-07 to 2009-10 revealed that:-
a) Infrastructure sharing charges which were in the nature of Rent, recoverable/
recovered were booked in the revenue heads relating to Infrastructure sharing partly
and the remaining were netted off from the respective expense heads.
b) Other Infrastructure sharing charges recoverable/recovered on account of Fuel
(Diesel), Electricity, Repairs and Maintenance and Security were netted off from the
expenses head and not included in the revenue at all.
The total amount netted off from the expense on account of site sharing revenue (Rent,
Diesel, Electricity, Repairs and Maintenance and Security) during 2006-07 to 2009-10 was
` 224.22 crore (Annexure – 3.11). This amount should have been taken to GR/AGR.
On being pointed out by audit, it was replied by BAL/BHL that -
• theprocedureofrevenuebookinginrespectofInfrastructuresitesharinghastwo
elements-
a) OPEX Reimbursement- Commercial Power, Fuel (Diesel), Security and
AMC, which was in the nature of reimbursement of actual expenses incurred,
was credited under the respective head.
(b) CAPEX Recovery- This amount, which was in the nature of rent was
recognized by Bharti Airtel under “Infrastructure Sharing Income”.
It was further stated that the part of rent which was credited in the expense head was in
nature of OPEX recovery only and as per AS-29, the expenses relating to a provision may
be presented net of the amount recognized for a reimbursement in the Profit and Loss
statement.
• ItwasalsostatedthatasperTDSATjudgmentofAugust2007,reimbursementof
cost/expenses received from other companies should not form part of AGR.
Reply of the BAL Management is not tenable due to following reasons:
• Intermsoflicenceagreement,GRspecificallyincludesrevenuefrompermissible
sharing of infrastructure without any set-off for related item of expense. Further,
5 CapitalExpenditure6 OperatingExpenditure
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licence agreements do not distinguish infrastructure sharing revenue between CAPEX and OPEX. Hence, set-off of revenue from Infrastructure sharing against the expenses is not allowed. Further, licence agreement permits only three permissible deductions and no such deduction (i.e. on account of reimbursement of costs of Infrastructure sharing) was allowed.
• TDSATjudgmentdated30August2007referredinthereplywassetasidebytheHonourable Supreme Court vide judgement dated 11 October 2011.
• Auditisoftheviewthatrevenuetowardsdieselexpenses,securityexpenses,repairand maintenance expenses and electricity charges did not constitute reimbursement since they had to be incurred irrespective of whether the towers were shared or not. In fact, by sharing the expenditure the Company benefited through additional income.
Thus, netting off site sharing revenue received/receivable from other telecom operators from the cost during the period from 2006-07 to 2009-10 resulted in understatement of GR/AGR by ` 224.22 crore and short payment of LF and SUC by ` 19.30 crore and
` 9.08 crore respectively by BAL/BHL (Annexure – 3.11).
3.2.5 Under reporting of revenue from Forex gain for GR/AGR by BAL/ BHL
As per accounting policy adopted by BAL/BHL for the years 2006-07 and 2007-08, the resultant foreign exchange differences arising on payment or conversion of liabilities were recognized as income or expense in the year in which they arise except in respect of liabilities for acquisition of fixed assets where such exchange difference was adjusted in the carrying cost of the respective fixed asset.
Further, both the companies changed their policy with effect from 1 April 2008 to charge/credit fluctuation gain/loss in respect of loan/liabilities for acquisition of fixed assets directly to the P&L Account.
Review of data/records of BAL/BHL for the period from 2006-07 to 2009-10 revealed that the Realized gain during 2006-07 to 2009-10 was ` 221.58 crore out of which forex gain of ` 5.93 crore only was considered in GR/AGR during 2006-07 under UASL/NLD/ILD licences of BAL (Annexure - 3.12).
It is pertinent to mention here that the above realised gain calculated from the data extracted from the reports generated from Oracle Financial System did not represent the actual gain of that particular item since the company recasts the value of all the items included under the foreign exchange gains/losses head every year, the matured items are accounted under realised gains and the un-matured items remain under unrealised gain. Thus, the realised gain of a particular item in that year would not be the actual gain due to accounting of the
gains /losses of that item during the intermediate period under unrealised. Audit could not
arrive at the actual value of items accounted under realised gain every year for want of
Report No. 4 of 2016
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original value of each item. Further, audit has considered the quarterly net gain, head of
account-wise and LSA-wise, as it was not possible for audit to segregate/collect the figures
of gains only from the data made available. The operator should calculate the gain of each
item with reference to its initial value of accounting and include the total forex gain in GR/
AGR.
On being pointed out by audit, it was stated by the Management that:-
• ForexGain was not Revenue:As per the Accounting Standard 9 on Revenue
Recognition, Foreign Exchange Gain has been specifically excluded from the
definition of Revenue.
• ForexGainwasNotional:The realized forex was nothing but an overall business
risk which each company would assume in foreign currency transactions. Such
notional gains/losses on account of reduction/increase in the liabilities/loans cannot
be considered to be revenue from operations and should not be included in the GR/
AGR.
• ForexGainsandlosseswasdynamicandindeterminable:TRAI Recommendations
dated 6 January 2015 on Definition of Revenue Base (AGR) states that the revenue/
profit arising on account of fluctuation of foreign exchange should not be part of
AGR for the purpose of computation of LF and SUC. Also TDSAT (August 2007)
did not view forex gain/loss differently from TRAI.
• NotrelatedtoTelecomactivities:The Notional foreign exchange fluctuation was a
contingency which had impact on every business and was not specific and unique to
telecom business. Also, as per TRAI recommendation dated 13 September 2006 on
the AGR matter, forex was not related to telecom activities.
• Further, BAL intimated that ` 73.49 crore was the amount of realised forex gain
during the years from 2006-07 to 2009-10.
Reply of the management is not tenable as -
• IntermsofthelicenceagreementGRshallbeinclusiveofanyothermiscellaneous
revenue and audit is of the view that any gain incidental to PSPs should be considered
for GR.
• The company has been following mercantile method of accounting and as per
commercial principle of accounting, “the profit/loss” is to be arrived after taking
into account all accrued receipts and expenses and comparing of trading assets
between two different dates. Under the mercantile system of accounting a forex
gain (revenue)/loss (expenditure) incurred as a result of exchange differences are
rational and cannot be considered as contingent/notional in nature. Further, audit has
considered the realised gain only.
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• Even as per accounting policy adopted by BAL/BHL during the years from
2006-07 to 2009-10, the resultant foreign exchange differences arising on payment
or conversion of liabilities are recognized as income or expense in the year in which
they arise. Further, company was reporting exchange differences (on net basis) in
their financial statement.
• TDSAT judgment dated 30 August 2007 and TRAI recommendation dated
13 September 2006 referred in the reply has no relevance in the light of the Hon’ble
Supreme Court judgement dated 11 October 2011 which stated “the TRAI and the
Tribunal had no jurisdiction to decide on the validity of the definition of AGR in
the licence agreement and to exclude certain items of revenue which were included
in the definition of AGR in the licence agreement between the licensor and the
licensee”. Audit is of the view that forex gain is incidental to telecom activity for
telecom operators.
• Itisnottruethatforeignexchangegains/lossesareneithercoveredinthedefinition
of GR in the Licence Agreement nor disclosed in the Statement of AGR, as Licence
Agreement provides that “GR shall be inclusive of …… any other miscellaneous
revenue, without any set-off for related item of expense, etc,” and forex gain was
part of Miscellaneous Revenue.
• TRAIRecommendationdated6January2015referredtointhereplyhasnotfinally
been accepted by DoT.
• Aforesaidrealisedforexgainof` 73.49 crore has been arrived by the TSP after
considering yearly net gain only of all the account codes booked for forex gain/
loss in a business unit/licences. However, audit considered the quarterly net gain
LSA-wise as the LF and SUC are payable LSA-wise every quarter and hence, the
difference in figures.
Thus, non-inclusion of foreign exchange gains pertaining to period from 2006-07 to
2009-10 resulted in understatement of GR/AGR by ` 216.84 crore. Resultantly, LF and
SUC amounting to ` 17.46 crore and ` 6.74 crore respectively was not paid by BAL/BHL
(Annexure - 3.12).
3.3 Under reporting of revenue in the Statements of Revenue and LF (AGR
Statements) though reported in the books of accounts.
3.3.1 Non consideration of Interest Income for GR/AGR.
Review of data/records furnished by BAL/BHL for the period from 2006-07 to 2009-10
revealed that interest income accounted in the books of accounts of BAL was partially
Report No. 4 of 2016
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considered for GR/AGR in the years 2006-07 and 2007-08 but not considered at all
in the years 2008-09 and 2009-10. Amount of interest income accounted in the books
were ` 340.74 crore out of which ` 1.61 crore only was considered for GR/AGR during
2006-07 to 2009-10 resulting in non-consideration of interest income amounting to ` 339.13
crore for the purpose of GR/AGR. Business unit/ licences wise details are furnished in
Annexure 3.13.
Similarly, interest income accounted in the books of accounts of BHL was fully considered
for GR/AGR in the year 2006-07 and partially considered in the year 2007-08 but not
considered at all in the years 2008-09 and 2009-10. In the year 2007-08, out of total interest
income of ` 2.37 crore accounted, ` 1.74 crore was considered for GR/AGR and ` 0.63
crore was not considered. In the years 2008-09 and 2009-10, interest earned amounting to
` 1.23 crore and ` 3.96 crore were not considered for GR/AGR.
BHL Management stated that –
• Interestincomeaccountedundercorporatetrialbalances(TBs)wasnotconsideredas
it was not related to telecom operations. It further stated that the interest accounted
in the corporate TBs was earned from deployment of surplus funds/borrowed funds
and it being a non-telecom revenue needed to be excluded from AGR.
• ItalsostatedthatsometimesfundsborrowedforCAPEXwereinvestedandinterest
earned and this interest being always less than the interest payable/paid on borrowings,
no interest income was left for inclusion in AGR for levy of revenue share.
• ConsideringtheTDSATjudgementdated30August2007,interestincomeaccounted
under Trial balances of UASL/NLD/IP1/ILD/ISP/VSAT were not considered for
AGR.
BAL/BHL’s Management contention for non-inclusion of interest income for AGR is not
tenable as
• AuditisoftheviewthatdefinitionofGRinlicenceagreementsexpresslyprovides
for inclusion of interest income for GR/AGR for computation of revenue share;
• TDSATjudgementdated30August2007hasbecomenullandvoidafterHonourable
Supreme Court judgement dated 11 October, 2011.
Thus non-inclusion of Interest income pertaining to period from 2006-07 to 2009-10 resulted
in understatement of GR/AGR by ` 344.95 crore. Impact on short payment of LF and SUC
due to non-consideration of interest income in GR/AGR was ` 28.51 crore and ` 11.80
crore respectively (Annexure - 3.13).
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3.3.2 BAL’s interest free loan to subsidiary resulted in avoidance of payment of LF/
SUC
Audit observed that BAL gave ` 1487.95 crore as interest free un-secured loan in 2009-10 to M/s Bharti Telemedia Ltd (BTL), a 95 per cent subsidiary of the BAL. Grant of interest free unsecured loan was in violation of Section 372(A) of Companies Act, 1956 and not in line with the arm’s length relation to be maintained between the holding company and subsidiary company.
As a result, BAL’s revenue was lower by the amount of interest receivable from BTL and ultimately the LF and SUC thereon was short-paid to the Government of India to that extent. The impact on short payment of LF and SUC could not be quantified since the date of release of loan and period for which above interest free loan remained outstanding was not available.
3.3.3 Non consideration of Profit on sale of Investment for GR/AGR for payment of
revenue share by BAL.
Format of Statement of Revenue and LF (AGR Statement) prescribed as Appendix II to Annexure -II as referred in Clause 20.4 of the UASL agreement is an integral part of the Licence Agreement. In the Statement, item 4 has been prescribed to reflect the “Income from Investment”.
Review of data/records furnished by BAL/BHL for the period from 2006-07 to 2009-10 revealed that gross income on account of Income from Investments were ` 34.14 crore, ` 57.75 crore, ` 235.48 crore and ` 183.82 crore in the year 2006-07, 2007-08, 2008-09 and 2009-10 respectively (Annexure - 3.14). Above income had not been considered in GR/AGR for computation of revenue share.
BAL Management stated that considering the TDSAT judgement dated 30 August 2007, income from investment accounted under corporate trial balance was not considered for AGR. It further stated that this corporate income was generated from treasury function which was a separate and distinct function from licenced activity and this income was a non-licenced activity/non-operational income. Therefore such corporate income should not form part of GR.
BAL’s Management contention for non-inclusion of income from investment for GR is not tenable as TDSAT judgement dated 30 August 2007 became null and void after Honourable Supreme Court judgment of 11 October 2011. Further, Audit opined that licence agreements provide for inclusion of income from investment in GR/AGR for computation of revenue share.
Thus non-inclusion of Income from investment pertaining to period from 2006-07 to 2009-10 resulted in understatement of GR/AGR by 511.19 crore. Impact on short payment of LF and SUC due to non-consideration of income from investment in GR/AGR was
` 42.45 crore and ` 17.45 crore respectively (Annexure - 3.14).
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3.3.4 Different standards for payment of dividends
As mentioned in para 1.4 (a) GR shall be inclusive of dividend along with other revenue stated therein. Thus the revenue from investment (dividend) was to be included for the purpose of revenue share. An analysis of the annual accounts of BAL for the period from 2006-07 to 2009-10 indicated that BAL’s investments in form of equity shares in its subsidiaries, Joint Ventures, associates and others (Annexure - 3.15 ) increased by more than 19 times from ` 580.24 crore in 2006-07 to ` 11,153.51 crore in 2009-10 (Annexure - 3.16).
BAL was the majority shareholder in most of these subsidiaries, Joint Ventures, associates, subsidiary’s subsidiary and other entities. However, BAL did not receive any return on these investments during this period in form of dividend or otherwise in spite of the fact that the total profit of these companies after tax was ` 157.04 crore, ` 415.64 crore, ` 905.44 crore and ` 893.68 crore during each of the four years from 2006-07 to 2009-10 respectively (Annexure - 3.17).
It was seen in audit that BAL had adopted different standards for declaration of dividend in respect of BAL itself and for other non-licensee companies where it had investments and majority shareholdings. While BAL had declared a dividend of 20 per cent on face value of shares for 2008-09 and 2009-10, no dividend was declared by any of the subsidiaries, Joint Ventures, associates and others where BAL had a majority shareholding. While dividend paid by BAL was an expense for it and was not subject to LF and SUC, the dividends received by it from companies/entities it had invested in would have attracted imposition of LF and SUC as per terms of the licence agreement.
Thus non-declaration of dividend by subsidiaries, Joint Ventures, associates and other entities in which BAL had invested was not in accordance with BAL’s own action of declaration of dividend and resulted in reduction of revenue of BAL and consequently lower payment of LF and SUC.
3.3.5 Non Consideration of revenue accounted under Global Operations (BILGO) for LF
BAL had set up its own branch at USA under brand name BILGO which carries the hubbing of traffic and does the switching of traffic arising out of bilateral agreements between BAL (ILD division) and various foreign operators located across the globe. BAL maintains a separate book of accounts to book the income/expenses relating to BILGO. The details of the operation carried out by BILGO and mechanism between the two segments (BILGO and BAL-ILD) are as follows-
(a) For call traffic originating from USA – BILGO switch hands over the outgoing traffic from other operator’s to BAL-ILD’s network for terminating anywhere in the world. For this service, BILGO retains five per cent and transfers 95 per cent of the
amount billed to the foreign telecom operators to BAL – ILD.
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(b) For call traffic terminating in the USA – BILGO switch handles the call traffic from
BAL-ILD and hands over the same to other operators in the USA. For this service,
BILGO charges to BAL-ILD at 105 per cent of what is payable by BILGO to the
foreign terminating operators and retains five per cent.
However it was noticed that during 2006-07 and 2007-08, this margin was 2.87 per cent
and 4.03 percent only. Amount of revenue and access charges booked in BILGO’s books
of accounts are as follow-
Table 3.6
(` in crore)
Year Total revenue Total Access Charges
Excess revenue over access charge
(Margin)
Margin(in per cent)
{Percentage of “d” w.r.t “c”}
(a) (b) (c) (d) (e)
2006-07 285.48 277.51 7.97 2.87
2007-08 340.73 327.53 13.20 4.03
2008-09 230.10 218.76 11.34 5.18
2009-10 312.62 297.23 15.39 5.18
Total 1168.93 1121.03 47.90 4.27
Revenue over access charges amounting to ` 47.90 crore was not considered for GR/AGR.
BAL’s Management stated that –
• BILGOwas operating on a foreign soil (USA) as a gateway station (POP) for
which licence/permission had been obtained from USA authorities, not from Indian
authorities and it had a separate identity from US Tax and regulatory perspective and
• This fiveper cent retention by BILGO was taxable in the USA as per Tax and
regulatory laws. As such revenue and access charges accounted in BILGO’s books
of accounts should not be considered for GR/AGR for LF.
BAL’s Management contention is not tenable as:
• SettingupoftheBILGOisonlyatechnicalarrangementmadebyBALtomanage
its ILD traffic and BAL had got ILD licence from the Indian authorities. BAL is
providing telecom service under the name of BILGO and was not a separate legal
entity. Even the transactions accounted in BILGO’s books of accounts are part of
telephone traffic of BAL’s ILD network and included in the financial statements of
BAL. Further, as per the definition of GR, GR shall include all revenue accruing to
the Licensee without any set-off for related item of expense. Hence the revenue of
BILGO should be included for GR.
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• Auditdoesnotdisputethetaxabilityoffiveper cent retained by BILGO in USA as
per Tax and regulatory laws but contends that since this constituted the income of
BAL, the same should be a part of the sharable revenue under ILD licence.
Accordingly, BAL’s ILD AGR was under reported by ` 47.90 crore (` 7.97 crore,
` 13.20 crore, 11.34 crore and 15.39 crore for the years 2006-07, 2007-08, 2008-09 and
2009-10 respectively) which should be added back to AGR for computation of LF for
BAL’s ILD licence. Impact on short payment of LF (ILD) due to non-consideration of
BILGO revenue was ` 2.87 crore (` 0.48 crore, ` 0.79 crore, ` 0.68 crore and ` 0.92 crore
for the years 2006-07, 2007-08, 2008-09 and 2009-10 respectively).
3.3.6 Non Consideration of revenue of erstwhile SBEL
Satcom Broadband Equipment Limited (SBEL) was a subsidiary of BAL prior to
1 October 2005. SBEL was in the business of selling VSAT hardware. SBEL got
amalgamated with BAL effective from 1 October 2005 as per certificate of registration
received on 27 July 2007. Though SBEL was amalgamated with BAL, BAL maintained
separate trial balances for accounting transactions relating to erstwhile SBEL’s domestic and
international transactions. The total revenue amounting to 116.24 crore booked under these
trial balances was not considered for GR/AGR under any licence during the period from
2006-07 to 2009-10 except in the year 2008-09 when Service Revenue amounting to
` 0.18 crore was considered in the GR of VSAT.
BAL’s Management stated that SBEL was incorporated as a separate legal entity and prior
to its merger with BAL, it was engaged in –
i) trading in telecom equipment,
ii) trading in VSAT equipment across the world, and
iii) turn-key project for VSAT installations.
These are mainly trading and international activities and not governed by the Telecom
licence. Post-merger, the accounts of BAL included the accounts for activities undertaken
by Satcom for which separate books of accounts were maintained. Further, the activities
carried on by Satcom are not linked with the telecom services being provisioned by units
of BAL. Activities were continued to be carried on by Satcom under BAL as were being
carried on prior to merger. Management further stated that merger changed the structure
of the entity but it did not change the nature of transaction being carried on. An activity
which was a non-licenced activity cannot become a telecom service post merger. Thus,
just because two companies have merged does not make a non-telecom activity a telecom
activity thereby subjecting it to LF. Post-merger, its business (which is non-telecom in
nature) was being carried on by BAL. Thus, the company is under no obligation to pay LF
on such activities/transactions as were carried on by Satcom.
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Reply of the Management is not tenable as SBEL was a separate legal entity prior to
1 October 2005 and it had not got any licence from Government of India for its activities
which were primarily dealing in VSAT equipment. However, it got merged with BAL with
effect from 1 October 2005 and transactions recorded in its books of accounts show that
revenue accounted are from telecom services (bandwidth charges, IRU charges, installation
charges, data services, equipment rental etc.) as well as sales of hardware to foreign/
domestic telecom companies. This revenue also formed part of revenue of BAL and in
terms of definition of GR, GR shall include all revenue accruing to the Licensee without
any set-off for related item of expense. Accordingly the revenue of ` 20.85 crore, ` 36.04
crore, ` 22.70 crore (out of it ` 0.18 crore already considered) and ` 36.65 crore accounted
under the books of accounts for the years 2006-07, 2007-08, 2008-09 and 2009-10 of
erstwhile SBEL should be included in the GR. Impact on short payment of LF (VSAT)
due to non-consideration of revenue booked in erstwhile SBEL accounts was ` 1.25 crore,
` 2.16 crore, ` 1.35 crore and ` 2.20 crore for the year 2006-07, 2007-08, 2008-09 and
2009-10 respectively.
3.3.7 Non consideration of revenue accounted under Infrastructure Provider (IP)-1
service for computation of revenue share by BAL
BAL had got two registrations for Infrastructure Provider 1 (IP1) from DoT (October
2000 and February 2001)7 for providing infrastructure services. The scope of services
under IP1 registration covers the business of providing assets such as Dark Fibre, Right of
Way, Duct Space and Towers on lease/rent out/sale basis to Telecom licensees. However,
BAL had maintained separate books of accounts (TBs) for recording transactions of IP1
services. Revenues booked under IP1 include Service Revenue, Interest Income and Other
Income which form part of Profit and Loss Account of BAL. Further, service revenue for
the period from 2006-07 to 2009-10 pertaining to IP1 services (` 435.73 crore) includes
revenue from BAL’s NLD division (` 221.40 crore), ISP division (` 9.13 crore) and from
other operators (` 205.20 crore).
However, the whole service revenue accounted under IP1 Trial Balances was not considered
for AGR for payment of LF despite the fact that this revenue formed part of revenue of
BAL and in terms of definition of GR, it shall include all revenue accruing to the Licensee
without any set-off for related item of expense.
BAL’s Management stated that the IP1 registration had nothing to do with the licence
agreement and the activities taken there under. The IP1 registration enables any company
incorporated in India to install and provide passive infrastructure to the Telecom Service
Providers and as per the existing policy, there was no imposition of LF on the companies
7 OriginalregistrationswereinfavourofBhartiTelesonicLimited(BTSOL)andBhartiTelenetLimited(BTL).BhartiTelesonicLimitedandBhartiTelenetLimitedweresubsumedinBAL{FormerlyBhartiTeleventureLimited(BTVL)}.
Report No. 4 of 2016
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having IP1 registration. The income earned from these services was accounted for separately
which therefore resulted in separate trial balances maintained by the company so as to
distinguish the same from other licenced income.
Audit accepts that the revenue from NLD division included in IP1 revenue is not subject to
LF but contends that income from ISP division and other operators should be considered
for revenue sharing. Accordingly, ` 214.33 crore (` 47.03 crore, ` 54.01 crore, ` 65.26
crore and ` 48.03 crore for the years 2006-07, 2007-08, 2008-09 and 2009-10 respectively)
should have been considered in AGR for the calculation of LF. Impact on short payment of
LF (NLD) due to non-consideration of IP1 revenue was ` 12.86 crore (` 2.82 crore, ` 3.24
crore, ` 3.92 crore and ` 2.88 crore for the years 2006-07, 2007-08, 2008-09 and 2009-10
respectively).
3.3.8 Non consideration of miscellaneous income for AGR for computation of LF/
SUC by BAL
As per schedule of Other Income forming part of Profit and Loss Account of BAL,
Miscellaneous Income for the years 2006-07, 2007-08, 2008-09 and 2009-10 was ` 79.87
crore, ` 200.61 crore, ` 87.08 crore and ` 45.28 crore respectively. Service area wise
details of such miscellaneous income are furnished in the Annexure - 3.18. From the
AGR statements vis-à-vis Trial Balances/Reconciliation statements furnished to audit, it was
noticed that an amount of ` 96.19 crore being the miscellaneous income was not included
in GR/AGR for computation of revenue share.
BAL’s Management stated that -
• Miscellaneousincomeonaccountofinsuranceclaim,noticepay,scrapsale
in UASL and NLD/ILD/ISP/VSAT/Corporate segments was not included in
GR/AGR as per TDSAT judgment of August 2007.
• Itisanincomefromnon-licencedactivity.
• Miscellaneous/OtherIncome(insuranceclaim)of2006-07ofUASLsegment
is not subject to LF as it is a capital receipt and it cannot be termed as
revenue in ordinary course of business.
• Miscellaneousincomeof` 2.37 crore in 2006-07 in ISP and VSAT segment
were in the nature of liability written back.
Audit view on the management reply is as follows:-
• Income from insurance claim has been excluded and the Miscellaneous
income considered by audit revised from ` 140.21 crore to ` 96.19 crore.
• TDSAT judgmentofAugust2007was set asideby theHon’bleSupreme
Court of India (October 2011)
Report No. 4 of 2016
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• Management contention that these miscellaneous incomes are from
non-licenced activity and hence not liable to be included in AGR is not
acceptable since definition of GR expressly provides that miscellaneous
income should be included in GR for computation of revenue share.
• ` 2.37 crore had been booked in miscellaneous Income in Trial Balances of
2006-07 related to ISP and VSAT segments. Whereas amount in the nature
of liability written back were booked in separate account heads. Hence, it
cannot be stated to be in the nature of liability written back.
As such, items of miscellaneous income as stated above amounting to ` 96.19 crore
not considered in respective AGR should be included in AGR for computation of
LF/SUC. Impact on short payment of LF and SUC due to non-consideration of
miscellaneous income in GR/AGR was ` 6.94 crore and ` 1.74 crore respectively
(Annexure - 3.18).
3.3.9 Non consideration of Income from profit on sale of fixed assets for AGR for
payment of revenue Share by BAL
From the examination of data/records furnished by BAL/BHL for the period from 2006-07
to 2009-10, it was observed that revenue on account of “Profit on sale of Fixed Assets”
was ` 8.75 crore, ` 12.04 crore, ` 7.24 crore and ` 1.92 crore during the years 2006-07,
2007-08, 2008-09 and 2009-10 respectively.
From the AGR Statements, it was found that amount of Profit on Sale of Fixed Assets was
considered for computation of AGR in the year 2006-07 but such income of ` 21.20 crore
was not considered for AGRs in the later three years i.e. 2007-10.
BAL’s Management stated that -
• ConsideringtheTDSATjudgementdated30August2007,therevenueonaccount
of profit on sale of fixed assets had not been considered for AGR.
• Thisrevenuewasinnatureofcapitalrevenueanditwasnotderivedfromlicenced
activity and hence it should not be included in AGR for computation of LF.
The contention of the BAL’s Management is not tenable since-
• TDSATjudgementdated30August2007hasbecomenullandvoidafterHon’ble
Supreme Court judgment dated 11 October 2011.
• Licenceagreementsdidnotdifferentiatebetweenlicencedactivityandnon-licenced
activity. In terms of definition of GR, GR shall include all revenue accruing to the
Licensee without any set-off for related item of expense and the company had also
considered it for inclusion in AGR in the year 2006-07. Thus, income of ` 21.20
crore on account of profit on sale of fixed asset accounted in the books of accounts
Report No. 4 of 2016
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of the company should be included in GR/AGR for computation of Revenue Share
payable by the company to Government of India.
Impact on short payment of LF and SUC due to non-consideration of profit on sale of fixed
asset in GR/AGR was ` 1.91 crore and ` 0.83 crore respectively (Annexure - 3.19).
3.4 Short/ non-payment of revenue share due to other issues.
3.4.1 Irregular Deduction of Bad debts written off from GR to arrive at AGR by
BAL/BHL
Review of data/records furnished by BAL/BHL for the period from 2006-07 to 2009-10
revealed that the amount of “Bad debts Written Off” accounted during the year 2006-07
to the tune of ` 105.51 crore in UASL segment had not been deducted from GR to arrive
at AGR. However, in the years 2007-08, 2008-09 and 2009-10, “Bad debts Written Off”
accounted in UASL segment of 181.13 crore, 63.18 crore and 41.13 crore respectively
was deducted while arriving at AGR.
Similarly, as per AGR Statements and TBs of BHL, it was found that no amount of “Bad
debts Written Off” had been deducted from GR in 2006-07 and 2007-08. However, in the
years 2008-09 and 2009-10, amount of “Bad debts Written Off” accounted in UASL/CMTS
segments of ` 2.25 crore and ` 0.03 crore was deducted while arriving at AGR.
Management stated that -
• ConsideringtheTDSATjudgementdated30August2007,theamountof“Baddebts
Written Off” had been deducted from GR.
• Bad debt was revenue not realized by the company and as per AS-9, revenue
includes gross inflow of economic benefits received and receivable by the entity on
its own account.
• Whenaparticularreceivableisknowntobebadandunrecoverable,suchbaddebts
during the particular period must be excluded from GR.
The contention of the Management is not tenable since
• TDSAT judgement dated 30 August 2007 has become null and void after
Hon’ble Supreme Court judgment dated 11 October 2011.
• WhileauditdoesnotquestionaccountingasperAS-9,itcontendsthatanyamount
of revenue becoming unrecoverable is treated as bad debts which form part of
Administrative and other expenses in the Profit and Loss Account.
• ThelicenceagreementdoesnotprovidedeductionofbaddebtfromGRtoarriveat
AGR. The licensee itself did not deduct the bad debts written off from GR to arrive
at AGR during the year 2006-07 and 2007-08.
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Thus, bad debts written off amounting to ` 287.72 crore and deducted from GR to arrive at
AGR in UASL/CMTS segments should be added back to AGR for computation of Revenue
Share payable by the companies to DoT. Impact on short payment of LF and SUC due to
deduction of bad debts from GR to arrive at AGR was ` 25.55 crore and ` 11.44 crore
respectively (Annexure - 3.20).
3.4.2 PSTN Deduction claimed against Leased Line Charges in 2006-07.
Review of data/records furnished by BAL/BHL for the period from 2006-07 to 2009-10
revealed that Lease Line charges payable by UASL Circles (Mobile and Fixed services)
of BAL/BHL to BAL’s NLD division was claimed under PSTN deduction in the year
2006-07 to the tune of ` 327.09 crore. LSA wise details are furnished in the
Annexure - 3.21.
Management stated that in terms of TRAI’s Interconnect Usage Charges Regulation (sixth
amendment) (February 2006), TSPs have been given liberty to decide carriage charges
to be paid to NLDO and hence they are under forbearance. TRAI has left the rates to be
charged on the mutual agreement between the service providers based on various service
elements being offered by NLDO which may include some fixed/minimum commitment in
terms of traffic minutes and creation of Point of Interconnection (POI). It was also stated
that the above transactions were in nature of a minimum commitment charge which can be
attributable to minute based carriage charge and the charges for setting up the POI.
The reply of the Management is not acceptable as in terms of UASL agreement (clause
19.2) and clarifications issued by DoT, lease line charge is not to be deducted from GR to
arrive at AGR. Further, TRAI Interconnect Usage Charges Regulation (sixth amendment)
provides that carriage charges per minute for long distance calls within India would be as
per mutual agreement between the service providers subject to a ceiling of 0.65 per minute
irrespective of the distance. As evident, it does not mention about any fixed/minimum
commitment charges but prescribes only minutes’ based charges which were claimed as
IUC deduction payable to NLD in addition to above mentioned lease line charges. Also, the
BAL/BHL themselves stopped claiming such deduction from 2007-08 onwards.
Inclusion of Lease Line Charges under PSTN deduction resulted in understatement of AGR
of UASLs of BAL/BHL by ` 327.09 crore for the year 2006-07. Resultantly, LF and
SUC was short paid in the year 2006-07 by ` 26.47 crore and ` 11.71 crore respectively
in respect of BAL and ` 1.56 crore and ` 0.92 crore respectively in respect of BHL
(Annexure - 3.21).
3.4.3 Non consideration of revenue from sale/lease of bandwidth charges for AGR for payment of SUC.
UASL agreement provides that “While calculating AGR for limited purpose of levying
Spectrum Charges based on revenue share, revenue from Wireline Subscribers shall not be
Report No. 4 of 2016
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taken into account”. Further, in the format of statement of revenue and licence fee (AGR
Statement) prescribed for the UASL agreement-
• Item1Ahasbeenprescribedtoreflectthe“RevenuefromWirelineSubscribers”
and
• Item8hasbeenprescribedtoreflectthe“Revenuefromsale/leaseofbandwidth,
links, R and G cases, turn key projects etc.”
During the review of the AGR Statements, it was noticed that “Revenue from sale/
lease of bandwidth, links, R and G cases, turn key projects etc.” amounting to ` 93.29
crore, ` 98.67 crore, ` 188.57 crore and ` 92.81 crore in the years 2006-07, 2007-08,
2008-09 and 2009-10 respectively was included in the AGR Statements for computation
of LF but not considered in the AGR for computation of SUC which was in contravention
of the provisions of the Licence agreements. LSAs wise details are furnished in the
Annexure - 3.22.
Management stated that above revenue were pertaining to wireline services and hence it was
not considered for levy of spectrum charges.
Management contention is not tenable as in terms of clause of 18.3 of UASL agreement,
revenue from wireline subscribers only needs to be excluded for spectrum charges. As
provided in the AGR statement, revenue from wireline subscriber is in item 1A and
Revenue from sale/lease of bandwidth, links, R and G cases, turn key projects, etc. is in
item 8. Thus, revenue from sale/lease of bandwidth is different from revenue from wireline
subscribers. As such, above revenue should be considered for computation of spectrum
charges also.
Thus, revenue from sale/lease of bandwidth, links, etc. amounting to ` 473.34 crore
should be added back in AGR for computation of SUC. Resultantly, SUC amounting to
` 20.70 crore was not paid on the said revenue by the company (Annexure-3.22).
3.5 Transfers of telecom infrastructure assets by BAL to its subsidiary (BIL) at NIL
value
M/s Bharti Infratel Limited (BIL) was incorporated as a subsidiary of BAL on
30 November 2006 with the object of inter-alia, setting up, operating and maintaining
wireless communication towers, provide network development services and to engage in
video, voice, data and internet transmission business in and out of India. BIL received the
certificate of commencement of business on 10 April 2007 from the Registrar of Companies.
Audit observed from BAL’s Annual Report for the year 2007-08 that the Scheme of
Arrangement8 between BAL and BIL was approved by the Hon’ble High Court of Delhi
8 Undersections391to394oftheCompaniesAct,1956,fortransferoftelecominfrastructureassetsfromBALtoBIL
Report No. 4 of 2016
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on 26 November 2007 and filed with the Registrar of Companies, Delhi and Gurgaon on
31 January 2008 i.e. the Effective Date of the Scheme. Pursuant to the scheme, the telecom
infrastructure of BAL was transferred to and vested with BIL with effect from 31 January
2008. BAL transferred the Telecom Infrastructure worth ` 5739.60 crore to BIL at Nil
value and BIL recorded the value of assets received from BAL at fair value of ` 8235.97
crore.
BAL and BIL being separate entities and also BIL was not a fully held subsidiary of BAL9,
transfer of assets was not a transaction at arm’s length. As the market value of the assets
was ` 8235.97 crore as revalued by BIL, the difference between the book value and the
value as accounted by BIL was profit foregone (` 2496.37 crore) on transfer of asset. In
accordance with licence agreement, this profit foregone on transfer of asset should be
considered for computation of LF and SUC.
Thus non consideration of the amount of ` 2496.37 crore resulted in short payment of
LF and SUC of ` 226.40 crore and ` 108.52 crore respectively for the year 2007-08
(Annexure 3.23).
3.6 Interest on short/non-payment of LF and SUC
On issues raised above (from paras 3.2 to 3.5) short/non-payment of LF and SUC
worked out to ` 719.46 crore and ` 347.49 crore respectively. The interest on this short/
non-payment of LF and SUC is ` 1584.94 crore (Annexure- 3.24). The calculation of
interest was based on the rate prescribed in the Licence agreement i.e. 2 per cent above the
Prime Lending Rate of State Bank of India existing as on the beginning of the financial year
and the period considered for the calculation was from the end of the concerned financial
year up to March 2015. The interest has been compounded monthly as prescribed in the
licence agreement.
3.7 DoT’s response to the audit observations
Audit observations on the revenue shared by M/s BAL were communicated to DoT in
May 2015. DoT in reply (January 2016) informed that demands for understatement of GR
were raised on the PSP in 2012 for the years 2006-07 and 2007-08, based on the report of
Special Audit conducted in 2009. These pertained to issues raised in paras on commission/
discount to dealers netted off from revenue and free airtime given to prepaid subscribers not
recognized as revenue (3.2.1(A)); understatement of GR due to non-inclusion of revenue
from infrastructure sharing in full (3.2.4); under reporting of revenue due to non-inclusion
of revenue/income in GR/AGR from forex gain (3.2.5), interest income (3.3.1), profit
from sale of investment (3.3.3), revenue from BILGO (3.3.5), revenue from IP-1 services
(3.3.7), miscellaneous revenue (3.3.8), profit on sale of assets (3.3.9); deduction of bad
9 BALwasholdingonly92.89per centoftheShareinBILason31March2008.
Report No. 4 of 2016
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debts from GR (3.4.1) and gain on successive transfer of passive infrastructure (3.5).
However, the demands were challenged by the operator in TDSAT/High Courts. It was
also informed that action would be taken as and when the final court judgement would be
pronounced.
Thus, DoT, without disputing the issues raised by Audit, has stated that the demands
could not be realized as the matter was sub-judice. The fact that DoT could not get/obtain
the revenue due indicated to the need for a more pro-active approach on part of DoT as
substantial amount of government revenue was involved.
DoT also stated that there were differences in the amounts objected to by DoT consequent
to the Special Audit and that pointed out by CAG audit. These variations may be on account
of differences in methodology adopted in quantifying the understatement of revenue for
which details of working paper of Special Auditors were not seen by CAG audit. However,
CAG audit has quantified the amount of short/non realization of revenue (LF and SUC) on
the basis of the actual entries identified through clear description in the books of accounts
of BAL for 2006-07 to 2009-10.
In respect of paras pertaining to netting off of discount/waiver given to post paid subscribers
from revenue (3.2.2); roaming revenue understated due to netting off inter-operator traffic
discount paid to other operators (3.2.3) and non-inclusion of revenue of erstwhile SBEL
(3.3.6), DoT stated that replies received from the PSP were under examination.
In respect of paras pertaining to different standards for payment of dividends (3.3.4);
irregular deduction claimed for lease line charges (3.4.2) and non-consideration of bandwidth
charges for SUC (3.4.3), it was stated that replies from respective wings of DoT were
awaited.
In respect of para pertaining to interest free loan to subsidiary (3.3.2), it was stated that
DoT had taken a decision in 2005, in consultation with Ministry of Law and learned AG,
that notional interest can neither be reckoned nor included in AGR.
Audit view is that DoT’s decision of not reckoning the due interest on interest free loan
given to subsidiaries which are not fully owned, for AGR purpose was not in line with
the provisions of the Companies Act, 1956. By providing interest free loan to other than
fully owned subsidiary, BAL’s revenue was lower by the amount of interest receivable
and ultimately the LF and SUC thereon was short-paid to the Government of India to that
extent.
DoT’s response to para 3.2.1 (B) and (C) on under reporting of revenue due to offers/
discounts to customers and dealers for pre-paid services and short reporting of revenue due
to upfront debits in revenue heads was awaited (January 2016).
Report No. 4 of 2016
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DoT also stated that the basic definition of GR and AGR was challenged by the TSP’s
in 2002-03. Since then, there has been protracted litigation and is continuing till date.
Also, some of the licensees have also filed (in 2012) writ petitions before various High
Courts invoking the writ jurisdiction under Article 226 of the Constitution challenging the
Section-4 of Indian Telegraph Act, 1885, as violative of the Article14 and 19(1) (g) of the
Constitution of India. The process of deduction verification by the CCA offices and the
LF assessment work by the DoT Headquarters was adversely impacted due to this. DoT
admitted that the numerous disputes are causing delays in assessment of the revenue share
due from the operator.
The response of DoT proves that though the revenue share regime was introduced as part of
NTP-1999, the Department has not been able to realise its due revenue share as envisaged
in the Licence agreement even after more than 16 years of its implementation.
It would be pertinent to mention here that when the Government decided to reduce the
LF for all operators by two per cent effective from April 2004, DoT expected that the
reduction would prompt operators to withdraw the challenges against the Government.
However, the reduction in LF did not have the expected impact and the operators continue
to institute litigations against the Government challenging the definition of GR/AGR and
demand notes. Thus the PSP got the benefit of reduction in rate of LF but the Government
didn’t get the reciprocal benefit of reduction in litigations.
Report No. 4 of 2016
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CHAPTER – IVRevenue Shared by Vodafone India Limited
4.1 Brief Profile of M/s Vodafone India Ltd
Brand Vodafone was launched in India in 2007 when Vodafone Plc, the British multinational
communications company, acquired majority stake in M/s Hutchinson Essar which was
providing GSM based cellular mobile services in sixteen1 licenced service areas in the
country. The decision of the Government of India in 2005 to raise the Foreign Direct
Investment (FDI) in telecom sector to 74 per cent helped the British company to make
major foray into the Indian telecom space. By 2007-08, the operator was allotted seven2
more licences and had established pan India presence with operations in all existing twenty
three Licensed Service Areas (LSA) in the country. Vodafone India provides wireless
mobile telephone services which include voice/data and total high-quality, innovative
communication solutions.
4.1.1 Licences held by Vodafone Group
In addition to access service licence in 23 service areas, Vodafone Group has carriage
licences i.e. National Long Distance (NLD) as well as International Long Distance (ILD)
and Internet Service Provider (ISP) licence.
The LSA/Circle wise service provision and related accounting activities are performed under
the aegis of the Corporate Head Office of Vodafone India Limited (erstwhile Vodafone
Essar Ltd) at Mumbai and its seven subsidiary Companies.3
4.1.2 Radio frequency spectrum held by Vodafone
All Vodafone group companies are GSM operators. LSA-wise quantum of spectrum allotted
to them as on 31 March 2010 were as follows-
Table 4.1Sl.No Spectrum (in MHz) Names of LSA
1 2 × 10 Delhi, Mumbai2 2 × 9.8 Gujarat, Kolkata3 2 × 8.2 UP(E)4 2 × 8.0 Chennai, Karnataka5 2 × 7.2 Tamil Nadu6 2 × 6.2 Andhra Pradesh, Haryana, Kerala, Maharashtra, Punjab, Rajasthan,
UP(W),West Bengal7 2 × 4.4 Assam; Bihar, Himachal Pradesh, Jammu & Kashmir, Madhya
Pradesh, North East, Odisha
1 Mumbai,Delhi,Kolkata,Gujarat ,Karnataka,AndhraPradesh,Chennai,Rajasthan,UP(E),Haryana,Punjab,UP(W),WestBengal,TamilNadu,Kerala,Maharashtra
2 Orissa,Bihar,NE,Assam,J&K,HimachalPradesh,MadhyaPradesh3 VodafoneEssarCellularLtd,VodafoneEssarDigilinkLtd,VodafoneEssarGujaratLtd,VodafoneEssarLtd,Vodafone
EssarMobileServiceLtd,VodafoneEssarSouthLtd,VodafoneEssarSpacetelLt/d.
Report No. 4 of 2016
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4.1.3 Subscriber base growth - 2006-07 to 2009-10
As on March 2007, with a subscriber base of 2.64 crore, Vodafone occupied third place
behind Bharti Airtel and the combined strength of the PSUs (BSNL and MTNL). By
2007-08, the Company established its foot print in all 23 LSAs and consolidated its position
to become the second largest GSM based cellular mobile service provider in the country.
By March 2010, the subscriber base grew to 10.09 crore with market share of 16 per cent
registering a growth of 281 per cent from 2006-07.
4.1.4 Financial data on GR/Deductions/AGR and revenue share paid by Vodafone
India Limited
Telecom Service Providers (TSPs) are required to pay LF and SUC at a percentage of AGR
on quarterly basis on self-assessment basis. The combined GR reported and revenue share
paid by Vodafone India Limited (VIL) for the four years from 2006-07 to 2009-10 is as
shown below:
Table 4.2
(` in crore)
Year GR Deductions AGRPercentage of AGR to GR
Revenue share
(LF+SUC)
2006-07 10399 1853 8545 82.17 1153
2007-08 16063 3713 12350 76.88 1606
2008-09 22217 5897 16320 73.46 2221
2009-10 25289 6695 18594 73.53 2399
Total 73968 18158 55809 75.45 7379
(Source: DoT records)
4.2 Audit verification of accounting and reporting of GR by Vodafone
As mentioned in para 1.4 (a), the GR shall be inclusive of all types of revenue stated therein
without any set-off for related item of expense, etc.
Further as mentioned in Annexure III of UASL agreements, service revenue (amount
billable) shall be shown gross and details of discount/rebate indicated separately.
Audit examination of the records alongwith the books of accounts of Vodafone revealed
incidences of non-compliance with the conditions of the licence agreement in recording
and reporting revenue. The occurrence was not universal throughout the different LSAs as
there was no uniform procedure for accounting revenue for the purpose of revenue share
payment. The nature of non-compliances were-
• Setting-offrelatedexpendituresfromrevenue.
• Non-inclusionofrevenueearnedfromallcategoriesinGR.
Report No. 4 of 2016
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Audit findings on GR computation by Vodafone for the period from 2006-07 to 2009-10 are
discussed below As no separate GLs were maintained for pre-paid and post-paid services,
no segregation of service wise understatement of revenue and revenue share impact was
done.
4.2.1 Commission/discounts to dealers netted of from pre-paid and post-paid revenue
Vodafone provides prepaid and post-paid services in their licenced network using Subscriber
Identification Module (SIMs). The sale of SIMs, Prepaid recharge vouchers (ECV), e-top
ups, etc. are through retailers/agents (dealers, franchisees, distributors) who are allowed
discounts by the Company. As per the licence conditions, GR has to include revenue from
sale of SIM/ECV, etc. without set-off.
Verification of General Ledgers (GL) of LSA-wise accounts revealed debits under certain
revenue account heads on account of expenses described as payment of ‘commission,
discount, additional margin to retailers, franchisees/dealers/agents/distributors’, ‘trade
margin’, etc., related to the sale of SIM/RCV (recharge vouchers)/Top up cards, etc.
All debits with the above descriptions under various revenue GLs were identified for
all the four years to ascertain the total amount netted off from revenue and it was seen
that a total amount of ` 1352.75 crore was debited from revenue during the period from
2006-07 to 2009-10 (Annexure- 4.01). It is important to mention here that details of cases
where revenue was captured in the Company’s financial system after net offs could not
be identified and hence audit had quantified only those transactions where the LSAs had
recorded them manually in the books of accounts with clear narratives on the nature of the
debits. Though the Company was required to report the amount netted off to DoT along
with the AGR statement it was seen that none of the LSAs except VCL4 in 2006-07 had
disclosed the amount netted off as discounts.
Management stated (May/August 2015) that the Company appoints distributors/dealers/
franchisees depending on the business needs and the arrangement with them is on
Principal-to-Principal basis from January 2007. Discounts given to them at the time of
primary billing were debited to revenue. As per the accounting policy followed, the actual
inflow to the Company i.e. the amount paid by the distributor only is carried to the Profit
and Loss Account (P & L account) and not the Maximum Retail Price of the product sold
through the distributor/franchisee/dealer. It was also explained that the sale of products to
the franchisee was on agreed price and that price is reflected in the P & L account and
there is no netting off of any expense and TDSAT also in their judgment of April 2015 had
held that there was no netting off in cases where revenue is recorded on the agreed price.
It was further informed that appeals have been filed in the Hon’ble Supreme Court, both by
the Operators and DoT, against the TDSAT judgment and hence the above positions of the
Company were subject to the final ruling by the highest Court.
4 Maharashtra&Goa,TamilNaduandKeralaLSAs
Report No. 4 of 2016
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Audit view on the reply of the management is as explained in para 3.2.1 (A).The amount
brought out in Audit is only a portion of the actual amount paid by the Company as discount/
commission to franchisees/dealers, etc. Reply confirming the LSA wise facts and figures
brought out by Audit and details on total value of upfront discounts/free air time allowed
from revenue on the discount/commission paid for the four years was awaited from the
Management (December 2015).While the matter is sub-judice at the Hon’ble Supreme
Court, Audit is of the view that netting of commission/discounts given to dealers from
revenue was a deviation from the UASL agreement and has resulted in understatement of
revenue by ` 1352.75 crore for the period 2006-07 to 2009-10 leading to short payment of
LF & SUC amounting to ` 119.59 crore and ` 53.30 crore respectively (Annexure - 4.01).
4.2.2 Airtime Discounts to customers
From the audit scrutiny of Trial Balances, furnished to audit by Vodafone, it was noticed
that the airtime discount offered to post paid subscribers as well as promo talk time given to
pre-paid subscribers were debited to a revenue heads. These heads would invariably reflect
a debit balance at the end of the year. Debit balances under a revenue GL head thus would
have the effect of a set-off from the total revenue. The total amount of set-off on account
of this accounting treatment worked out to ` 444 crore for the four years from 2006-07 to
2009-10.
The Company intimated that discounts in post-paid airtime were nothing but the amount
of usage by the customer against post-paid rental. As an illustration it was stated that if a
subscriber opts for a rental plan of ` 100 and the Company offers free talk time ` 100, the
Company would book ` 100 as rental revenue, ` 100 as usage revenue and ` 100 as Airtime
discount and there was no debit in revenue.
Free airtime given to post-paid subscriber against the rental as per tariff plans submitted to
TRAI as illustrated above was justified. Debit to revenue heads for the amount of promo
talk time given to prepaid subscribers not covered under tariff plans submitted to TRAI was
not consistent with the provisions of the licence agreement as explained in para 3.2.1 (B).
However, amount of promo talk time given to prepaid subscribers and free airtime given
to post paid subscribers could not be segregated easily as the Company had accounted it in
one GL code only.
4.2.3. Roaming revenue understated due to netting of Inter Operator traffic (IOT)
Discounts paid/credited to other Operators
Revenue earned by the different LSAs of Vodafone from roaming services was disclosed
under item no. 3 of the AGR statement. On a review of the revenue accounted under
various heads operated to account roaming revenue, debits on account of ‘discounts were
seen effected. These discounts were ultimately credited under provision for contingencies
(roaming), which was further set-off with roaming commission receivable from other
Report No. 4 of 2016
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operators. During the four years, 2006-07 to 2009-10, ` 242.69 crore, as confirmed by the
Management, was debited from revenue (Annexure - 4.02).
On being pointed out, the Company, replied that the revenue recognition on account of
roaming discount was as per AS-9 where Revenue was defined as “Revenue is the gross
inflow of cash, receivables or other consideration arising in the course of the ordinary
activities of an enterprise from the sale of goods, from the rendering of services, and
from the use by others of enterprise resources yielding interest, royalties and dividends.
Revenue is measured by the charges made to customers or clients for goods supplied and
services rendered to them and by the charges and rewards arising from the use of resources
by them…”Accordingly, the Company did not include discount allowed on International
roaming charges to international operators in the GR as such discounts were not in the nature
of revenue but were discounts on volume of international roaming traffic as agreed with the
roaming partners. Revenue from both in-roaming and out-roaming calls are recorded net
off discounts offered/received. It was also informed that TDSAT in its judgment of April
2015 had held that discounts are to be added to the revenue and the Company has preferred
an appeal against it in the Hon’ble Supreme Court of India.
Audit view on the reply of the Management is as explained in para 3.2.3 of this Report.
Further, regarding revenue recognition as per AS-9 stated by Management, Audit was not
challenging the accounting methodology adopted by the Company but for the purpose of
Licence fee, the revenue is to be recognised “Gross” without set-off of related expenses as
mandated under licence agreement. While the issue is sub-judice at the Hon’ble Supreme
Court, Audit view is that setting off discounts paid to international roaming partners from
roaming revenue was in violation of the licence conditions.
Taking into account the amount accepted by the Management as roaming discounts the
LF and SUC short paid worked out to ` 23.07 crore and ` 10.23 crore respectively
(Annexure - 4.02).
4.2.4 Understatement of GR due to Service Tax being set-off from revenue on schemes
like ‘Full Pe Full’, ‘Full Talk Time’ etc.
When the validity on the prepaid card was extended through recharge, additional talk time
through schemes like ‘Full Pe Full’/ ‘Full Talk Time’ etc., was allowed to the subscribers as
an incentive to retain the potentially floating subscriber base. As per the revenue recognition
policy of the Company, revenue from sale of recharge coupons, was recognized exclusive
of service tax and if free air time was given to customers as part of any scheme, the Service
Tax component was borne by the Company. For example, in a recharge of ` 120 customer
would be getting talk time of ` 120 where as in other normal plans the Service Tax (ST)
component would be deducted from the recharge value. So apparently, even though talk
time was allowed in full, the liability of Service Tax was being borne by the Company.
Report No. 4 of 2016
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It was seen that the revenue from schemes (Full Pe Full, Full Talk Time etc.), where FAT
was given to users, the liability of Service Tax (ST) was being deducted from outgoing
call/access revenue and revenue on account of FAT was not being recognised in GR. This
was not consistent with clause 19.1 of the UAS licence agreement. ST being allowed to
be deducted from revenue when its receipt in full for services rendered was not accounted
in GR was equivalent to revenue being understated to the extent ST paid and resulted in
Government dues being short paid.
Vodafone Management responding to the audit observation stated that the Company offers
full talk time schemes to selected customers as per various marketing schemes and these
schemes were generally informed to TRAI. In cases where full talk time was offered
customer got talk time for the full value of the recharge and revenue recorded is after
providing for service tax from the value of recharge. Talk time offered to the subscriber
was not relevant in such cases as the receipt of the amount from customer was recorded in
books as such and included in revenue and service tax paid on it.
The reply was not tenable as Audit opines that the value of the talk time availed by the
user was to be reckoned as call revenue and the admission that revenue component was
recognised after providing for service tax substantiated the fact that expenditure towards
service tax was set-off from the revenue received for the services provided by the Company.
Thus the Service Tax absorbed by the Company was the revenue foregone since it would
have been recovered from the end-users. Audit could identify the amount of service tax
paid by debiting revenue in 12 LSAs during the four years covered and this worked out to
` 222.54 crore resulting in short collection of LF and SUC amounting to ` 18.45 crore and
` 9.27 crore respectively(Annexure - 4.03).
Management (December 2015) confirmed the amount of understatement worked out in
audit.
4.2.5 Understatement of GR due to non-inclusion of revenue from Infrastructure
sharing in full
As mentioned in para 1.4 (a),the GR shall be inclusive of revenue from permissible sharing
of infrastructure and any other miscellaneous revenue without any set-off for related item
of expense, etc.
Audit noticed that during the four years from 2006-07 to 2009-10, Vodafone had invoiced
` 807 crore towards Cell sites sharing revenue but the amount included in the AGR
statements for these years was only ` 253 crore leading to understatement of GR by ` 554
crore. Audit quantified infrastructure revenue only in LSAs where invoice details were
clearly available in the accounting system. Those accounts had shown income from renting/
leasing infrastructure net of amounts received towards OPEX.
Report No. 4 of 2016
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Vodafone Management responded (September 2015) stating that the Company had entered
into arrangements with other telecom operators for sharing of infrastructural facilities and
the operational expenditure for running and maintaining such facilities were shared between
Vodafone and other operators. The arrangement was meant to defray the cost incurred
for operating the infrastructural facilities and hence the amount received from the other
operators was in the nature of their contribution towards operational expenditure and hence
do not qualify as revenue. Amount received on account of CAPEX was being included
in the GR. It was also stated that the TDSAT in its ruling of April 2015 had held that
reimbursements were not to be included in the revenue. The issue is sub- judice as appeals
have been filed in the Hon’ble Supreme Court of India on the TDSAT judgment.
Reply of the Management was not tenable in view of the following:
• Intermsoflicenceagreement,GRspecificallyincludesrevenuefrompermissible
sharing of infrastructure without any set-off for related item of expense and licence
agreements do not distinguish infrastructure sharing revenue between CAPEX and
OPEX. Hence, set-off of revenue from infrastructure sharing against the expenses
is not allowed. Revenue towards diesel expenses, security expenses, repair &
maintenance expenses and electricity charges did not constitute reimbursement since
they had to be incurred irrespective of whether the towers were shared or not. In
fact, by sharing the expenditure the company benefited through additional income.
• Further,itwasnotedthatDoThadfiledanappealbeforeHon’bleSupremeCourt
against the TDSAT Judgment dated 23 April 2015 as referred in the reply. While
the matter is sub-judice at the Apex Court, Audit view is that as UASL does not
provide for any deductions from revenue other than those permitted under Clause
19.2 deducting OPEX from infrastructure sharing revenue was not in conformity
with the UASL agreement.
The Management informed (December 2015) that the OPEX reimbursement was ` 514.49
crore in respect of cases pointed out by Audit and the reason for mismatch between the
amount worked out by Audit and validated by the Management was on account of inclusion
of service tax element also by Audit. While the fact of inclusion of service tax was accepted,
on an analysis of the reply it was seen that the amount confirmed by the Management was
short by 21.78 crore as information on one LSA (UP-W) was not included. Thus, the total
amount of OPEX not included in GR worked out to 536.27 crore leading to short payment
of LF and SUC of ` 46.90 crore and ` 21.02 crore respectively (Annexure - 4.04).
4.2.6 Under reporting of revenue from forex gains for GR/AGR
Audit noted that the Company accounted its gain/loss under five account heads (in four
revenue heads and one expenditure head). Audit scrutiny of the Trial Balances, Audited
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AGR statements Auditors Report, Notes on Accounts/Statements and Revenue Reconciliation
Statements etc. revealed that different LSAs of the Company followed different methods in
recording their Forex transactions as detailed below:
• AmountsnetofgainorlosswereshownintheRevenueReconciliationStatements
only
• Net forex loss was debited in the AGR under different types of income viz.,
miscellaneous income, any other income etc.
• AnetamountwasshownintheirAGRinwhichcaseithadadirectimpactonthe
revenue share paid.
Foreign exchange gain realised by the various LSAs during 2006-07 to 2009-10 was
` 155.44 crore but these gains were not offered for revenue share in these years. Audit could
not arrive at the actual value of items accounted under realised gain every year for want of
original value of each item as brought out in para 3.2.5. Further, Audit has considered the
net gain, head of account-wise and LSA-wise, as it was not possible for Audit to segregate/
collect the figures of gains only from the data made available. Interim gains if any, was not
considered. Vodafone Management replied (September 2015) that-
• The income from fluctuations in foreign exchange(s)was notional in nature and
not revenue. The accounting standards require this notional gain or loss on forex
fluctuations to be accounted at the end of the year so that the profit/loss of the
company was fairly stated as on the balance sheet date. It is reiterated that in
respect of cost or purchase items like operating expense on account of consultancy,
purchase of equipment or loan taken in foreign currency, the fluctuations due to
foreign currency do not form part of revenue as such fluctuations ultimately result
in increase or reduction in cost or purchase price and have no linkage with the
revenues.
• TDSAT(April2015)hadruledthatForexgainsarenottobeincludedintheAGR.
Contention of the Management was not acceptable. Audit view on the treatment of forex
gains for revenue share has been explained under Para 3.2.5 of this Report. Audit noted that
DoT had gone on appeal against the TDSAT judgement of April 2015. While the matter is
sub-judice at the Hon’ble Supreme Court, Audit view is that forex gains should be a part
of the GR computed for payment of revenue share since it falls within the broad definition
of GR given in the UASL agreement.
Short payment of LF and SUC on account of the deviation from licence conditions worked
out to ` 14.19 crore and ` 6.12 crore respectively (Annexure - 4.05).
Report No. 4 of 2016
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4.2.7 Debits from revenue as Waiver- Goodwill waiver, rebates etc.
Review of revenue of Vodafone revealed debits on account of ‘waiver’ from revenue
captured under ‘Access Fee’; ‘Itemized Billing Rental’; ‘Caller Tune Rental’ etc. leading
to understatement of revenue. During the four years under audit coverage, an amount of
` 105 crore was seen set-off from revenue in eleven LSAs5.
Waiver was an inducement or supplemental reward given by the Management of a Company/
service provider- to a client/subscriber which serves as a motivational device for a desired
action or behaviour. This could be in the form of concession in rates, waiver of a percentage
of the dues etc. Deducting the revenue foregone in this process from GR was a deviation
from the conditions of licence agreement. Management (December 2015) confirmed that
only ` 7.87 crore was set-off towards Waiver but year wise/LSA wise details of the amount
was not provided to audit. It was also informed that waivers as pointed in audit pertained
to billing disputes and the same were not added to revenue. TDSAT also had ruled that in
case a subscriber was billed wrongly, discounts given for such wrong billing was a revision
of bill and hence cannot be a part of GR.
The justification that all the waivers were on account of wrong billing is not accepted by
audit as in no cases the descriptions of the transactions as appeared in the documents/
records made available to Audit mentioned billing errors. Waivers on other accounts should
not be deducted from revenue as explained under para 3.2.2 of this Report. The setting
off of waivers from different GL codes led to short payment of ` 0.63 crore towards LF
and ` 0.31 crore towards SUC (Annexure - 4.06). In the absence of year wise/LSA wise
details, Audit computed the LF and SUC impact by apportioning the amount confirmed by
the Management amongst the LSAs where the set-off was noticed proportionate to their GR
for the relevant years. DoT may get the details from the PSP for the balance amount of
` 97.13 crore as seen in audit and ensure that there was no short payment of revenue share.
4.3 Other Income not included in Gross Revenue
Review of the reconciliation statements with the trial balances, audited AGR statements and
notes on accounts prepared by the Statutory Auditors submitted along with Auditors’ Report
and comparing them with primary accounting records of all the LSAs for the years 2006-07
to 2009-10 showed that income under some categories appearing in the company’s accounts
were not considered for computation of GR/AGR and payment of revenue share. These
revenues, though should have been a part of GR for revenue share payment was included
separately in reconciliation statements thereby avoiding payment of revenue share on them.
Income thus excluded are discussed below:
5 GLcodesinLSAswithclearmentionas‘waiver’onlyhasbeenincluded.Hencetheamountset-offcannotbetakenasabsolute
Report No. 4 of 2016
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4.3.1 Interest Income
Vodafone had accounted Interest income under different account heads. Audit noticed that
Vodafone had included interest Income in full in the GR/AGR in the year 2006-07 but
during the years 2007-08 and 2008-09 the income was only partially captured in the GR. In
the year 2009-10, income on this account was not at all included for payment of LF/SUC.
The extent of interest income not included in the GR/AGR during the four years from 2006-07
to 2009-10 worked out to ` 2741.37 crore.
Vodafone management replied that the company was of the view that interest on
inter-corporate loans and interest from banks on short term deposits cannot be treated
as revenue generated from service. The matter was sub-judice (September 2015) as the
Company had filed an appeal in the Hon’ble Supreme Court of India against the TDSAT
ruling (April 2015) which held that interest income was to be added to revenue.
Vodafone management (December 2015) accepted that interest income of ` 2738 crore was
not offered for revenue share against the figure of ` 2741.37 crore as pointed out by audit.
However, the Management did not provide details of the difference in figures as pointed out
in audit and confirmed by it. In the view of Audit, licence agreement expressly provides for
inclusion of interest income for GR/AGR for computation of revenue share. LF impact due
to the non-inclusion of interest income of ` 2741.37 crore worked out to ` 250.73 crore and
the impact on SUC worked out to ` 105.30 crore (Annexure - 4.07).
While the matter is sub-judice at the Hon’ble Supreme Court, Audit view is that interest
income should be part of the GR of the Company as per the conditions of UASL.
4.3.2 Income received on profit of Sale of fixed assets not included in GR
Audit observed from the LSA-wise books of accounts6 that ‘profit on sale of fixed assets’
by Vodafone during the years 2006-07 to 2008-09, was not considered for computation
of GR/AGR in the respective years and was reported only in the ‘Revenue Reconciliation
Statement’. Further, as income was taken net of loss from sale under the category, in cases
where loss exceeded gains in any year, the gains were not included in the GR. Total “profit
on sale of fixed assets” received during the years 2006-07 to 2008-09 but not considered
for payment of revenue share worked out to ` 200.81 crore.
Vodafone management stated that in the financials, the net profit or loss on sale of capital
assets during a year was shown as one net item and profits if any, were in the nature of
capital assets. It was also stated that TDSAT had upheld the views of the Company in its
ruling of April 2015. The management confirmed (December 2015) that an amount of
` 200.76 crore was not considered while computing GR for revenue share payment against
6 Company Trial Balance, Audited AGR statements, Auditors Report, Notes on Accounts / Statements and Revenue Rec-onciliation Statements etc.
Report No. 4 of 2016
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` 200.81 crore as pointed out by audit. However management did not provide details of the
difference in figures.
The opinion of the company was not acceptable as:
• Thesourcefromwhichanassetwaspurchasedhasnorelevanceinthecontextof
the conditions in the licence agreement.
• Definition of GR in licence agreements expressly provides for inclusion of
miscellaneous income in GR/AGR for computation of revenue share.
• RegardingTDSATjudgmentof23April2015,auditnotedthatanappealwasfiled
by DoT before Hon’ble SC against the judgment.
While the matter is sub-judice at the Hon’ble Supreme Court, Audit view is that profit from
sale of fixed assets should be a part of the GR of the Company as per the conditions of
UAS licence.
Non-consideration of profit from sale of fixed assets in the GR had led to short payment of
` 19.45 crore towards LF and ` 8.72 crore towards SUC (Annexure - 4.08).
4.4 Bad debts deducted from GR
On a review of the AGR statements submitted by Vodafone during 2007-08 to 2009-10, it
was noticed that deduction on account of bad debts were being claimed and revenue share
was being paid only on the AGR arrived at after such deduction.
Total amount of bad debts deducted from revenue came to ` 311.91 crore which had an
adverse impact of ` 29.55 crore on LF and ` 13.02 crore on SUC paid for the three years
(Annexure - 4.09).
Definition of GR/AGR does not permit for deduction of expenses on account of bad debts
written off.
The Management, in response, stated that:
• Underthelicenceagreement,baddebtsarenotrequiredtobeaddedtoAGR.Bad
debts represent income that has not been received and is notional in nature and hence
cannot be considered as revenue.
• TDSAThadheld(April2015)thatbaddebtsaretobeaddedtorevenueandthe
Company had filed appeal in the Supreme Court against the TDSAT ruling.
The contention of the Management was not tenable, as:-
• ThelicenceagreementdoesnotprovidedeductionofbaddebtfromGRtoarriveat
AGR.
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• Though theCompany has filed an appeal against the TDSAT judgment and the
matter is subjudice at the Hon’ble Supreme Court, Audit is of the view that since the
licence agreement permits only three deductions from the GR, deducting bad debts
from the AGR was not in conformity with the licence conditions.
4.5 Transfer of assets to subsidiary Company
Vodafone Essar Infrastructure Limited (VEIL) was incorporated in 2007 as a fully owned
subsidiary of Vodafone India Limited. The main objective VEIL was to provide infrastructure
service to telecommunication operators, including construction, leasing and maintenance of
passive infrastructure assets. As per the Scheme of Arrangements approved by the various
jurisdictional High Courts, Vodafone East Limited (VEL) (20 October 2009) and Vodafone
Cellular Limited (VCL) (17 November 2009), the passive infrastructure assets of these two
companies were to be transferred to VEIL without any consideration.
The appointed date of the Scheme was from April 2009. Though the effective date for the
transfer of assets for the two companies was November 2009, the financial impact of the
transfer of passive infrastructure was not reflected in their 2009-10 annual accounts as per
the Annual Reports of VCL, VEL and VEIL.
Further, the assets transferred to VEIL were yet to be revalued as of 31 March 2010 as
seen from the Annual Report of VEIL. Due to non-revaluation of the assets transferred as
of 31 March 2010, the difference between the fair value (after revaluation) and book value
could not be ascertained as in case of BAL (Para No. 3.5). In the absence of the same,
profit foregone on transfer of assets that would have accrued to VEL and VCL could not
be ascertained. Further, transfer of assets at NIL consideration was not an arm’s length
transaction.
Audit could not ascertain the impact of the transfer of assets at NIL consideration on
computation of LF and SUC for want of details.
4.6. Interest on revenue share short paid
On issues raised above (from paras 4.2 to 4.5) short/non-payment of LF and SUC
worked out to ` 522.56 crore and ` 227.29 crore respectively. The interest on this short/
non-payment of LF and SUC was ` 915.54 crore (Annexure-4.10). The calculation of
interest was based on the rate prescribed in the Licence agreement i.e. 2 per cent above the
Prime Lending Rate of State Bank of India existing as on the beginning of the financial year
and the period considered for the calculation was from the end of the concerned financial
year up to March 2015. The interest has been compounded monthly as prescribed in the
licence conditions.
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4.7. DoT’s response to the audit observations
Audit observations on the revenue shared by Vodafone India were communicated to DoT
in August 2015. DoT in reply (January 2016) informed that demands for understatement of
GR as pointed out in paras pertaining to Commissions/discounts to dealers netted off from
revenue (4.2.1); understatement of GR on airtime discount to subscribers (4.2.2); roaming
revenue understated due to netting of inter-operator traffic discounts paid to other operators
(4.2.3); understatement of GR due to non-inclusion of revenue from Infrastructure sharing
in full (4.2.5); under reporting of revenue due to non-inclusion of revenue/income in GR/
AGR from forex gain (4.2.6) and Interest Income (4.3.1) were raised on the PSP in 2012
for the years 2006-07 and 2007-08, based on the report of the Special Audit conducted
in 2009. But the demands have been challenged by the operator in TDSAT in 2012. The
matter was sub-judice. It was also informed that action will be taken as and when the final
court judgment is pronounced.
Thus, DoT agreed to the issues raised by Audit. However, it pleaded helplessness in
realising the revenue from Vodafone India on account of these issues being sub-judice.
Considering that a substantial amount of government revenue is blocked for many years on
account of litigation, DoT should play a proactive role in getting these legal issues settled
at the earliest.
DoT also pointed out to the variation in the amounts quantified by CAG and the demands
raised by DoT as a consequence of the Special Audit in its reply. These variations could
be on account of the differences in methodology adopted in quantifying the understatement
of revenue. Audit has determined the understated amounts on the basis of actual entries
identified through clear descriptions in the books of accounts of Vodafone India for
2006-07 to 2009-10. However, details of working papers of Special Auditors were not seen
by CAG audit.
In respect of paras 4.2.4 and 4.2.7 of this Report, pertaining to understatement of GR due
to service tax being set-off from revenue on schemes like ‘Full Pe Full’, ‘Full Talk Time’
etc. and debits from revenue as Waiver - goodwill waiver, rebates etc. respectively, DoT
stated that it has sought the response of the Company on the audit observations and action
would be taken after examining them.
On the audit observation mentioned under Para 4.3.2 on Income received on profit of sale
of fixed assets not included in GR, it was informed that demands in respect of seven LSAs
have been prepared and are in the process of issue to the Operator and demands for the
remaining circles would be issued soon.
For Para 4.4 on bad debts deducted from GR, DoT stated that “as correctly pointed out
in CAG report the deductions on account of bad debts is not permitted in the revenue and
Report No. 4 of 2016
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licence fee statement..... DoT does not permit such deductions at the time of verification
and the amounts so claimed are being added back to GR/AGR at the time of assessment”.
In respect of para relating to transfer of passive infrastructure (4.5), reply from DoT was
awaited.
DoT also stated that the basic definition of GR and AGR was challenged by the TSP’s in
2002-03. Since then, there has been protracted litigation and is continuing till date. Also,
some of the licensees have filed (in 2012) writ petitions before various High Courts invoking
the writ jurisdiction under Article 226 of the Constitution challenging the Section-4 of
Indian Telegraph Act, 1885, as violative of the Article 14 and 19 (1) (g) of the Constitution
of India. The process of deduction verification by the CCA offices and the LF assessment
work by the DoT Headquarters was adversely impacted due to this. DoT admitted that
the numerous disputes are causing delays in assessment of the revenue share due from the
operator.
The response of DoT prove that though the revenue share regime was introduced as part of
NTP 1999, the Department has not been able to realise its due revenue share as envisaged
in the licence agreement even after more than 16 years of its implementation.
Report No. 4 of 2016
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Chapter VRevenue shared by M/s Reliance Communications Limited and
M/s Reliance Telecom Limited
5.1 Brief Profile of M/s Reliance Communications Limited (RCL) and Reliance
Telecom Limited (RTL).
Reliance Infrastructure Developers Private Limited was incorporated on 15 July 2004 as
a private limited company. During July-August 2005, the company changed its name to
Reliance Communication Ventures Limited (RCoVL) and converted into a public limited
company. In March 2006, RCoVL merged with Reliance Infocomm Limited (RIC) which
had originally obtained telecom licences in 1997 and renamed as Reliance Communications
Limited (RCL) (June 2006).
Reliance Telecom Limited (RTL) was incorporated on 1 March 1994.
5.1.1 Licences granted to RCL and RTL
RIC obtained its first licence for Basic Services (Basic licence) in Gujarat in September
1997 and basic licences in eighteen1 more LSAs in July 2001. These basic licences migrated
to UASL in November 2003. It obtained UASL for Jammu and Kashmir in September
2004. Thus by September 2004, RCL (formerly RIC) held UASL in all LSAs except Assam
and North East. It also obtained NLD and ILD licences in January-February 2002.
RTL obtained original CMTS licences in seven2 LSAs in December 1995 (migrated
to UASL in October 2007) and acquired one more CMTS licence in Kolkata in
September 2001 (migrated to UASL in April 2009). Thus, both RCL and RTL were
simultaneously holding UAS and CMTS Licences respectively in six LSAs of Bihar, HP,
MP, Kolkata, Orissa and WB.
Reliance Communications Infrastructure Limited (RCIL) and Reliance WiMax Ltd, both
subsidiaries of RCL, hold ISP licences and another subsidiary, Reliance Infratel Ltd (RITL)
(Formerly in 2006-2007 known as Reliance Telecom Infrastructure LTD (RTIL)) had
registration for IP-I services.
5.1.2 Spectrum allotted to RCL/RTL
Initially RCL was a CDMA operator whereas RTL was a GSM operator. In 2008, RCL
obtained GSM spectrum and RTL got CDMA spectrum and hence they provide services
on dual technology3. LSA wise spectrum allotted to RCL/RTL as on 31 March 2010 was
as follows:
1 AP, Bihar, Delhi, Haryana, HP, Karnataka, Kerala, Kolkata, MP, Maharashtra, Mumbai, Orissa, Punjab, Rajasthan, Tamil Nadu, UP (E), UP (W), WB,
2 Assam,Bihar,HP,MP,NE,Orissa,WB.3 ThoughRTLobtainedCDMAspectrumbutitdidn’tprovideservicesusingCDMAspectrum.
Report No. 4 of 2016
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Table 5.1
Reliance Communications LimitedSl.No. Technology Spectrum Licenced Service Area1 GSM 2 × 4.4 MHz Andhra Pradesh, Delhi, Gujarat, Haryana, J&K,
Karnataka, Kerala, Maharashtra, Mumbai, Punjab, Rajasthan, TN, UP(E) and UP(W)
2 CDMA 2 × 5 MHz Andhra Pradesh, Bihar, Delhi, Karnataka, Kerala, Kolkata, MP, Maharashtra, Mumbai, TN, UP(E) and UP(W)
3 CDMA 2 × 3.75 MHz Gujarat, Haryana, Orissa, Punjab, Rajasthan, WB
4 CDMA 2 × 2.5 MHz HP, J&K
Reliance Telecom Limited
1 GSM 2 × 8 MHz Bihar
2 GSM 2 × 6.2 MHz HP, Assam, MP, Orissa, Kolkata, NE, WB
3 CDMA 2 × 2.5 MHz Assam, NE
5.1.3 Subscriber base of RCL/RTL
RCL provides both wireless and wireline services whereas RTL provides only wireless
services. Wireless subscribers of RCL/RTL increased from 2.80 crore as on March 2007 to
10.24 crore as on March 2010 and wireline subscribers of RCL increased from 0.06 crore
to 0.12 crore during the period. The market share of Reliance Group was 14 per cent as on
March 2007 which increased to 17 per cent as on March 2010.
5.1.4 Gross Revenue (GR), Deduction, Adjusted Gross Revenue (AGR) reported and
revenue share paid by RCL/RTL
As brought out in Para 1.5, Telecom Service Providers are required to pay LF and SUC
at a percentage of AGR on quarterly basis on self-assessment basis. The GR, Deductions
and AGR of RCL/RTL for the years 2006-07 to 2009-10 are as shown in the table below.
Table 5.2
(` in crore)
Year GR Deductions AGRPercentage of AGR to GR
Revenue Share (LF + SUC)
2006-07 14264 4229 10035 70.35 1043
2007-08 16997 5158 11839 69.65 1229
2008-09 17507 5557 11950 68.26 1249
2009-10 17392 6000 11392 65.50 1163
Total 66160 20944 45216 68.34 4684
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5.1.5 Arrangement between RCL and its subsidiary RCIL for Value added Services,
Selling/Marketing and Billing:
RCL and its subsidiary RCIL entered into Value Added Services (VAS) and Selling/Marketing
agreements as detailed below to carry out their business:
i) Value Added Services (VAS) agreement:
Reliance Communications Infrastructure (RCIL) is a subsidiary having ‘A’ category ISP
licence and is in the business of providing internet, miscellaneous applications, content and
other allied services under the brand names R Connect, R World, Reliance World, 1234,
2345 and SMS content services. An agreement was signed between RCL (UAS Licence
holder) and RCIL in April 2006 for three years and was subsequently extended up to March
2012.
As per this agreement, RCIL was to provide all the above services to RCL’s subscribers
and RCL would provide the access services required to facilitate the same.
‘R Connect’ is an internet service and the same is provided to RCL subscribers through
dial up. As per the agreement, the revenue was to be shared between RCIL and RCL for
‘R Connect’ services.
‘R world’ is a one-stop-shop for applications and content which include mobile TV, videos,
games, cricket updates, music and ring tones, etc. As per the agreement, revenue was to
be shared between RCL and RCIL for applications and content services (including ‘SMS’
or ‘MMS’ based applications and content services).
ii) Selling and marketing agreement:
RCIL also entered into a selling and marketing agreement with RIC (subsequently RCL) in
October 2004 valid up to September 2007. This agreement was renewed in October 2007
between RCIL and RCL for a further period of 3 years.
The term ‘business’ was defined under Section I of the agreement as the means of marketing
of RCLs services or various tariff plans relating to telecommunications services offered by
RCL including fixed wireless terminals/fixed wireless phones, etc., and any other services
to be provided by RCL from time to time.
Clause 2.3 stated that while marketing the services, RCIL was free to bundle the tariff
plans of RCL with other products or services as it deemed fit and offer composite schemes
to customers.
Clause 2.4 stated that RCIL, if required could enter into agreements with distributors,
retailers or any other person for promotion of the schemes and services.
As per Clause 2.8, nothing contained in the said agreement shall deem RCIL to be a telecom
service provider and in no circumstances shall RCIL be a reseller of RCLs services.
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Under Clause 3.9, RCIL shall on behalf of RCL, bill and collect the amount due from
RCL’s subscribers. For this purpose, RCIL shall procure and install all billing and other
software and necessary infrastructure as directed by RCL from time to time.
The fees for the marketing, billing and collection were detailed in Clauses 7.1 and 7.2
of the agreement. Thus through this arrangement RCL effectively diverted a significant
non determinable portion of revenue to a subsidiary resulting in avoidance of payment of
LF and SUC on such diverted revenues.
5.2 Under reporting of Gross Revenue in the books of accounts of Reliance
Communications Limited (RCL)/Reliance Telecom Limited (RTL)
As mentioned in para 1.4 (a), the GR shall be inclusive of all types of revenue stated therein
without any set-off for related item of expense, etc, and as brought out in Para 1.5, service
revenue (amount billable) shall be shown gross and details of discount/rebate indicated
separately.
Audit examination of records/books of accounts of RCL/RTL and its related subsidiaries
revealed that these companies had not adhered to the provisions of the licence agreement as
discussed in following paragraphs.
5.2.1 Booking of Prepaid Revenue net of Free Air Time/Commission by RCL/RTL
Audit examination of records/books of accounts of RCL/RTL for the years 2006-07 to
2009-10 revealed that
• FreeAirTime(FAT)giventosubscriberswasnotaccountedforinthefinancial
systems at all.
• Revenueaccountedwasnetofcommissiongiventodistributors/agentswhichwasin
violation of the licence agreement.
On being pointed out by audit, Management replied that
• Tariffmeansratesandrelatedconditionsw.r.t.rentals,deposits, installationfee,
free call usage charges and any other related fees or service charge. This shows that
while any tariff was introduced, it was essential that tariff should include details
of free minutes. As free minutes were not chargeable and billable, same cannot be
considered for revenue. Company are not generating any revenue from such free
minutes hence no question of any revenue/business promotion expenses does arise.
• Freetalktime/freeairtimewerenotinnatureofdiscountsandrebatehencethere
was no need to account for or to show the same in accounts. It’s a service to
subscriber free of cost and no revenue was earned from free talk time/free air time
and hence cannot be considered as rebate/discount.
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• Hencesuchminuteswereeliminatedinbillingcycleforchargingtosubscriberas
the same were offered free of charge to subscribers.
• Consideringvalueoffreetalktime/freeairtimewasnotcorrect.TDSATalsovide
its judgement dated 23 April 2015 very categorically held that inflow should be real
and income should not be notional.
• InthiscasenorealinflowtotheCompanyandnovaluewasearnedbytheCompany;
hence it was justified not to include free minutes in billing to subscribers.
The reply of the management is not tenable as –
• Freetalktime/freeairtimeoverandabovethetariffplanssubmittedbytheCompany
to TRAI was in the nature of business promotion activity, cost of such offers amount
to expenses. Further in view of provisions of UASL agreement, service revenue
should be shown in gross without any set off. It should be booked separately in the
books of accounts and should not have been eliminated at “Mediation level4”. While
noting that the TDSAT judgment dated 23 April 2015 referred by the Management
in its reply has been challenged in the Hon’ble Supreme Court by DoT in July 2015,
Audit is of the view that elimination of free talk time at mediation level itself and
not showing it in books of accounts was in violation of the licence agreement.
• Similarly,nettingoffofcommissiongiventodistributors/agentswasalsoinviolation
of the agreements.
Though DoT was aware of the accounting of RCL/RTL through the notes/schedules of
annual reports, no action was found to be taken to prevail upon the Company to furnish the
GR as mandated in the Annexure III of the licence agreement.
5.2.2 Booking of revenue by RCL net of commission given to its subsidiary (RCIL)
and booking of revenue in the subsidiary (RCIL) books of accounts instead of
RCL’s accounts
Reliance Communications Infrastructure Limited (RCIL) which had got Category “A” ISP
licence was a wholly owned subsidiary of RCL during the years 2006-07 to 2009-10. As
detailed in para 5.1.5, RCL and RCIL entered into agreements for providing Value Added
Services (VAS) to RCL’s subscribers and Selling/ Marketing products of RCL by RCIL.
Consequent to these agreements, revenue from VAS was accounted in the books of RCIL
and only a portion of the total revenue was passed on to RCL. By this arrangement, RCL
paid LF only on the portion of revenue passed on by RCIL and not on GR earned from
subscribers of VAS which was in violation of the licence agreement.
4 A mediation device is a network component in Telecom network that receives, processes, reformats and sends infor-mation to other formats between network elements and are commonly used for Billing and Customer Care systems.
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Also, the revenue earned towards sale of handsets working under CDMA technology which
cannot be independent from telecom service, Subscribers Identity Module (SIM) cards and
installation charges from subscribers which were essential telecom services, was accounted
in RCIL’s books of accounts. Total understatement of GR by RCL owing to its arrange-
ment with its subsidiary (RCIL) worked out to ` 5594.63 crore. The income booked in the
RCIL’s accounts instead of RCL’s has been apportioned among the UAS licences on the
basis of percentage of GR for calculation of impact on short/non-payment of LF and SUC
on the basis of rates applicable for respective service areas. Audit considers this to be the
most suitable and conservative method of determining the under reporting of revenue share.
Details are furnished in following paragraphs:-
(A) Commission/discount paid to RCIL by RCL for selling and marketing of its
services netted off from its revenue for computation of GR/AGR.
As per the marketing agreement between RCL and RCIL, RCIL was an agent and autho-
rized person for selling the product of RCL. As per the agreement, RCL would sell the
prepaid vouchers to RCIL at the rate as agreed from time to time and RCIL would sell the
same to its distributors at the same net price.
From the books of accounts of RCIL for the period from 2006-07 to 2009-10, it was found
that the discount/commission received by RCIL from RCL amounting to ` 1170.51 crore
for selling its product was shown as “Billing Income” which was in turn the commission
paid to the distributors by RCIL. However, RCL had netted of the commission/discount
paid to RCIL on sale of prepaid cards and only the net realized value was accounted as
revenue that was considered for AGR.
The value of commission/discount given to distributors/agents for sale of pre-paid products
(SIM cards/recharge vouchers) was to be treated as business expenses by RCL and the gross
value of the prepaid cards i.e. the value of the telecommunications service being provided
by the operator (RCL) was required to be considered as revenue without any set off.
On being pointed out by Audit, it was replied by the management that-
• Thearrangementwasprincipaltoprincipal.Theinvoiceswereissuedtothedistributor
on agreed price and the same is considered as revenue.
• InclusionofnotionalincomeintheformofdiscountonprepaidvouchersinAGR
was not tenable. Only realized value to be considered in the AGR.
The reply of the management is not tenable as
• RCILwasanagentofRCLunderamarketingagreementandasclearlymentioned
in the agreement, RCIL shall not be deemed to be a telecom service provider and
in no circumstances RCIL be a reseller of RCLs services. The transaction between
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RCIL and RCL were in the nature of distributor acting on behalf of the company and
in substance there exists a principal to agent relationship only as explained in para
3.2.1 (A).
• Discount paid on prepaid vouchers was not a notional income as stated by the
Management in its reply. Discount paid was marketing expenses.
While the matter is sub-judice at Hon’ble Supreme Court, Audit view is that netting of
commission/discount paid to RCIL on sale of prepaid cards was against the UAS licence
agreement and hence GR/AGR of RCL for the years 2006-07 to 2009-10 was understated
by ` 1170.51 crore resulting in short payment of LF and SUC by ` 106.88 crore and
` 30.88 crore respectively (Annexure - 5.01).
(B) Non consideration of gross value of revenue on account of R world and SMS
content services in the GR/AGR of RCL
As mentioned in para 1.4 (a), the GR shall be inclusive of revenue from VAS along with
other revenues stated therein without any set-off for related item of expense.
RCL provides telecommunication services under UASL. RCIL, a wholly owned subsidiary
of RCL, having ISP licence provided internet, miscellaneous content and other allied services
under the brand names ‘R Connect’, ‘R world’, ‘Reliance world’, ‘1234’, ‘2345’, and
‘SMS content services’. As stated in para 5.1.5, RCL and RCIL have entered into agreement
for providing VAS to RCL subscribers.
On scrutiny of the books of accounts of RCIL and RCL, it was observed that as against
revenue from RCL’s subscribers on account of VAS (R World and SMS content services)
amounting to ` 1273.45 crore booked in the accounts of RCIL, only ` 265.58 crore was
passed on to RCL. Hence ` 265.58 crore only was considered in GR/AGR of RCL for
computation of revenue share.
On being pointed out by audit it was replied by the Management that VAS (R world and
content SMS) providers are neither regulated nor licenced and they mainly act as channel
partners to mobile network. RCIL had paid relevant access charges to RCL on which RCL
had already paid the licence fee and hence question of additional licence fee does not arise.
The reply of the management is not tenable as R World and SMS content services are varied
bundle of VAS over SMS, voice etc. When the content delivery was not over the internet
but over SMS and voice etc., the same was not within the scope of ISP licence held by
RCIL. VAS to subscribers could be provided by only UAS/CMTS licensee. Hence, the
GR from subscribers on account of VAS should be booked in RCL’s accounts and to be
included in the GR for computation of revenue share. Any amount payable to RCIL, being
VAS/ content service provider, should be charged to expense in RCL’s accounts.
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Hence, the revenue of ` 1007.87 crore (` 1273.45 – ` 265.58) should have been included
in GR/AGR by RCL.
The Impact on short payment of LF and SUC on this account was ` 91.99 crore and
` 26.76 crore respectively (Annexure - 5.02).
(C) Non-inclusion of revenue from Caller Ring Back Tones for computation of GR/
AGR by RCL.
Caller Ring Back Tones (CRBT) is a type of VAS that was introduced by RCL for its
subscribers and intimated to TRAI (May 2006). As explained in above paragraph, revenue
from VAS should be included in GR/AGR.
On scrutiny of the books of accounts of RCIL and RCL for the years 2006-07 to 2009-10, it
was observed that the revenue of ` 540.84 crore pertaining to CRBT was booked in RCIL’s
books of accounts. No revenue from CRBT was found to be booked in RCL’s books of
accounts. Thus, non accounting of ` 540.84 crore in the books of RCL resulted in under
reporting of GR/AGR.
On being pointed out by Audit, it was replied by the Management that the CRBT service
was introduced by RCL for its subscribers in May 2006 for only one month on promotional
basis. When this service was launched on commercial basis, the same was provided by
RCIL under VAS/content services (R World services). RCIL was providing content
services on standalone basis as separate legal entity. No licence is required to provide
content services.
The reply is not tenable as CRBT is a VAS provided over SMS and voice, etc. and
Audit opines that this could be provided only by UASL/CMTS licensee. Thus revenue from
CRBT (VAS) should be included in GR for computation of revenue share.
Hence, the revenue of ` 540.84 crore from CRBT should have been included in GR/AGR
by RCL. The impact on short payment of LF and SUC on this account was ` 49.34 crore
and ` 14.40 crore respectively (Annexure - 5.03).
(D) Non-inclusion of revenue from sale of SIM cards for computation of GR/AGR
by RCL.
As stated in para 5.1.5, RCIL, a wholly owned subsidiary of RCL and having Category
“A” ISP licence entered into an agreement with RCL for selling/ marketing products of
RCIL.
During the course of audit of accounts of RCL and RCIL for the years from 2006-07 to
2009-10, it was found that the revenue from sale of SIM cards amounting to ` 103.17 crore
were booked in the accounts of RCIL for the years 2008-09 and 2009-10.
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SIM card is an integral part of telecom services without which service cannot be activated.
SIM cards cannot be sold as goods, independent from the services provided by the UAS
licensee. SIM cards on its own without the services would hardly have any value. Further,
even in terms of selling and marketing agreement between RCIL and RCL, RCIL was not
a telecom service provider and in no circumstances RCIL would be a reseller of RCL’s
services.
Hon’ble Supreme Court of India in its judgment dated 4 August 2011, in an appeal by
IDEA Mobile Communications Ltd. versus Commissioner of Central Excise and Customs,
Cochin held that the amount received by the cellular company from its subscribers towards
SIM card would form part of the taxable value for levy of service tax, for the SIM cards
were never sold as goods independent from services provided.
In view of all the above facts, the value of SIM cards sold should form part of the GR of
RCL who was a telecom service provider and not with RCIL, an ISP licence holder and a
subsidiary of RCL.
The impact of short payment of LF and SUC on this account was ` 9.40 crore and
` 2.69 crore respectively (Annexure - 5.04).
Reply to an Audit observation issued to the company (May 2015) in this regard was awaited
(January 2016).
(E) Non-inclusion of revenue from sale of handsets for computation of GR/AGR by
RCL
As mentioned in para 1.4 (a), the GR shall be inclusive of sale proceeds of handsets (or any
other terminal equipment etc.), along with other revenues stated therein without any set-off
for related item of expense.
As stated in para 5.1.5, RCIL, a wholly owned subsidiary of RCL and having category
“A” ISP licence, had entered into an agreement with RCL for selling/ marketing products
of RCIL.
During the course of audit of accounts of RCL and RCIL for the years 2006-07 to 2009-10,
it was found that the revenue from sale of CDMA handsets amounting to ` 2523.95 crore
were booked in the accounts of RCIL for the years 2006-07 to 2009-10. No revenue on
account of sale of handsets was booked in RCL.
It was observed from the tariff plans submitted to TRAI during April/June 2006 that
RCL offered bonus talk time to prepaid customers on selected handsets (CDMA) models.
Further, internal correspondences within the Company during 2006, 2007 and 2009 showed
that the handsets were bundled with schemes offered by RCL.
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On being pointed out by Audit, it was replied by the Management that-
• RCLwasnotdealinginhandsetsale.AllsalesarebyRCILthroughitsdistributors/
dealers and not to any customers.
• NofreeminutesaregivenbyRCILtothedistributors/dealers.RCLprovidesfree
promotional minutes on activation by the subscribers as a promotional offer. Since
these are free minutes, no revenue was accrued to RCL.
• Saleofhandsetsdoesnotrequireanytelecomlicence.RCILhadnotdonebundling
as RCIL had not shared any handset revenue with RCL.
• AsperAugust2007judgmentofTDSAT,‘bundlingoftelecomserviceswillmean
that if somebody buys from a company and that company give concession in services
or reduce monthly rental’.
• AsperHon’bleSupremeCourtverdict,itisopentothelicenseesnottoundertake
activities for which they do not require telecom licence and shall transfer these
activities to any other person, firm or company.
The reply is not tenable as-
• ThoughRCILsoldthehandsetsonbehalfofRCLasperthemarketingagreement
entered between them, sale of handsets and rendering of services under the CDMA
technology were not independent activities but an integral part of telecom activity
under UAS Licence. Hence sale of handsets (CDMA) by RCIL in the guise of
selling and marketing agreement between it and its holding company RCL could not
be termed as an independent non licenced activity. Hence the entire revenue on sale
of handsets should be considered for revenue sharing.
• RCLprovided various concessions to the customers/distributors and bundled the
services and RCIL is only selling the handsets on behalf of RCL as per the marketing
agreement.
• Auditisnotstatingthatsaleofhandsetswasalicencedactivitybutcontendsthatunder
CDMA technology, sale of handsets and rendering of services were inseparable.
• TDSAT judgment of August 2007 was set aside by Hon’ble Supreme Court in
October 2011.
Hence, the revenue from sale of handsets (CDMA) of ` 2523.95 crore should be included
in the GR/AGR of RCL. The impact on short payment of LF and SUC on this account was
` 231.64 crore and ` 64.51 crore respectively (Annexure - 5.05).
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(F) Non-inclusion of revenue from installation charges of Fixed Wireless Phone/
Terminal (FWP/T) in subscribers’ premises for computation of GR/AGR
by RCL.
As mentioned in para 1.4 (a), the GR shall be inclusive of installation charges along with
other revenues stated therein without any set-off for related item of expense.
From scrutiny of the books of accounts of RCL and RCIL for the period from 2006-07 to
2009-10, it was observed that the revenue on account of installation charges of FWP/T at
the subscribers’ premises amounting to 248.29 crore was booked in the accounts of RCIL.
FWP/T instruments were integral to the provision of telecom service to be provided by
RCL to its subscribers. Since RCL was a UAS licensee, the revenue of ` 248.29 crore
pertaining to instrument cost, installation and upfront charges received from the subscriber
should be part of GR of RCL.
On being pointed out by Audit, it was replied by the Management that-
• RCLenteredintoanagreementwithRCILforprovidingFWP/Tinstallationservices.
RCIL provides services of installation of the instruments at subscriber’s premises
for which RCIL receives amount directly from the subscriber. It was carried out by
RCIL at its own risk. Therefore, revenue accrued from this activity rightly belongs
to RCIL. The activity of installation can be undertaken by anybody i.e. even by
the persons who do not have any telecom licence. TDSAT in its judgment in May
2010 held that the installation charges are given back to the person who does the
installation work and hence it would not come in the purview of AGR.
• AsperHon’bleSupremeCourtjudgment,itwasopentothelicenseesnottoundertake
activities for which they do not require licence.
The reply of the management is not tenable-
• As it is evident from the letter dated 1April 2006 fromRIC toRCIL that the
FWP/Ts were the property of RIC (later changed into RCL) and it had requested
RCIL to install it in the premises of the subscriber. Though RCIL could undertake
the job of installation of FWP/T but it would be only an agency function and in terms
of UASL agreement, GR from subscribers for installation of terminal equipment
(FWP/T) should be revenue of UAS licensee (RIC/RCL) and charges payable to
installation agency (RCIL) should be expense of the licensee. TDSAT judgment
of May 2010 referred in management reply is not related to telecom operators but
related to Direct to Home (DTH –related to TV broadcast) operators.
• Auditdoesnotquestionwhowasundertakingtheactivitybutcontendsthatrevenue
from installation charges of FWP/T should be considered for Revenue Share in
accordance with Licence Agreement.
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Hence, the entire revenue of ` 248.29 crore accounted in RCIL’s books on account of
installation of FWP/T should have been taken to the GR/AGR of RCL. The impact on short
payment of LF and SUC on this account was ` 22.71 crore and ` 6.50 crore respectively
(Annexure - 5.06).
5.2.3 Netting of commission from the revenue by RCL for computation of GR/AGR
On scrutiny of the records furnished by RCL, it was noticed that the commission paid on
broadband prepaid vouchers amounting to ` 1.11 crore was netted off from the revenue and
the net revenue was booked in the accounts of RCL.
On being pointed out by audit, it was replied by the Management that it was just the
discount given on prepaid vouchers which was netted off with the GR and was not liable
to LF payable to GOI.
The reply of the Management is not tenable as netting of commission from revenue was not
in conformity with the licence agreement. The impact on short payment of LF and SUC on
this account was ` 0.09 crore and ` 0.03 crore respectively (Annexure - 5.07).
5.2.4 Netting of revenue earned from channel partners/Franchisees from expenses
for computation of GR/AGR by RCL
On scrutiny of the books of accounts of RCL for the years 2006-07 to 2009-10, it was
noticed that the income from the provision of broadband connectivity to channel partners/
franchisees amounting ` 4.50 crore were credited to expense heads. This resulted in
non-consideration of the revenue in the GR/AGR.
On being pointed out, it was replied by the Management that the adjustments involve setting
off reimbursement of one cost, viz. cost of access from another cost viz. commission
payable by the Company. It was not a case where an item of revenue and an item of cost
were netted off so that revenue was recorded short or not recorded.
The reply is not tenable as the franchisees were paid commission for their activities. While
cost of access actually was a cost to the franchisee and revenue to the licensee, on the other
hand commission payable by company was an expense of licensee. Therefore contrary to
licensee’s claim, it was indeed pairing off an item of revenue with an item of cost.
The impact on short payment of LF and SUC on this account was ` 0.42 crore and
` 0.12 crore respectively (Annexure - 5.08).
5.2.5 Netting of revenue by discount given to distributors/dealers/franchisees on sale
of prepaid products for computation of GR/AGR by RTL
As per the Accounting Policy of Reliance Telecom Limited (RTL) for the year 2006-07
“Revenue is recognized as and when the services are provided on the basis of actual usage
of the company’s network.” This policy was revised for the years 2007-08 to 2009-10
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which states that Revenue from telecommunication services is recognized on the basis of
actual usage of the company’s network in accordance with contractual obligations and is
stated net of taxes and trade discounts.
It was observed during audit that a sum of ` 11.95 crore (` 10.69 crore in respect of
RTL and ` 1.26 crore in respect of Reliable Internet Services Limited (RISL) which later
merged with RTL in September 2007), was shown under expenses as discount granted to
distributors/dealers/franchisees for sale of prepaid cards and recharge vouchers for the first
quarter of 2006-07. However, this discount was netted off with the “Billing Revenue” in
the Annual Accounts of the Company and also with the GR in the AGR statement (for the
year 2006-07).
From 1 July 2006 onwards, the revenue on sale of prepaid cards and recharge vouchers was
accounted net of discounts given to distributors/dealers and the netted off revenue only was
considered for GR/AGR instead of including the gross value.
Based on the amount of discount booked and corresponding prepaid revenue (net) submitted
under AGR statements for eight LSAs of RTL/RISL for the quarter I of 2006-07, the
quantum of discount was projected by audit for the years 2006-07 (for quarter II to IV),
2007-08, 2008-09 and 2009-10. Total amount of discount netted off from revenue for the
years 2006-07 to 2009-10 worked out to ` 392.99 crore.
The above amount of ` 392.99 crore was calculated after taking into account the ratio of
discount to prepaid revenue (net) booked for the first quarter of 2006-07 as the booking of
discount was dispensed with from the second quarter of 2006-07 onwards by the company.
On being pointed out by Audit about the netting of discount from revenue, it was replied
by the Management that-
• Therevenuefromprepaidvoucherwasrecognizednetofdiscount.Thearrangement
with distributors was Principal to Principal. The invoices were issued to distributor
on agreed price and the same was considered as revenue. Only realized revenue was
to be considered in the AGR.
• Overaperiodoftimevariousrangesofprepaidproductswerelaunchedandapplying
same ratio for all years was not correct.
The reply of the management is not tenable in view of audit explanation given in para
3.2.1 (A). Regarding projection of amount of discount by Audit, since the Company
dispensed with the booking of discount from the second quarter of 2006-07 and also the
details of the actual GR figures was not disclosed either to the DoT or Audit, therefore,
Audit had to take recourse to the application of the ratio of discount to prepaid (net)
pertaining to the quarter I of 2006-07 to project the amount of discount for the quarters II
to IV of 2006-07 and for the years 2007-08 to 2009-10.
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While the matter is sub-judice at Hon’ble Supreme Court, Audit view is that netting of
commission/discount paid to distributors/dealers on sale of prepaid products was against the
UAS licence agreement and hence GR/AGR of RTL for the years 2006-07 to 2009-10 was
understated by ` 392.99 crore resulting in short payment of LF and SUC by ` 25.72 crore
and ` 14.04 crore respectively (Annexure - 5.09).
5.2.6 Non-inclusion of value of Free of Charge (FOC) recharge vouchers given to
distributors for computation of GR/AGR by RTL
Examination of the books of accounts of RTL for the period 2006-07 to 2009-10 revealed
that service tax of ` 12.12 crore paid on free of cost recharge vouchers given to the
Distributors was booked under expense as ‘service tax paid – not billed’.
Also ` 85,218 and ` 11,09,799 were booked under expense as “Channel Associative –SE
Incentive” for 2006-07 and 2007-08 respectively representing the service tax paid on Free
Recharge coupon given to distributors. Though the service tax was paid, the gross value of
FOC vouchers was not found to be included in the GR of RTL.
On being pointed out by Audit, it was replied by the Management that
• TheLFwaspayableonrealizablerevenueonly.NoLFwaspayableonthenotional
income. Income which was not accrued to Licensee cannot be charged for LF. In
the aforesaid cases, company has not earned any revenue from these vouchers and
no inflow was there. Hence notional revenue from these vouchers cannot be included
in the revenue of the company.
• TDSATvideitsjudgmentdated23April2015alsoheldthatinordertobecounted
as “GR”, the item of inflow must not be notional but real.
The reply of the management is not tenable as
• Free recharge coupons given to distributors onwhich Service Taxwas paid by
the Company was nothing but discounts/commission paid to them. In view of
explanation given in para 3.2.1 (A), commission paid to distributors should not be
netted off from revenue for computation of GR/AGR. Free recharge coupons given
to distributors are equivalent to cash for them as these can be sold on the basis of
airtime available in the coupons.
• While noting that TDSAT judgment dated 23 April 2015 referred in reply was
challenged in Hon'ble Supreme Court by DoT in July 2015, Audit is of the view
that licensee instead of giving cash as commission had passed on benefit of use
of telecom service for which revenue was forgone and hence it was not a case of
notional revenue.
Based on the amount of service tax paid, the gross value of FOC recharge vouchers have
been worked out to ` 87.32 crore. The impact on short payment of LF and SUC on this
account was ` 5.70 crore and ` 3.00 crore respectively (Annexure - 5.10).
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5.3 Under reporting of revenue in the Statements of Revenue and LF (AGR
Statements) though reported in the books of accounts.
5.3.1 Non consideration of forex gain in GR/AGR by RCL and RTL:
In the books of accounts of RCL/RTL, total net balances under the account codes operated
for booking transactions related to foreign exchange gain/loss were included in the Schedule
of “Financial Charges (net)” as Foreign Currency Exchange Fluctuation (gain)/loss (net).
From quarterly GL balances of all account codes operated for accounting Forex gain for
2006-07 to 2009-10, it was noticed that out of total Realized gain of ` 1934.72 crore
(` 1820.49 crore for RCL and ` 114.23 crore for RTL), only ` 600.86 crore (RCL
` 590.56 crore and RTL ` 10.30 crore) was considered by the licensee for GR/AGR in the
year 2007-08. Thus realised forex gain of ` 1333.86 crore (RCL ` 1229.94 crore and RTL
` 103.92 crore) was not considered for GR/AGR.
It is pertinent to mention here that the above realised gain calculated from the data extracted
from the reports generated from Financial System (SAP) did not represent the actual gain
of that particular item since the Company recasts the value of all the items included under
the foreign exchange gains/losses head every year, the matured items are accounted under
realised gains and the un-matured items remain under unrealised gain. Thus, the realised
gain of a particular item in that year would not be the actual gain due to accounting of the
gains /losses of that item during the intermediate period under unrealised. Audit could not
arrive at the actual value of items accounted under realised gain every year for want of
original value of each item. Further, audit has considered the quarterly net gain, head of
account-wise and LSA-wise, as it was not possible for audit to segregate/collect the figures
of gains only from the data made available. The operator should calculate the gain of each
item with reference to its initial value of accounting and include the total forex gain in GR/
AGR.
On being pointed out by Audit, it was replied by the Management that,
• AspertheTDSATjudgmentdated30August2007,thesaiditemwasnotconsidered
for the calculation of LF.
• KeralaHighCourtinitsjudgmentdated10July2012statedthattherevenueearned
from Non Telecom activities should not be included for the purpose of calculation
of LF.
• AS-9doesnotrecognizeforexgainasrevenue.AspertheTDSATjudgmentdated
23 April 2015, the aforesaid income was not liable for LF.
• TheCompany,tillQuarter3of2008-09waspayingLFonnon-Telecomrevenue
also and subsequently claimed refund from DoT of the LF paid on such non-Telecom
revenue. The unrealized gain was notional and not liable to LF.
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The reply of the management is not tenable in view of audit explanation already given
in para 3.2.5. Further, regarding specific reply of the Management, Audit views are as
follows:
• TDSATjudgmentdated30August2007wassetasidebyHon’bleSupremeCourtin
October 2011.
• KeralaHighCourt order dated 10 July 2012 is an interimorder.Audit view is
that since Licence Agreement provided “GR shall be inclusive of …… any other
miscellaneous revenue, without any set-off for related item of expense, etc,” and
forex gain was part of Miscellaneous Revenue, this should be included in GR for
computation of revenue sharing.
• TDSATjudgmentdated23April2015referredinreplywaschallengedinSupreme
Court by DoT in July 2015. While the matter was sub-judice at the Hon’ble Supreme
Court, Audit opines that non-consideration of forex gains in the GR by the Company
was a deviation from the licence conditions.
The understatement of GR by ` 1333.86 crore due to non - inclusion of forex gain
resulted in short payment of LF and SUC ` 107.63 crore and ` 26.93 crore respectively
(Annexure - 5.11).
5.3.2 Non consideration of Interest/Other income for computation of GR/AGR by
RCL/RTL
As mentioned in para 1.4 (a), the GR shall be inclusive of interest, dividend and any
other miscellaneous revenue along with other revenue stated therein without any set-off for
related item of expense. Audit scrutiny of books of accounts of RCL/RTL revealed that
Interest/other income have been partly considered for computation of GR/AGR during the
period 2006-07 to 2009-10 as discussed below-
(A) Non - inclusion of interest/dividend income in GR/AGR by RCL/RTL
In respect of RCL, total interest/dividend income booked in the accounts for the years
from 2006-07 to 2009-10 was ` 1328.40 crore, out of which ` 98.88 crore had been
considered in GR/AGR for computation of revenue share. Thus interest/dividend income of
` 1229.52 crore was not considered in GR/AGR.
Similarly, in respect of RTL, total interest income booked in the accounts for the years
2008-09 and 2009-10 and income from investment in 2009-10 of ` 139.52 crore was not
considered for GR/AGR by RTL.
The income from investment of RTL for the year 2008-09 has been commented separately
under para 5.3.4 due to netting of some income with expenses.
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(B) Non - inclusion of other income in GR/AGR by RCL/RTL
The total other income booked in the accounts of RCL for the years from 2006-07 to
2009-10 was ` 161.78 crore, out of which ` 81.73 crore had been considered in GR/AGR
for computation of revenue share. Thus other income of ` 80.05 crore was not considered
in GR/AGR.
Similarly in respect of RTL, the total other income (profit on sale of securities/bonds,
miscellaneous, etc.) booked for the years 2008-09 and 2009-10 was ` 537.40 crore. Out of
total other income, only ` 0.78 crore had been considered for GR/AGR for computation of
revenue share and ` 536.62 crore (` 537.40 crore - ` 0.78 crore) was not considered for
GR/AGR.
On being pointed out by Audit, it was replied by the Management that-
• AspertheTDSATjudgmentdated30August2007,Licenseesarerequiredtopay
a share out of the revenue generated from Telecom activity. This income was not
related to Telecom Activity and so not liable for LF.
• Hon’bleKeralaHighCourt in itsorderdated10July2012 restrictedDoTfrom
raising any demand for LF under which it seeks to include revenues arising from
any non licenced telegraph activities.
• TDSATinitsjudgmentdated23April2015excludedvariousnontelecomrevenue
items which have not been specifically provided in definition of GR in the Licence
agreement. Hence the said income was not liable for LF.
The reply of the Management is not tenable as
• TDSAT judgment dated 30August 2007was set aside by theHon’ble Supreme
Court in its judgment dated 11 October 2011.
• KeralaHighCourtorderdated10July2012referredinreplyisaninterimorder.
• WhilenotingthattheTDSATjudgmentdated23April2015hasbeenchallenged
in the Hon’ble Supreme Court by DoT in July 2015, Audit is of the view that
Licence agreement clearly prescribes the inclusion of interest, dividend and any
other miscellaneous revenue in GR/AGR.
In view of above, non - inclusion of interest, dividend and other miscellaneous income as
mentioned above in para 5.3.2 (A) and 5.3.2 (B) has resulted in understatement of GR/AGR
by ` 1985.72 crore. The impact on short payment of LF and SUC due to under reporting
of interest and miscellaneous income was ` 153.44 crore and ` 48.56 crore respectively
(Annexure - 5.12).
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5.3.3 Interest free loan to subsidiary by RCL resulted in avoidance of payment of
LF/SUC
Test check of Annual Accounts of RCL revealed that interest free un-secured loan was given to its subsidiary Campion Properties Limited (CPL) and Reliance Tech Services Private Limited (RTSPL). The accounts revealed that the loan amount at the end of 2006-07, 2008-09 and 2009-10 against these subsidiaries were ` 36.78 crore (CPL), ` 3.63 crore (RTSPL) and 15.27 crore (RTSPL) respectively. As these two companies were not wholly owned subsidiaries of RCL during these particular years, the grant of interest free unsecured loan was in violation of Section 372A of Companies Act, 1956 and not in line with the arm’s length relation to be maintained between the holding and subsidiary companies.
On being pointed out by audit, it was replied by the management that as per section 372A (8) (a) (i), provisions of section 372A does not apply to any loan made by a company providing infrastructural facility. RCL being telecom service provider was exempted from the provision of section 372A.These companies were promoted to support activities of RCL and therefore it was necessary for RCL to provide financial support repayable at demand, to carry out their activity smoothly in overall interest of RCL, hence it was not prejudicial to the interest of RCL. Notional income was not liable to LF.
The reply of the management is not tenable as RCL was a telecom service provider and was not established with the object of providing infrastructural facilities and hence the exemption under section 372A (8) (a) (i) was not applicable to it. Thus, GR/AGR of RCL was lower by the amount of interest receivable and thereby short payment of LF and SUC. The impact on short payment of LF and SUC could not be quantified since the date of release of loan
and period for which above interest free loan remained outstanding was not available.
5.3.4 Netting off of loss on sale of investment and non - inclusion of balance profit on
sale of investment for computation of GR/AGR by RTL
As per financial statements of RTL for the year 2008-09, income from non-trade investments was ` 108.92 crore.
However no income on this account was considered for computation of GR/AGR.
On being pointed out, it was replied by the management that-
As per TDSAT judgment dated 30 August 2007, various revenues which were not related to telecom activities should not be included in the AGR for the purpose of LF.
Only interest/dividend income with direct nexus with the provision of telecom service merits inclusion in the AGR. The profit on sale of investments was received on borrowed funds and company was paying interest on the same. Hence it was not included in the AGR.
The reply of the management is not tenable in view of audit explanation given under
para 5.3.2.
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Hence, non-inclusion of profit on sale of investments of ` 108.92 crore has resulted in
understatement of GR/AGR resulting into short payment of LF and SUC by ` 7.30 crore
and ` 3.94 crore respectively to Government of India (Annexure - 5.13).
5.3.5 Different standards for payment of dividends - RCL
As mentioned in para 1.4 (a), GR shall be inclusive of dividend along with other revenue
stated therein. This implies that licence agreement intended to include the revenue from
investment (dividend) for the purpose of revenue share. An analysis of the annual accounts
of RCL for the period from 2006-07 to 2009-10 indicated that its investments in the form
of equity shares and preference shares in its subsidiaries and associates had increased
approximately five times from ` 5434.42 crore in 2006-07 to ` 31898.30 crore in 2009-10
(Annexure - 5.14).
RCL was the majority shareholder in most of these subsidiaries and associates. However,
RCL did not receive any return on these investments during this period in form of dividend
or otherwise in spite of the fact that the total profit of these companies after tax was
` 708.61 crore, ` 668.65 crore, ` 1118.01 crore and ` 1499.98 crore during each of the
years from 2006-07 to 2009-10 respectively (Annexure - 5.14).
It was seen in audit that RCL had adopted different standards for declaration of dividend
in respect of RCL itself and for other non-licensee companies where it had investments
and majority shareholdings. While RCL had declared a dividend of 10 to 17 per cent on
face value of shares for 2006-07 and 2009-10, no dividend was declared by any of the
subsidiaries and associates where RCL had a majority shareholding. While dividend paid by
RCL was an expense for RCL and was not subject to LF and SUC, the dividends received
by it from companies/entities it had invested in would have attracted imposition of LF and
SUC as per terms of the licence agreement.
Thus non-declaration of dividend by subsidiaries and associates in which RCL had invested
was not in accordance with RCL’s own action of declaration of dividend and resulted in
reduction of revenue of RCL and consequently lower payment of LF and SUC.
5.4 Revenue considered for Licence Fee but not considered for Spectrum Usage
Charges (SUC)
5.4.1 Non consideration of revenue from sale/lease of bandwidth for computation
of SUC
UASL agreement provides that “while calculating AGR for limited purpose of levying
spectrum charges based on revenue share, revenue from wireline subscribers shall not be
taken into account”. Further, in the format of statement of revenue and licence fee (AGR Statement) prescribed for the UASL agreement-
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• Item1Ahasbeenprescribedtoreflectthe“revenuefromwirelinesubscribers”and
• Item8hasbeenprescribedtoreflect the“revenuefromsale/leaseofbandwidth,links, R&G cases, turnkey projects etc.”
In the statement of revenue and licence fee (AGR Statement) for the years 2006-07, 2007-08, 2008-09 and 2009-10, revenue from sale/lease of bandwidth links, R&G cases, turnkey projects etc. amounting to 1588.19 crore was shown under item 8 of the statements. However, this revenue was not considered for payment of SUC though considered for payment of LF which was in contravention of the provisions of the licence agreement.
The Management replied that the UASL agreement provides for the limited purpose of levying annual royalty/SUC and the revenue from wire line subscribers shall not be taken into account. Hence, the revenue from lease line and bandwidth subscribers was not required to be added in the AGR for the purpose of calculation of spectrum charges.
Audit view on above has been brought out in para 3.4.3.
As such, above revenue of ` 1588.19 crore should be considered for computation of SUC. This resulted in short payment of SUC by ` 40.66 crore to Government of India (Annexure - 5.15).
5.4.2 Non consideration of income from investment for computation of SUC
As per AGR Statements submitted by RCL, Income from investment (item 4 of the statement) for the four quarters of 2006-07 was ` 70.60 crore. However, amount of ` 17.83 crore of fourth quarter alone was considered in the AGR for computation of SUC (CDMA) and amount for the remaining three quarters of ` 52.77 crore was not considered in AGR for SUC.
However in subsequent years i.e. 2007-08, 2008-09 and 2009-10, income from investments, if considered for LF, was also considered for SUC by the company.
On being pointed out by audit, the management replied that the SUC shall be payable on revenue earned from wireless subscribers only. As investment income is not wireless revenue, the inclusion of it in the AGR for SUC does not arise. It was also stated that the SUCpaidonQ4incomefrominvestmenthadbeenclaimedasrefundfromDoT.
The reply of the management is not tenable as for the purpose of SUC, revenue from wireline subscribers only depicted in item 1A of AGR statement was to be excluded. Income from investment was to be included in item 4 of the AGR statements. In view of above, income from investment of ` 52.77 crore should have been considered for payment of SUC.
The impact on short payment of SUC is ` 0.94 crore (Annexure - 5.16)
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5.5 Transfer of infrastructure assets by RCL/RTL to its subsidiary Reliance Infratel
Ltd (RITL)
5.5.1 Transfer of Optic Fibre Undertaking (OFU) by RCL to RITL
Reliance Communications Limited (RCL) had transferred the assets and liabilities relating
to its Optic Fibre Undertaking (OFU) to its subsidiary RITL engaged in providing Telecom
Infrastructure services. This was done pursuant to the scheme of arrangement under
sections 391 to Section 394 of Companies Act for the transfer of optic fibre undertaking
approved by the Hon’ble High Court of Bombay on 18 July 2009 with the appointed date as
01 April 2008. The total value of the OFC Network of RCL as on 1 April 2008 was taken
as ` 7206.42 crore as the consideration payable on account of transfer.
Profit of ` 3063.27 crore arising from such transfer which was arrived at by deducting net
block of 4137.95 crore and capital work in progress of 5.20 crore from the consideration
amount of ` 7206.42 crore was credited to the Profit and Loss account.
It was noticed that the Company did not include the above profit in the GR/AGR.
On being pointed out by Audit about non inclusion of profit on transfer of asset in GR/
AGR, the Management replied that
• The Company was paying licence fee as per the TDSAT judgment dated
30 August 2007.
• KeralaHighCourtinitsjudgmentdated10July2012statedthatthenontelecom
revenue should not be included in the AGR for the purpose of calculation of LF.
Hence the Company excluded the profit arising as a result of transfer of OFU
undertaking which was not related to Telecom activities.
• Thetransactionwasnotasalebutatransferandnoactualgainwasreceived.Also
notional gain cannot be included.
• Thetransactionwasanincomeandnotrevenue.Itisclearthattheconnotationof
‘revenue’ as that received from ordinary activities of an enterprise is not endorsed
by AS-9.
• Thesaidincomewasnot liabletolicencefeeaspertheTDSATjudgmentdated
23 April 2015.
The reply of the Management is not tenable as-
• TDSATjudgmentdated30August2007wassetasidebytheSupremeCourtinits
judgment dated 11 October 2011.
• KeralaHighCourtorderdated10July2012wasaninterimorder.
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• RCLandRITLweretwodifferentlegalentitiesandhencetransferofassetfrom
RCL to RITL is the disposal of assets and the company itself has recognised the
profit on disposal of its assets in its profit and loss account.
• ProfitontransferofOFUbyRCLtoRITL,thoughnotendorsedasrevenueunder
AS-9, it should be included in GR/AGR for computation of LF and SUC as per
licence agreement.
• WhilenotingthattheTDSATjudgmentdated23April2015hasbeenchallengedin
Supreme Court by DoT in July 2015, Audit is of the view that gains on account of
transfer of OFC network was part of Miscellaneous Revenue and thus, was to be
included in GR in accordance with licence agreement.
Hence, in view of licence agreement, the profit of 3063.27 crore credited to the Profit and
Loss account should also have been taken to GR/AGR. The impact on short payment of LF
and SUC was ` 279.27 crore and ` 81.37 crore respectively (Annexure - 5.17).
5.5.2 Transfer of passive infrastructure by RCL/RTL to its subsidiary (RITL) at ‘nil’
value
Reliance Infratel Limited (RITL), a subsidiary of Reliance Communications Limited
(through Reliance Communications Infrastructure Limited (RCIL)), was incorporated in
2001 as a private limited company. Reliance Communications Limited (RCOM) had filed
a Scheme of Arrangement5 with the High Court of Judicature at Bombay on 5 December
2006 for the separation of its wireless towers assets owned by RCOM and its wholly owned
subsidiary Reliance Telecom Limited (RTL). The High Court’s approval was received on
16 March 2007 and the scheme became effective from 10 April 2007. Pursuant to
the scheme, the passive infrastructure assets of RCL and RTL having book value of
` 3200.74 crore and 866.80 crore respectively were transferred to RITL at ‘nil’ value. RITL
recorded6 the value of assets transferred from RCL and RTL at fair value of 3327.46 crore and
` 1188.36 crore respectively.
RCL, RTL and RITL, being separate entities and also RITL was not a fully held subsidiary
of RCL/RTL7, transfer of assets was not a transaction at arm’s length. As the market
value of the assets transferred from RCL and RTL were ` 3327.46 crore and ` 1188.36
crore respectively, as revalued by RITL, the difference between the book values and the
values as accounted by RITL were profits foregone on transfer of asset. Amount of profits
foregone by RCL and RTL were ` 126.72 crore and ` 321.56 crore respectively in the year
2007-08. In view of licence agreement, these profits foregone on transfer of asset should be
considered for computation of LF and SUC.
5 under sections 391 to section 394 of the Companies Act, 1956, for the transfer of passive infrastructure of RCL and RTL to RITL.
6 in its books of accounts for the year 2007-08.7 RCL was holding only 79.71 per cent of the Share in RITL as on 31 March 2008.
Report No. 4 of 2016
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On being pointed out by Audit, it was replied by the Management that
• Thesaidtransactions and fair valuations were pursuant to the scheme of arrangement
approved by the Hon’ble High Court of Bombay and no actual purchase and sale of
assets/liabilities took place.
• Further,TDSATinthejudgmentpronouncedon23 April 2015 in a separate but
related context affirmed that “in order to be counted as “gross revenue”, the item
inflow must not be notional but real”. Consequentially, it would be inappropriate
to consider such notional income in the determination of the GR under the licence
agreement.
• RITL had revalued assets in its books of accounts. Increase in value of assets
on account of any revaluation of assets cannot be considered as revenue. If this
revaluation is considered as income, the same would be accounted in RITL and not
in RTL.
The reply of the Management is not tenable as –
• RCL,RTLandRITLwereseparateentitiesandRITLwasnotafullyheldsubsidiary
of RCL/RTL. Assets transferred were written off from the books of RCL/RTL and
debited to their profit and loss accounts. Hence these transactions were similar to
sale/disposal of assets.
• Gainonrevaluationofassetstransferredwasnotnotionalasitaccruedconsequent
to disposal of assets from one entity to another entity. While noting that the TDSAT
judgment dated 23 April 2015 has been challenged by DoT in July 2015 in the
Hon’ble Supreme Court, Audit view is that transfer of assets from RCL/RTL to
RITL at value other than a 'fair value' was not a transaction at arm’s length.
• Since assetwas not disposed at fair value in linewith arm’s length transaction,
increase in value of assets on account of any revaluation of assets by transferee
Company (RITL) was the profit foregone by the transferor companies (RCL/RTL).
Thus non consideration of the amount of ` 126.72 crore in GR/AGR resulted in short
payment of LF and SUC of ` 11.56 crore and ` 3.44 crore respectively by RCL for the
year 2007-08 (Annexure - 5.18).
Similarly, non consideration of the amount of ` 321.56 crore in GR/AGR resulted in short
payment of LF and SUC of ` 17.62 crore and ` 11.72 crore respectively by RTL for the
year 2007-08 (Annexure – 5.19).
5.6 Non-consideration of Refund of Service Tax for GR during the year 2009-10
Audit observed that an amount of ` 51.45 crore being the refund of Service Tax was
accounted under Operational Income during the year 2009-10. However, the said amount
was not considered while computing GR for the purpose of LF and SUC.
Report No. 4 of 2016
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Management stated that the Company had provided certain services which were in the
category of export of services and paid service tax on same from accumulated credits, the
same was claimed as rebate from the Service Tax department which on receipt, was shown
as miscellaneous income in annual accounts, this refund was an incentive on export of
services and hence, not liable for LF. The Management also stated that Service Tax paid
was not claimed as deduction in AGR and hence, any rebate/incentive/refund cannot be
liable for LF.
The reply is not tenable since RCL is a telecommunication company and any income that
accrues to it by virtue of its business of telecom activities has to be a part of its revenue.
Audit is of the view that any monetisation of export credit or any other incentive received
by the Company constitutes part of miscellaneous income and as per the terms of Licence
Agreement, has to be included in GR for computation of LF and SUC.
Non-inclusion of the amount has resulted in short payment of LF and SUC by ` 4.69 crore
and ` 1.36 crore respectively (Annexure – 5.20). It is also pertinent to mention that the
issue was noticed in Reliance during test check and hence commented upon.
5.7 Interest on short/non - payment of LF and SUC
On issues raised above (from paras 5.2 to 5.5) short/non-payment of LF and SUC worked
out to be ` 1125.40 crore and ` 381.85 crore respectively. The interest on this short/
non-payment of LF and SUC is ` 2221.29 crore (Annexure-5.21). The calculation of
interest was based on the rate prescribed in the licence agreement i.e. 2 per cent above the
prime lending rate of State Bank of India existing as on the beginning of the financial year
and the period considered for the calculation was from the end of the concerned financial
year up to March 2015. The interest has been compounded monthly as prescribed in the
licence condition.
5.8 Reply from DoT on issues raised above
Audit observations on the revenue shared by RCL/RTL were communicated to DoT in
September 2015. DoT in reply (January 2016) informed that demands for understatement
of GR as pointed out in paras pertaining to commissions/discounts paid to RCIL by RCL
(5.2.2 A), VAS/CRBT revenue not included in GR/AGR of RCL (5.2.2 B and 5.2.2 C);
non-inclusion of installation charges of FWP/T in GR/AGR of RCL (5.2.2 F); commissions/
discounts paid to distributors by RTL (5.2.5); FOC coupons given to distributors by RTL
(5.2.6); under reporting of revenue due to non-inclusion of revenue/income in GR/AGR
from forex gain (5.3.1), interest and other income (5.3.2); profit from sale of investment
(5.3.4) and gain on transfer of passive infrastructure (5.5.2) were raised on the PSP in
2012 for the years 2006-07 and 2007-08, based on the report of Special Audit conducted in
2009. But the demands were challenged by the operator in TDSAT/Hon’ble High Courts.
Report No. 4 of 2016
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The matter is still sub-judice in the court. It was also informed that action would be taken
as and when the final court judgment was pronounced.
Thus, DoT agreed to the issues raised by Audit. However, it pleaded helplessness in realising
the revenue from RCL/RTL on account of these issues being sub-judice. Considering that a
substantial amount of government revenue is blocked for many years on account of litigation,
DoT should play a proactive role in getting these legal issues settled at the earliest.
DoT in its reply also pointed out to the variation in the amounts quantified by CAG
Audit and the demands raised by DoT as a consequence of the Special Audit. These
variations could be on account of the difference in methodology adopted in quantifying the
understatement of revenue. Audit has determined the understated amounts on the basis of
actual entries identified through clear descriptions in the books of accounts of RCL/RTL
for 2006-07 to 2009-10. However, the details of working papers of the Special Auditors
were not seen by CAG Audit.
In respect of paras pertaining to non-inclusion of revenue from sale of SIM cards
(5.2.2 D); sale of handsets (5.2.2 E); understatement of GR by netting of broadband
commission from revenue (5.2.3) and non-inclusion of gain on transfer of optical fibre
(5.5.1), the DoT stated that reply received from the PSP was under examination.
In reply to para relating to booking of revenue net of FAT/commission (by eliminating it
at mediation level itself) (5.2.1), it was stated that DoT had sent a notice to the company
(June 2015) to prepare the accounts as per the norms mentioned in the licence agreements
and in respect of para relating to netting of revenue from expenses (5.2.4), it was stated that
show cause notice was issued to RCL to submit information on gross basis for items which
have been netted off as required under clause 22.3 of UASL agreement.
In respect of para pertaining to interest free loan to subsidiary (5.3.3), it was stated that
DoT had taken a decision in 2005, in consultation with Ministry of Law and learned AG,
that notional interest can neither be reckoned nor included in AGR.
Audit view is that DoT’s decision of not reckoning the due interest on interest free loan
given to subsidiaries for AGR purpose was not in line with the provisions of the Companies
Act 1956. By providing interest free loan to its not fully owned subsidiary, RCL’s revenue
was lower by the amount of interest receivable and ultimately the LF and SUC thereon was
short paid to the Government of India to that extent.
In respect of paras relating to non-consideration of revenue from sale of bandwidth for SUC
(5.4.1) and non-consideration of income from investment for SUC (5.4.2), it was stated that
reply from WPF wing of DoT was awaited.
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DoT also stated that the basic definition of GR and AGR was challenged by the PSP
in 2002-03. Since then, there has been protracted litigation and is continuing till date.
Also, some of the licensees have also filed (2012) writ petitions before various High
Courts invoking the writ jurisdiction under Article 226 of the Constitution challenging the
Section-4 of Indian Telegraph Act, 1885, as violative of the Article 14 and 19(1) (g) of the
Constitution of India. The process of deduction verification by the CCA offices and the
LF Assessment work by the DoT Headquarters was adversely impacted due to this. DoT
admitted that the numerous disputes are causing delays in assessment of the revenue share
due from the operator.
The response of DoT indicates that though the revenue share regime was introduced as
part of NTP-1999, the Department has not been able to realise its due revenue share as
envisaged in the licence agreement even after more than 16 years of its implementation.
It would be pertinent to mention here that when the government decided to reduce the
licence fee for all operators by two per cent effective from April 2004, DoT expected that
the reduction would prompt operators to withdraw the challenges against the government.
However, the reduction in licence fee did not have the expected impact and the operators
continue to institute litigations against the government challenging the definition of GR/
AGR and demand notes. Thus the PSPs got the benefit of reduction in rate of licence fee
but the government didn’t get the reciprocal benefit of reduction in litigations.
Report No. 4 of 2016
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CHAPTER – VIRevenue shared by Idea Cellular Limited (ICL) and
Aditya Birla Telecom Limited (ABTL)
6.1. Brief profile of the company
M/s Idea Cellular Limited (ICL) was a company under Aditya Birla Group. It was among
the first private sector companies that were awarded licences for providing cellular services.
Though it was an early entrant, its growth was not at par with other contemporary telecom
companies when telecom sector in India witnessed phenomenal growth. However, of late,
ICL achieved remarkable gain in telecom market share.
6.1.1 Licences granted to Idea Cellular Ltd (ICL) and Aditya Birla Telecom Ltd.
(ABTL)
M/s Idea Cellular Limited (ICL), initially incorporated as M/s Birla Communications Ltd.,
was among the first private telecom companies to be awarded licences in December 1995
for providing cellular services in Maharashtra and Gujarat LSAs. In 1996, M/s Birla
Communications changed its name to M/s Birla AT&T Communications Ltd. following a
joint venture with M/s AT&T Corporation. During the years 2000 and 2001, it got licences
in Andhra Pradesh and Madhya Pradesh by acquiring M/s Tata Cellular Limited and
M/s RPG Cellular respectively and changed its name to Birla Tata AT&T (BATATA) and
also obtained licence for Delhi LSA in 2001. In 2002, the Company changed its name to
Idea Cellular Ltd and launched “Idea” brand name. It got licences in six more LSAs1 by
acquiring M/s Escotel Communications Limited. In the year 2006, ICL obtained licence
for Mumbai LSA and licence for Bihar was obtained by one of its the promoter companies,
Aditya Birla Telecom Ltd (ABTL). ABTL became a 100 per cent subsidiary of ICL in
2007. During 2008, ICL obtained licences in seven more LSAs.2 ABTL transferred its
UAS licence of Bihar to ICL in 2009-10. Now ICL holds licences in Punjab and Karnataka
LSAs after merger of Spice Communications Limited w.e.f. 01 March 2010.
Idea Cellular Ltd. holds two licences for National Long Distance (NLD) services and one
licence for International Long Distance (ILD) services. The first NLD licence was obtained
in 2006 by ICL and second NLD as well as ILD licences were obtained through acquisition
of M/s Spice Communications Ltd which had obtained NLD and ILD licence in 2007. ICL
got registered as an Infrastructure Providers- Category I (IP-I) in 2008 and as an Internet
Services Provider (ISP) in 2010.
1 Haryana, UP (West), UP (East), Kerala, Rajasthan and Himachal Pradesh2 Tamil Nadu, Orissa, Kolkata, North East, Jammu and Kashmir, Assam and West Bengal
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6.1.2 Spectrum allotted to ICL/ABTL
ICL is a GSM operator. LSA wise GSM spectrum allotted to ICL as on 31 March 2010
was as follows:
Table 6.1
Sl No Spectrum Licenced Service Area
1 2 × 9.8 MHz Maharashtra
2 2 × 8.0 MHz Andhra Pradesh, Delhi, Kerala, Madhya Pradesh and UP (West)
3 2 × 7.8 MHz Punjab
4 2 × 6.2 MHz Gujarat, Haryana, Karnataka, Rajasthan and UP (East)
5 2 × 4.4 MHzAssam, Bihar, Himachal Pradesh, J&K, Kolkata, Mumbai, NE, Orissa, Tamil Nadu and West Bengal.
6.1.3 Subscriber base of ICL/ ABTL
During the period under audit, subscribers of ICL grew from 1.40 crore as on 31 March 2007 to 6.38 crore as on 31 March 2010 registering a phenomenal growth of 450 per cent. ICL had a market share of seven per cent during 2006-07 which increased to 10 per cent during 2009-10.
6.1.4 Gross Revenue, Deduction and Adjusted Gross Revenue reported and revenue share paid by ICL/ABTL
As brought out in Para 1.5, Telecom Service Providers are required to pay LF and SUC at a percentage of AGR on quarterly basis on self-assessment basis. GR, Deductions, AGR reported and revenue shared (LF and SUC) by ICL/ABTL during the period under audit are as follows:
Table 6.2
(` in crore)
Year GR Deductions AGRPercentage of AGR to GR
Revenue share(LF+SUC)
2006-07 4518 851 3667 81.16 4462007-08 7150 1558 5592 78.21 6812008-09 10728 2677 8051 75.05 11072009-10 13323 2723 10600 79.56 1319Total 35719 7809 27910 78.14 3553
6.2 Under reporting of revenue by ICL/ ABTL
As mentioned in para 1.4 (a), the Gross Revenue shall be inclusive of all types of revenue stated therein without any set-off for related item of expense, etc, and as brought out in Para 1.5, service revenue (amount billable) shall be shown gross and details of discount/rebate indicated separately.
Audit examination of records/Books of accounts of ICL/ABTL revealed that these companies
had not adhered to the provisions of the Licence Agreement on the following issues:
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6.2.1 Under reporting of revenue due to netting off of revenue pertaining to Commission/offers/discounts to dealers/subscribers for prepaid services
From the examination of data/records pertaining to prepaid services furnished by ICL/ABTL for the period from FY 2006-07 to 2009-10, it was observed that -
• Themargin/commissiongiventodistributors/agentswasnettedofffromthe
revenue pertaining to prepaid services.
• Offers to the subscriberviz.FreeAirTime (FAT) tocustomers,Freeof
Cost (FOC) SIMs/Talk time/SMS facility to customers, Promotional offers
to customers, Full talk time offered to customers, Adjustments offered to
customers, PCO incentives were setoff from the revenue pertaining to prepaid
services.
Item wise details are furnished below:
A) Margin/ Commission:
The licensee company appoints distributors/franchises/dealers for selling telecom services on commission basis. The company supplies to the distributors/franchises/agents the prepaid recharge coupons/e-top up for sale to subscribers and pay commission/margin to them. During review of data/records offered by ICL/ABTL for the period from 2006-07 to 2009-10, it was observed that the Primary commission/margin paid to the distributors/franchises/dealers at the time of sale of prepaid recharge coupons/e-top up were deducted from the revenue. This resulted in revenue getting set-off of commission/margin in the books as well as in the GR and as a result, Net Revenue was considered in AGR statements submitted to DoT.
Total amount deducted from revenue on account of commission/margin to the distributor/franchisees/agents/dealers during 2006-07 to 2009-10 was ` 698.70 crore (Annexure - 6.01).
Since, the commission/margin paid to the distributors/franchises/dealers was in the nature of business expenses (marketing expenses), therefore, set-off of such expenses with revenue was against the licence condition.
On being pointed out by Audit, it was stated by Management that-
• AsperlegalopinionobtainedbyICL,therelationshipbetweentheCompanyanddistributor was on a Principal to Principal basis and accordingly the Company was required to account for the transactions with such distributors as such on the amount realized from the distributor.
• In accordance with AS-9, the price at which the Company sells the product tothe distributors was the consideration received and hence only this amount should be recognized as revenue. There was no inflow of cash, receivables or other consideration.
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• AsperTDSATjudgementdated30August2007, theLFwas tobepaidon therevenues actually realised by the licensee.
Audit view on the reply of the Management is as explained in para 3.2.1 (A).
• Further, regarding revenue recognition as perAS-9 statedbyManagement, it isstated that audit is not challenging the accounting methodology adopted by the Company but for the purpose of licence fee, the revenue is to be recognised “Gross” without set-off of related expenses as mandated under licence agreement.
• TDSATjudgmentdated30August2007referredinthereplywassetasidebytheHonourable Supreme Court vide judgement dated 11 October 2011.
Thus, the netting off of commission/margin to the distributor/franchises/agents/dealers during 2006-07 to 2009-10 to the tune of ` 698.70 crore has resulted in short payment of LF and SUC amounting to ` 59.93 crore and ` 29.74 crore respectively.
B) Free airtime/un-used airtime/ promotional offers/PCO incentives to customers
During review of data/records furnished by M/s ICL/ABTL for the period from 2006-07 to 2009-10, it was observed that in order to accommodate Offers to the subscribers viz. Free Air Time (FAT)/Unused air time (UAT) to customers, Free of Cost (FOC) SIMs/SMS/free talk time (FTT)/bonus talk time/adjustments to customers, the value of the same was deducted from revenue from prepaid services upfront and as and when the same was used by subscriber, the revenue was credited by the said amount. Resultantly, the revenue on account of these offers to subscribers was not recognised in the GR/AGR.
Since, offers to customers (FAT/UAT/FTT/FOC/Extra talk time, etc.) were part of overall commercial strategy to enhance business, the cost of such offers/discounts/rebate were in the nature of expenses. Further, as per licence agreement service revenue should be shown in gross without any set-off. Thus, the action of the Management in setting off the offers/discounts/rebate from revenue was against the licence agreement and resulted in short
payment of LF and SUC as detailed below:
Table 6.3
(` in crore)Free airtime/un-used airtime/
promotional offers/PCO incentives to customers
Under reporting of
GR
LF Impact
SUC Impact
Remark
Free Airtime (FAT)/ Un-used airtime (UAT) 202.36 15.91 8.00 Annexure – 6.02
Free of Cost (FOC) SIMs/SMS to customers 4.62 0.42 0.20 Annexure – 6.03
Free talk time (FTT) to customers 344.13 30.74 13.45 Annexure – 6.04Netting of refund of Admin fee etc. 7.09 0.47 0.31 Annexure – 6.05Public Call Office (PCO) incentives 107.93 10.08 3.86 Annexure – 6.06Total 666.13 57.62 25.82
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On being pointed out by Audit, it was stated by Management that -
• In certain prepaid tariff scheme, if free airtimewas provided to subscribers on
making recharge through specified recharge vouchers denominations, the tariff
amounts which were actually paid by the subscribers were ultimately booked as
revenue. These tariff schemes were within the TRAI guidelines.
• Itwasnotpossible to treatpromotionaloffersasanexpensesince itwasnotan
expense incurred by the company.
• TDSATorderdated23April2015holds that“inorder tobecountedas“gross
revenue”, the item of inflow must not be notional but real”.
• TheCompanyisgivingrechargecouponwithfreeairtime/promotionaloffers to
PCO operators which were normal voucher with higher denominations and tariff
scheme for the same were already approved by TRAI.
Audit views regarding the netting are brought out in para 3.2.1 B. Further, reply of the
Management is not tenable as-
• FATincludedinauditobservationsdidnotincludethosetariffschemesinwhichfree
air time is provided to subscribers on making recharge through specified recharge
voucher denominations.
• Annexure-IIIofthelicenceagreementstatesthat“Servicerevenue(amountbillable)
shall be shown gross and details of discount/rebate indicated separately”. This
indicates that service revenue should be shown gross, however the Management has
set-off the promotional offers while preparing AGR statements, which was against
the licence agreement.
• WhilenotingthattheappealhasalreadybeenfiledbyDoTbeforetheHonourable
SC against TDSAT Judgement of April 2015, Audit is of the view that offers to
customers (FAT etc.) are part of overall commercial strategy to enhance business
and the cost of such offers amount to expenses.
• Promotionaloffersfornormalconnections/PCOoperatorsweregenerallygivento
popularize new rate plans and to attract new subscribers etc. Therefore it was a part
of overall commercial strategy to enhance business. Hence, it amounts to expenses.
Thus, netting off of offers/discount/rebate amounting to ` 666.13 crore given to
pre-paid subscribers has resulted in understatement of GR/AGR, which ultimately resulted
in short payment of LF and SUC to Government of India amounting to ` 57.62 crore and
` 25.82 crore respectively.
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6.2.2 Under reporting of revenue due to netting off of discounts granted to post-paid
subscribers
From the examination of data/records pertaining to post-paid services furnished by ICL
for the period from 2006-07 to 2009-10, it was observed that promotional discounts were
shown separately as debit figures under the post-paid revenue GL codes by one LSA
(UP West) and netted off from AGR instead of booking the same separately as expenditure.
Since no other LSA had shown the amount of promotional discount separately and booked
the revenue net of such discounts, audit applied the similar percentage as that of UP (West)
LSA to arrive at the total promotional discount offered to post-paid customers. The amount
worked out to ` 202.79 crore in the remaining 21 LSAs.
Promotional discounts are part of overall commercial strategy to enhance business,
therefore, such offers/discounts were in the nature of expenses and hence, in terms of
licence agreements, should not be deducted from GR.
To an audit query, it was stated by Management that-
• AsperAS-9,revenuewasdefinedastheconsiderationreceivedincashfromsaleof
goods or rendering services. There was no realization of such rebate and waiver in
the hands of the Company and thus it could not be treated as revenue.
• AsperTDSATjudgementdated30August2007,amountofwaiversanddiscounts
could not be treated as revenue forming part of GR and licensees cannot be asked to
pay licence fee thereon.
• BillableamountsformpartofAGRandLF/SUCwascomputedonthesameafter
reversal of the effects of incorrect/excess amounts billed earlier.
• It was customary in business to offer certain waivers/rebate to subscribers, the
amounts of which were credited in the bills. Such waivers/discounts/rebates were
losses to the company and could not be treated as revenue.
• Billingplanbaseddiscountswerethosewhichwereofferedtosubscribersasper
agreed terms and billing plan at the time of acquisition. Due to system constraints
the billing pattern cannot be changed and hence the customer cannot be charged zero
towards rental in subsequent months. These discounts are only adjustments entries
for amount charged extra due to system constraints.
• Subscribers are offered someminutes/ usage in every post-paid planwhichwas
known as Usage Discount Package (UDP) and was part of billing plan duly filed
with TRAI. Such UDP was applied at the time of running the bill cycle due to
system limitations and such minutes/usage offered with plan cannot be rated on real
time basis.
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• In the adjustment figures available in GL of UP (West) LSA which was taken
as base by audit for arriving at extrapolated amount for other LSAs is incorrect.
However, for internal reporting purpose UP (West) LSA passed additional entry
to the extent of minutes offered to subscribers by debiting GL code pertaining to
Post paid promotional airtime and crediting GL code pertaining to post paid airtime
revenue. Both the GL codes were under the revenue segment.
Audit view on the reply of the Management is as under-
• ConsideringthereplyoftheManagementthatboththeGLcodeswereunderthe
revenue segment and it was an additional entry passed for internal management
reporting, the amount of promotional discount which earlier worked out to ` 479.52
crore was reworked to ` 202.79 crore (Annexure - 6.07) with only those debit
figures in the revenue head which had corresponding credit entry in the Debtors GL
code.
• RegardingrevenuerecognitionasperAS-9statedbyManagement,itisstatedthat
Audit is not disputing the accounting methodology adopted by the Company but
contends that for the purpose of licence fee, the revenue is to be recognised “Gross”
without set-off of related expenses as mandated under licence agreement.
• TDSATjudgementdated30August2007mentionedinthereplyhasbeensetaside
by the Supreme Court vide its judgement dated 11 October 2011
• Incaseofbillingplanbaseddiscounts,allsuchdebitsintherevenueheadshada
corresponding credit to the Sundry debtor heads thereby reducing the revenue to
that extent. The advance rentals were accounted for through the liability heads and
the contention of the Management that due to system constraints the customer was
charged rental and the same was adjusted by promo pack is neither acceptable nor is
in compliance with the existing norms.
• TheamountworkedoutaspromotionaldiscountwastakenfromtheJournalVouchers
wherein the revenue heads were debited with corresponding credit to the debtors
thereby impacting the revenue to that extent.
Non consideration of promotional discounts, rebates and waivers offered to
post-paid customers in GR/AGR in violation of the terms of licence agreement resulted in
non-payment of LF and SUC amounting to ` 17.80 crore and ` 8.37 crore respectively.
6.2.3 Under reporting of Roaming Revenue due to set-off of Inter Operator traffic
discounts paid/credited to other Operators
ICL had arrangements with other International Operators for roaming. It was noticed that
the Inter Operator traffic (IOT) discounts paid/credited to these operators’ accounts were
debited/deducted from the revenue heads.
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Having roaming arrangement with other national/international operators was a matter of mutual agreement between two operators and giving discounts over and above the agreed charges for roaming was part of overall commercial strategy to enhance business between the two operators. As such, these discounts were in the nature of expenses and hence, in terms of licence agreements, should not be deduced from revenue.
It was observed that IOT Discounts amounting to ` 28.74 crore during 2007-08 to 2009-10 were debited from roaming revenue.
On being pointed out by Audit, it was stated by Management that-
• IOTdiscountswerevolumebasedandlinkedtothequantumofroamingdurationby their subscribers on the company’s network. Such roaming discounts were trade discounts and the company’s recognition of the roaming revenue net of trade discount is in line with prescribed accounting standards. Such trade discounts passed on to other operators on roaming cannot be added back for calculation of AGR.
• Discountswhenpassedonreducethequantumofroamingrevenue.Similarly,whenreceived, they reduce the pass through payable for out roaming leading to higher AGR. Hence, if the recipient operator is required to include gross roaming charges as revenue and the payer operator is only allowed deduction of net roaming charges, it will lead to double taxation to the extent of discount on roaming charges.
• As perAS-9, “trade discounts and volume rebates given should be deducted indetermining revenue”.
Audit view on the reply of the Management is as explained in para 3.2.3. Further view of the audit on the Management reply is as follows:
• Theargumentofdoubletaxationisnottenableastheamountoflicencefeepaidwasin effect a revenue share and not tax.
• RegardingrevenuerecognitionasperAS-9statedbyManagement,itisstatedthatAudit is not challenging the accounting methodology adopted by the Company but for the purpose of licence fee, the revenue is to be recognised “Gross” without set-off of related expenses as mandated under licence agreement.
Netting off of IOT discounts amounting to ` 28.74 crore given to international roaming operators resulted in reduction of GR/AGR which ultimately resulted in short payment
of LF and SUC amounting to ` 2.72 crore and ` 1.21 crore respectively to DoT
(Annexure – 6.08).
6.2.4 Under reporting of revenue from Infrastructure sharing revenue from other
telecom operators for GR/AGR by ICL/ABTL
Telecom infrastructure (towers, network equipment’s, etc.) owned by ICL/ABTL were
being shared with other telecom companies. ICL/ABTL entered into agreements with other
telecom companies for infrastructure sharing.
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Review of data/records pertaining to Infrastructure Sharing Charges furnished by
ICL/ABTL for the period from 2006-07 to 2009-10, revealed that Infrastructure sharing
charges recoverable/recovered on account of rent, fuel (Diesel), Electricity, Operational
and Maintenance, Insurance, Security etc. were netted off from the expense heads, hence
not included in the revenue at all.
Total amount netted off from the expenses on account of site sharing revenue (rent, Diesel,
Electricity, Operational and Maintenance, Insurance, Security etc.) during 2006-07 to
2009-10 was ` 344.72 crore. This amount should have been taken to GR/AGR.
To an audit query, it was stated by Management that-
• Some part of Operating Expenditure (OPEX) cost in the Infrastructure sharing
charges, which was in the nature of Rent, fuel, security, AMC cost and repairs
and maintenance were proportionately recovered from other operators sharing the
infrastructure on actual cost incurred. Such re-imbursement of expenses cannot
be revenue since this was covered under paras 46 and 47 of AS-29 and cannot be
disclosed as revenue in compliance with AS requirements and hence do not form part
of AGR.
While charges for Capital Expenditure (CAPEX) costs were rentals and hence treated
as revenue which was credited to the relevant income/revenue head and disclosed
under revenues in the books of accounts, recovery of combined operation costs
incurred for day to day running and maintaining such common passive infrastructure
equipment by the host operator cannot be included for the purpose of AGR.
The cost incurred on the specific heads of expenditure by the principal owner was
always more as compared to recovery of this expenditure made from the beneficiary
party. Thus, re-imbursement of operating expenditure cannot be considered for AGR.
It was not a case where any revenue item and cost items were netted off and that
revenue was recognized short or not recognized. This was the case of reimbursement
of incurred costs as operating costs were paid by one operator but have to be shared
by more than one operator and there was no way that such payment towards shared
cost by one operator to another can be treated as revenue.
• InMaharashtra LSA, rectification entries, reversal of expenses and credit notes
issued amounting to ` 17.79 crore was incorrectly considered as recovery towards
infrastructure sharing. In Haryana LSA, rectification entries and reversal of
expenses amounting to ` 1.57 crore was incorrectly considered as recovery towards
infrastructure sharing. In Mumbai LSA, recovery amounting to 1.01 crore towards
security service charges was not pertaining to Mumbai Circle.
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Audit view on the reply of the Management on infrastructure sharing revenue is explained
in detail in para 3.2.4. However, rectification/reversal/credit-note entries amounting to
` 20.37 crore which were not considered initially by audit and were brought to notice
vide Management’s reply have been considered. Accordingly, the figure of ` 344.72 crore
initially pointed out was revised to ` 324.35 crore.
Thus netting off of infrastructure sharing revenue received/receivable from other telecom
operators from the cost relating to 2006-07 to 2009-10 resulted in understatement of
GR/AGR by ` 324.35 crore and consequent non-payment of LF and SUC amounting to
` 27.69 crore and ` 13.35 crore respectively (Annexure – 6.09).
6.2.5 Non consideration of revenue from Switch sharing between Idea (NLD) and
Idea (LSAs) for GR/AGR
As mentioned in para 1.4 (a) above, the GR shall be inclusive of all types of revenue
stated therein without any set-off for related item of expense, etc and AGR is arrived at by
reducing GR by permissible deductions as stated therein.
ICL obtained licence to provide long distance services from December 2006. These services
are basically to carry a call from one licence area/circle to another licence area/circle which
requires switches.
Review of records of ICL for the period from 2006-07 to 2009-10 revealed that the Idea
NLD division did not have its own switches and therefore it used the switches of all service
areas for which NLD division paid an agreed amount of ` 0.07/0.10 per minute of call
carried. Though these amounts were paid by Idea NLD to the respective LSAs, the same
was not considered as revenue for determination of GR/AGR by the respective LSAs and
this revenue was found credited under expenditure Head of NLD switch and other expenses.
This resulted in understatement of revenue by ` 252.47 crore for the period under audit.
To an audit query, it was stated by Management that-
• NLDserviceswerebeingusedtocarrycallsfromoneserviceareatootherservice
area. For speedy roll out of services and to achieve saving in CAPEX, the company
integrated its NLD switch with CMTS/UASL switches as permitted under the NLD
licence agreement.
• NLDserviceswereusingswitchesofotherLSAsforroutingthelongdistancetraffic.
Since these switches were capitalized in respective LSA books, all maintenance,
repair and depreciation expenses were also incurred and accounted in respective
LSA itself. Hence, such LSAs were reimbursed for use of switches by NLD division
to reflect the correct profitability of each segment.
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• Thecontentionof considering such sharing of switch expense between LSAs and
NLD as revenue of LSAs was against prescribed accounting norms and such notional
transactions should not be considered as revenue for the purpose of calculation of
AGR.
The reply of the Management itself states that the LSAs were being reimbursed by NLD for
utilizing their switches and hence was in the nature of infrastructure sharing. In terms of
licence agreement, GR includes revenue from permissible sharing of infrastructure without
any set-off for related item of expense. Thus the actual amount received by LSAs from
NLD division should be reflected in their accounts as revenue and taken into consideration
of GR/AGR. Booking of revenue received from NLD division towards switch sharing as
a credit under expenditure head of account by LSAs was not permissible under UASL
agreement.
Thus non consideration of Switch sharing revenue received by the LSAs from Idea
NLD division during 2006-07 to 2009-10 has resulted in understatement of GR/AGR by
` 252.47 crore and consequent non-payment of LF and SUC amounting to ` 22.63 crore
and ` 9.78 crore respectively (Annexure - 6.10).
6.2.6 Non consideration of revenue by ICL from assets given on Indefeasible Right to Use (IRU) for GR/AGR
In terms of clause 19.1 of the UASL agreement and NLD licence agreement, revenue from
permissible sharing of infrastructure and leasing of infrastructure respectively shall form
part of GR for computation of revenue share.
A sum of `1.13 crore was accounted as revenue under a separate Trial Balance maintained
for Passive Infrastructure Division of Idea Cellular Limited (ICL) for the year 2009-10 and
it was included in the Service Revenue in the Profit and Loss Account of ICL.
Review of data/records pertaining to Infrastructure sharing charges offered by ICL for the
2009-10 revealed that this was revenue accruing from the Optical Fibre Cable (OFC) given
to Tata Teleservices Limited (TTSL) on Indefeasible Right to Use (IRU) basis in the service
areas of UP (W), MP, Bihar, AP and Gujarat. However, this revenue was not considered
in GR/AGR for computation of revenue share for the year 2009-10.
To an audit query, it was stated by ICL Management that the Company was holding
Infrastructure Provider Category-I registration issued by DoT and licence fee was not
applicable on revenue arising out of provisioning of services under this registration. The
revenue highlighted by audit during 2009-10 pertains to passive Infrastructure Division
of ICL and accounted from sale of Optical Fibre Cable (OFC) to TTSL under IRU. This
revenue was shown under service revenue for preparation of Profit and Loss Account of
ICL but since licence fee was not applicable on this revenue, it was not considered in GR/
AGR for computation of revenue share (LF and SUC).
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The reply is not tenable considering the fact that revenue was from sale of OFC under IRU
and hence akin to the activity covered under NLD licence. Thus non consideration of IRU
revenue received by ICL during 2009-10 has resulted in understatement of NLD GR/AGR
by ` 1.13 crore and consequent non-payment of LF amounting to ` 0.07 crore.
6.2.7 Under reporting of revenue from forex gain (revenue) for GR/AGR by
ICL/ABTL
Review of data/records furnished by ICL/ABTL for the period from 2006-07 to 2009-10
revealed that the forex realized gain amounting to ` 53.58 crore was not considered for
GR/AGR.
Above realised gain calculated from the data extracted from the reports generated from
Oracle Financial System did not represent the actual gain of that particular item since the
Company recasts the value of all the items included under the foreign exchange gains/losses
head every year, the matured items are accounted under realised gains and the un-matured
items remain under unrealised gain. Thus, the realised gain of a particular item in that year
would not be the actual gain due to accounting of the gains/losses of that item during the
intermediate period under unrealised. Audit could not arrive at the actual value of items
accounted under realised gain every year for want of original value of each item. Further,
audit has considered the quarterly net gain, head of account-wise and LSA-wise, as it was
not possible for audit to segregate/collect the figures of gains only from the data made
available. The operator should calculate the gain of each item with reference to its initial
value of accounting and include the total forex gain in GR/AGR.
On being pointed out by Audit, it was stated by the Management that:-
• Audithasreferredclause19.1ofthelicenceconditionrelatingtoGrossRevenueand
queried on why foreign exchange fluctuations should not be added for the purpose of
AGR. The words used in clause 19.1 to define GR are those primarily from inflows
of licensee i.e. revenue relating and inclusive of those charges, fees, proceeds and
revenues which will go into invoicing of services and goods to get the consideration
which form part of service revenue of the licensee.
• Foreign exchange gains, between the rate of forex when the liability was first
recorded in the books and the rate of forex as and when such liability was finally
discharged, cannot be said to have any meaning so as to form part of Gross Revenue
mentioned under clause 19.1.
• Foreignexchangefluctuationsarisingoutofre-statementofpayablestowardscapital
equipment and foreign currency loans for mark to market or hedged closing rates
as of the end of any closing date was not revenue. Fluctuations in foreign exchange
rates have nothing to do with the revenue of the service provider. The impact of
forex fluctuations, whether upward or downward, on AGR must be ignored.
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• AsperAccountingStandard9onRevenueRecognition,ForeignExchangeGainis
not revenue.
• TDSAT in its judgementdated30August2007held thatForeignexchangegain
should not be considered for AGR purpose.
• According toTRAI, impactof foreignexchangefluctuations,whetherupwardor
downward, on AGR must be ignored.
Reply of the Management is not tenable as:-
• Auditviewregardingclause19.1ofthelicenceagreementhasbeenbroughtoutin
para 3.2.5.
• Companyhadbeenreportingexchangedifferences(onnetbasis)intheirfinancial
statement. It is not true that foreign exchange gains/losses are neither covered in the
definition of GR in the Licence Agreement nor disclosed in the Statement of AGR
as Licence Agreement provides that “Gross Revenue shall be inclusive of any other
miscellaneous revenue, without any set-off for related item of expense, etc.” and
Forex gain was part of Miscellaneous revenue.
• AS-9onlystatesthatrealisedorunrealisedgainsresultingfromchangesinforeign
exchange rates and adjustments arising on the translation of foreign currency financial
statements were not included within the definition of “revenue” for the purpose of
this Standard (AS-9). Treatment of forex gain/loss is covered under AS-11.
• TDSATjudgmentdated30August2007referredinthereplywassetasidebythe
Honourable Supreme Court judgement dated 11 October 2011.
• TRAIrecommendationreferredtointhereplyhasnotfinallybeenacceptedbyDoT.
Thus non-inclusion of foreign exchange gains pertaining to period from 2006-07 to 2009-10
has resulted in understatement of GR/AGR by ` 53.58 crore, and consequent short payment
of LF and SUC amounting to 4.45 crore and 2.00 crore respectively (Annexure - 6.11).
6.3 Under reporting of revenue in the Statements of Revenue and LF (AGR
Statements) though reported in the books of accounts
6.3.1 Non consideration of Interest Income for GR/AGR by ICL/ ABTL
Review of data/records furnished by ICL/ABTL for the period from 2006-07 to 2009-10
revealed that interest income accounted in the books of accounts of ICL was considered
for GR/AGR in the year 2006-07 but not considered at all in the years 2007-08, 2008-09
and 2009-10. Amount of interest income accounted in the books were ` 566.87 crore out
of which ` 17.08 crore only was considered for GR/AGR during the years from 2006-07 to
2009-10 resulting in non-consideration of interest income amounting to ` 549.79 crore for
the purpose of GR/AGR (Annexure - 6.12).
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Likewise, interest income accounted in the books of accounts of ABTL amounting to
` 10.49 crore in the year 2008-09 was not included in GR/AGR.
Management in its reply stated that considering the TDSAT judgement dated 30 August 2007,
interest income accounted under Trial balances of UASL/NLD/IP1/ILD/ISP/VSAT was
not considered for AGR. Interest income accounted under corporate trial balances was
not considered as it did not relate to telecom operations. It further stated that the interest
accounted in the corporate TBs was earned from deployment of surplus funds/borrowed
funds and it being non telecom revenue needs to be excluded from AGR. It also stated that
sometimes funds borrowed for CAPEX were invested and interest earned and this interest
being always less than the interest payable/paid on borrowings, no interest income was left
for inclusion in AGR for levy of revenue share. Telecom services in Bihar LSA commenced
in October 2008, the very first year of commercial operations for which service revenue
for the year 2008-09 was ` 43.53 crore. ABTL had procured loans of over ` 300.00 crore
to roll out CAPEX out of which ` 120.00 crore was from the Holding Company i.e. ICL.
While the loan from ICL was interest free, interest was incurred on other loans. This was
a project situation where services were just launched in few districts of Bihar, a major roll
out was in progress. In such situations other than short term deployment of excess funds
before the funds are used for CAPEX, there cannot be any excess funds. Project funding in
telecom results in mismatch of loans disbursed and final use of proceeds, thereby resulting
in treasury income as also treasury expenses. Cash surpluses generated by business are used
for investing in other forms (other than in CAPEX) for business due to the loan conditions
of the lenders. If at all interest incomes are to be included, it should be done only after
taking the interest costs into consideration. Considering the above, interest income should
not be included in GR/AGR.
The Management’s contention for non-inclusion of interest income for AGR is not tenable as
TDSAT judgement dated 30 August 2007 has become null and void after Hon’ble Supreme
Court judgement dated 11 October 2011. Also definition of GR in licence agreements
expressly provides for inclusion of interest income for GR/AGR for computation of revenue
share.
Impact on short payment of LF and SUC due to non-consideration of interest income
` 560.28 crore in GR/AGR of ICL/ABTL during the years 2007-08, 2008-09 and 2009-10
is ` 44.59 crore and ` 20.47 crore respectively (Annexure - 6.12).
6.3.2 Non consideration of profit on sale of Investment for GR/AGR for payment of revenue share by ICL/ ABTL
Format of Statement of Revenue and LF (AGR Statement) prescribed as Appendix II to
Annexure II as referred in Clause 20.4 of the UASL agreement is an integral part of the
Licence Agreement. In the Statement, item 4 has been prescribed to reflect the “Income
from Investment”.
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From the data/ records of ICL, it was found that there was income on account of “Profit
on Sale of Investment” for ` 8.13 crore, ` 43.18 crore, ` 222.75 crore and ` 87.87 crore
for the year 2006-07, 2007-08, 2008-09 and 2009-10 respectively. Above income had been
accounted by ICL in the Corporate TB. Above income on “Profit on Sale of Investment”
was considered for GR/AGR for computation of revenue share in 2006-07. However an
amount of ` 353.80 crore (Annexure - 6.13) pertaining to “Profit on Sale of Investment”
was not considered in GR/AGR for computation of revenue share for the years 2007-08,
2008-09 and 2009-10. Similarly in respect of ABTL, investment income of ` 45.03 crore
for the year 2008-09 was not included in GR/AGR.
Management in reply stated that considering the TDSAT judgement dated 30 August 2007,
income from investment accounted under Corporate TB was not considered for AGR. It
further stated that this corporate income was generated from treasury function which was
a separate and distinct function from licenced activity and this income was a non-licenced
activity/non-operational income. Therefore such corporate income should not form part of
GR. It was further stated that Telecom services in Bihar LSA commenced in October 2008,
the very first year of commercial operations for which service revenue for the year 2008-09
was ` 43.53 crore. ABTL had procured loans of over ` 300.00 crore to roll out CAPEX
out of which ` 120.00 crore was from the Holding Company i.e. ICL. This was a project
situation where services were just launched in few districts of Bihar, a major roll out was in
progress. In such situations other than short term deployment (investments) of excess funds
before they are used for CAPEX, there cannot be any excess funds. Project funding in
telecom results in mismatch of loans disbursed and final use of proceeds, thereby resulting
in treasury income as also treasury expenses. Cash surpluses generated by business are used
for investing in other forms (other than in CAPEX) for business due to the loan conditions
of the lenders. Considering the above, profit on sale of investment should not be included
in GR/AGR.
The Management’s contention for non-inclusion of income from investment for GR is
not tenable as TDSAT judgement dated 30 August 2007 has become null and void after
Honourable Supreme Court judgment dated 11 October 2011. Further, licence agreements
provide for inclusion of income from investment in GR/AGR for computation of revenue
share.
Thus, non-consideration of income from investment in GR/AGR for ` 398.83 crore by
ICL/ABTL during the year 2007-08 to 2009-10 resulted in non-payment of ` 33.36 crore
as LF and ` 14.49 crore as SUC (Annexure - 6.13).
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6.3.3 Non consideration of miscellaneous income for AGR for computation of LF/
SUC by M/s ICL
In the Profit and Loss Account of ICL, revenue/income grouped under the Schedule of
“Other Income” is further sub grouped in two categories- (i) Liability/Provisions written
back and (ii) Miscellaneous receipts. From the AGR statements, it was found that amount
of other income grouped under first category was not considered for AGR in the years
2006-07 to 2009-10 whereas income grouped under second category (Miscellaneous receipt)
was considered for AGR in the years 2006-07 and 2009-10 but partly considered in the
years 2007-08 and 2008-09.
Amount of miscellaneous Income (excluding insurance claims) for the years 2007-08 and
2008-09 are ` 9.37 crore, out of which only ` 1.04 crore was considered for AGR and
balance amount of ` 8.33 crore was not considered (Annexure - 6.14).
To an audit query, the Management stated that:-
• Withregardtomiscellaneousreceipts,suchreceiptswereincidentaltobusinesssuch
as scrap sale, insurance claims etc. which do not have any connection with telecom
operations under the licence agreement.
• As per TDSAT judgement dated 7 July 2006, the principle for computation of
licence fee would be based on AGR. Licence fee would be paid only on revenue
earned from licenced activities (and not from unlicenced activities). As per TDSAT
judgement dated 30 August 2007, which was agreed with by DoT, revenue from sale
of fixed assets which was in the nature of capital receipts and insurance claims should
not be part of AGR and other items falling under the categories of miscellaneous/
other income would have to be decided for taking a view regarding its inclusion or
exclusion on a case to case basis.
ICL’s Management reply is not tenable since
• DefinitionofGRexpresslyprovidesthatmiscellaneousincomeshouldbeincluded
in GR for computation of revenue share. Management contention that these
miscellaneous income were from non-licenced activity and hence not liable to be
included in AGR is not acceptable. These miscellaneous incomes were incidental to
licenced activities only.
• The Company’s contention that DoT agreed with the TDSAT judgement dated
30 August 2007 was not correct as DoT challenged it and Hon’ble Supreme Court
set aside the TDSAT judgement vide its judgement dated 11 October 2011.
• Insuranceclaimincludedinmiscellaneousrevenuewasexcludedbyauditforarriving
at the amount of miscellaneous income not considered for GR/AGR.
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As such, items of miscellaneous income amounting to ` 8.33 crore not considered in
respective AGR should be included in AGR for computation of LF/SUC. Impact on short
payment of LF and SUC due to non-consideration of miscellaneous income in GR/AGR was
` 0.70 crore and ` 0.32 crore respectively (Annexure-6.14).
6.3.4 Non consideration of Income from profit on sale of fixed assets for AGR for
payment of revenue share by ICL/ABTL
From the examination of data/records furnished by ICL for the period from 2006-07 to
2009-10, it was noticed that gain on sale of fixed assets of ` 16.00 crore (Annexure - 6.15)
was found to be adjusted against other administrative expenditure in the Profit and Loss
account of ICL during 2007-08, 2008-09 and 2009-10 and was not included in GR/AGR
for consideration of LF/SUC.
Similarly, in case of ABTL, profit on sale of fixed assets of ` 0.12 crore was not included
in GR/AGR for consideration of LF/SUC.
To an audit query, the Management stated that –
• Thecompany’saccountingtreatmentandpresentationofaccountswasinaccordance
with Schedule VI of the Companies Act. Any loss/gain on sale was capital receipt
in nature. The investments made in assets were resulting in generation of revenue
which was subject to licence fee. Sale proceeds from disposal of such assets resulting
in either Gain/loss are nothing but the recovery of the amount higher than the
Written down Value of Assets in the books. This gain was really not a gain since
the benefit of depreciation was not availed earlier. This would also tantamount to
charging licence fee on revenue from operations as well as the capital expenditure
portion earlier put for business. This revenue was in nature of capital revenue and it
was not derived from licenced activity and hence it should not be included in AGR
for computation of LF.
• ConsideringtheTDSATjudgementdated30August2007,therevenueonaccount
of profit on sale of fixed assets was not considered for AGR.
The contention of the Management is not tenable since-
• DefinitionofGRexpresslyprovidesthatmiscellaneousincomeshouldbeincludedin
GR for computation of revenue share. Further, licence agreements did not differentiate
between licenced activity and non-licenced activity. In terms of definition of GR,
Gross Revenue shall include all revenue accruing to the Licensee without any set-off
for related item of expense and revenue earned as above was incidental to licenced
activity only. The Company had also considered it for inclusion in AGR in the year
2006-07.
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• TDSATjudgementdated30August2007hasbecomenullandvoidafterHonourable
Supreme Court judgment dated 11 October 2011.
Thus non-inclusion of income of ` 16.12 crore on account of profit on sale of fixed asset
in GR/AGR for computation of Revenue resulted in short payment of LF and SUC by
` 1.54 crore and ` 0.69 crore respectively (Annexure – 6.15).
6.4 Short/ non-payment of revenue share due to other issues
6.4.1 Irregular Deduction of Bad debts written off from GR to arrive at AGR by ICL
Review of data/records provided by ICL for the period from 2006-07 to 2009-10 revealed that for 2009-10, ` 173.31 crore was included under Administration and Other Expenses as “Bad debts Written Off”. However, in the year 2009-10, an amount of ` 172.18 crore on account of “Bad debts Written Off” was deducted from GR while arriving at AGR pertaining to eight LSAs3.
To an audit query, Management stated that considering the TDSAT judgement dated 30 August 2007, the Company claimed deduction of “Bad Debts Written Off” during the 2009-10 while preparing the Annual Audited AGR for the aforesaid eight LSAs amounting to ` 172.18 crore. However, while making licence fee and spectrum charge payment to DoT, the Company had not taken deduction of “Bad Debt Written Off” and to that extent the Licence Fee and Spectrum Usage Charges amounting to ` 25.19 crore was paid in excess. It was further stated that during 2009-10, ` 173.31 crore was written off as Bad Debts resulting in the reversal of the provision for such doubtful receivable created earlier. The entry for effecting this write off of the receivables was passed by debiting the expense GL Code for provision and crediting respective debtors and Service Tax account in the circle books of accounts which resulted in re-grouping of ` 173.31 crore from provision for Bad and Doubtful debts/Advances (Expense) to Bad debts Written Off (Expense). However, the charge to Profit and Loss Accounts during 2009-10 was only ` 47.29 crore.
The contention of the Management is not tenable since the TDSAT judgement dated 30 August 2007 has become null and void after Hon’ble Supreme Court judgment dated 11 October, 2011. Further, the licence agreement does not provide deduction of bad debt from GR to arrive at AGR and the licensee itself did not deduct the bad debts written off from GR to arrive at AGR during the year 2006-07, 2007-08 and 2008-09. Though the Company stated that it paid LF and SUC on “Bad Debt Written Off”, Audit observed that in the audited AGR statement, the same was claimed as deduction which was against the licence agreement. Further, in the absence of documentary evidence to show that amount waspaid,thereplywasnotverifiable.QuarterlypaymentmadebytheCompanyonthe
basis of unaudited AGR would be considered by DoT at the time of assessment which
would be based on audited AGR statement only.
3 AP,Delhi,Gujarat,Haryana,Kerala,Maharashtra,MPandUP(W).
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Thus deduction of bad debts from GR to arrive at AGR in audited AGR statement resulted
in understatement of GR by ` 172.18 crore having impact on LF and SUC by ` 16.89 crore
and ` 7.03 crore respectively (Annexure - 6.16).
6.5 Other issues
6.5.1 Transfer of infrastructure assets by Idea Cellular Ltd to its subsidiary at NIL
consideration for ultimate transfer to a Joint Venture
ICL was initially promoted (March 1995) by Aditya Birla group of companies including
ABTL. However, ABTL ceased to be the promoter from 29 August 2006 and became a
subsidiary company of ICL from 28 February 2007. ABTL obtained UAS Licence for Bihar
LSA (December, 2006) but commenced its telecom operations only in 2009-10.
ICL established three new subsidiaries namely, Idea Cellular Services Limited (ICSL) and
Idea Cellular Infrastructure Services Limited (ICISL) (incorporated on 3 October 2007) and
Idea Cellular Tower Infrastructure Limited (ICTIL) (incorporated on 3 December 2007).
ICTIL was a wholly owned subsidiary of ICISL and hence the subsidiary of ICL.
A scheme of arrangement between ICL and ICTIL for demerger of passive infrastructure
of ICL and transfer of these infrastructures to ICTIL in 9 LSAs4 with appointed date
1 January 2009 was approved by the High Courts of Delhi and Gujarat and the scheme
became effective from 29 September 2009. Accounting entries in the books of accounts of
ICL and ICTIL were made in the year 2008-09 as per the scheme. Accordingly in the books
of ICL, book value of assets of ` 1622.78 crore was removed from books and investment
in its subsidiary, ABTL, (holding company of ICTIL) was increased by the same amount.
In the books of ICTIL, above assets were recorded at their book value with corresponding
credit to General Reserve.
Another scheme of arrangement between ABTL and ICL for transfer of UASL and related
assets and liabilities of ABTL (of Bihar LSA) with appointed date 1 April 2009 was
approved by the High Courts of Bombay & Gujarat which became effective from 1 March
2010. Accounting entries in the books of accounts of ICL and ABTL were made in the
year 2009-10 as per the scheme. Accordingly in the books of ABTL, net book value of
asset of ` 2069.45 crore was written off and same amount was withdrawn from Reserve for
Business Restructuring. In the books of ICL, assets & liabilities transferred were recorded
at their book value and ` 2069.45 crore was credited to General Reserve.
Thus, it is apparent that the assets were transferred by ICL and ABTL at NIL value since
the transferee companies (ICTIL and ICL) accounted the value of assets at book value
with corresponding credit to General Reserve. The transfer of assets at NIL value was not
a transaction at arm’s length since all the three companies were different entities. Due to
4 AP,Delhi,Gujarat,UP(E),UP(W),Haryana,Kerala,RajasthanandMumbai.
Report No. 4 of 2016
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accounting of assets at book value by the transferee companies and pending revaluation,
the profit foregone by the transferor companies and its effect on LF and SUC could not be
quantified.
6.6 Interest on short/non-payment of LF and SUC
On issues raised above (from paras 6.2 to 6.4) short/non-payment of LF and SUC
worked out to be ` 289.99 crore and ` 133.27 crore respectively. The interest on this
short/non-payment of LF and SUC is ` 541.63 crore (Annexure - 6.17). The calculation of
interest was based on the rate prescribed in the Licence agreement i.e. two per cent above
the Prime Lending Rate of State Bank of India existing as on the beginning of the financial
year and the period considered for the calculation was from the end of the concerned
financial year up to March 2015. The interest has been compounded monthly as prescribed
in the licence condition.
6.7 DoT’s response to the audit observations
Audit observations on the revenue shared by ICL were communicated to DoT in
November 2015. Reply of DoT is awaited (January 2016).
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CHAPTER – VIIRevenue shared by Tata Teleservices Limited and
Tata Teleservices (Maharashtra) Limited
7.1 Brief profile of the company
M/s Tata Teleservices Limited (TTSL) was incorporated in 1996 and in December 2002,
TTSL acquired 50.83 per cent of the paid up equity capital of Hughes Telecom India
Limited (HTIL) which had basic licence in Maharashtra. In February 2003, the name of
HTIL was changed to M/s Tata Teleservices (Maharashtra) Limited (TTML), and is an
associate company of TTSL. TTSL provides basic services as well as cellular services on
dual technology i.e., CDMA and GSM.
7.1.1 Licences granted to TTSL and TTML
TTSL was awarded Basic Licence in Andhra Pradesh LSA in September 1997 and in
August 2001 it was awarded Basic Licences for five more LSAs1. Subsequently, during
January-February 2004, twelve2 more UASL licences were granted to the Company. Three
new UAS Licences for Assam, Jammu and Kashmir and North East were awarded in 2008.
TTML holds UASL in Mumbai and Maharashtra. Thus, TTSL and TTML have presence
in all the 22 LSAs.
TTSL holds NLD licence also and TTML holds ISP licence.
7.1.2 Spectrum allotted to TTSL and TTML
Spectrum allotted to TTSL and TTML as on 31 March 2010 were as follows:
Table 7.1
Sl No Spectrum Licenced Service Area
CDMA
1 2 × 5 MHz Andhra Pradesh, Delhi, Maharashtra, Mumbai
2 2 × 3.75 MHz Chennai, Bihar, Gujarat, Haryana, Karnataka, Kerala, Kolkata, Punjab, Rajasthan, UP East, UP West
3 2 × 2.5 MHz Tamil Nadu, Assam, Himachal Pradesh, Jammu and Kashmir, Madhya Pradesh, North East, Odisha, West Bengal
GSM
1 2 × 4.4MHz Andhra Pradesh, Bihar, Tamil Nadu (including Chennai), Gujarat, Haryana, Karnataka, Himachal Pradesh, Kerala, Kolkata, Maharashtra, Madhya Pradesh, Mumbai, Odisha, Punjab, Rajasthan, UP East, UP West, West Bengal
1 Delhi,Gujarat,Karnataka,TamilNaduandChennai.2 WestBengal,Bihar,Haryana,HimachalPradesh,Kerala,MadhyaPradesh,Orissa,Punjab,Rajasthan,UttarPradesh–
West,UttarPradesh–EastandKolkata.
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7.1.3 Subscriber base of TTSL and TTML
The subscribers of TTSL/TTML grew from 1.66 crore as on 31 March 2007 to 6.71 crore
as on 31 March 2010 registering a growth of 305 per cent. TTSL group remained in fourth
position during the years 2006-07 to 2009-10 and its market share increased from 8 per cent
as on March 2007 to 11 per cent as on March 2010.
7.1.4 Gross Revenue, Deduction, Adjusted Gross Revenue reported and revenue
share paid by TTSL and TTML
Telecom Service Providers are required to pay LF and SUC at a percentage of AGR on
quarterly basis on self-assessment basis. GR, Deduction, AGR reported and revenue share
(LF and SUC) paid by TTSL and TTML during these years were as follows:
Table – 7.2
(` in crore)
Company YearGross
Revenue (GR)
Deductions Adjusted
Gross Revenue (AGR)
Percentage of AGR to
GR
Revenue share
TTSL
2006-07 5,015.43 1,570.06 3,445.37 68.7 318.18
2007-08 5,921.93 1,853.03 4,068.90 68.71 370.68
2008-09 6,510.74 2,222.26 4,288.48 65.87 388.91
2009-10 6,125.02 1,497.10 4,627.92 75.56 416.32
Total 23,573.12 7,142.45 16,430.67 69.7 1494.09
TTML
2006-07 1,389.45 358.60 1,030.85 74.19 103.08
2007-08 1,702.95 395.34 1,307.62 76.79 130.76
2008-09 1,912.34 427.39 1,484.94 77.65 148.49
2009-10 2,038.65 387.89 1,650.75 80.97 165.07
Total 7,043.38 1,569.22 5,474.16 77.72 547.42
7.2 Under reporting of revenue by TTSL and TTML
As mentioned in para 1.4 (a), the GR shall be inclusive of all types of revenue stated therein
without any set-off for related item of expense, etc.
Further as mentioned in Annexure-III of UASL agreement, service revenue (amount billable)
shall be shown gross and details of discount/rebate indicated separately.
Audit examination of records/Books of accounts (Vouchers, General Ledger, Trial Balance,
Profit and Loss Accounts, Balance Sheet, etc.) of TTSL and TTML revealed that these
companies had not adhered to the provisions of the licence agreement as discussed below.
Report No. 4 of 2016
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7.2.1 Commission paid to distributors/franchisees/agents/dealers, etc. debited from
the revenue in respect of TTSL
During audit scrutiny of the records of TTSL for the years from 2006-07 to 2009-10, it
was observed that the commission paid to the distributors/franchisees/agents/dealers, etc.,
was netted off from the revenue. Since the commission/margin paid to the distributors/
franchisees/dealers was in the nature of business expenses (marketing expenses), therefore,
set-off of such expenses with revenue was against the licence condition. However, in
respect of TTML, it was observed that commission paid to the distributor/franchisees/
agents/dealers, etc., was treated as expenses.
The total commission netted off from revenue in respect of all the licenced areas of TTSL
during the years 2006-07 to 2009-10 was ` 521.35 crore as confirmed by the management
(Annexure - 7.01). In response to the audit observation, the Management stated that
transactions with the wholesaler/retailer were in the nature of Principal to Principal and
also there was no sub-licence/assignment/transfer of licence as per clause 6 of the licence
agreement. Hence, trade discount or discount on bulk purchase of recharge vouchers (RCV)
and start up kits (SUK) paid to the wholesalers/dealers /retailers should not be added back
for the purpose of computing LF.
Audit view on the reply of the Management regarding Principal to Principal is as explained
in para 3.2.1 (A).
Thus, commission paid to the distributor/franchisees/agents/dealers, etc. netted off from
revenue resulted in understatement of GR/AGR by ` 521.35 crore and short payment of LF
and SUC amounting to ` 47.33 crore and ` 14.25 crore respectively.
7.2.2 Revenue understated due to netting of discounts allowed to subscribers etc. by
TTSL and TTML
Review of data/records furnished by TTSL/TTML for the period from 2006-07 to
2009-10 revealed that the Company offered various schemes/discounts to subscribers
(volume discounts, intra circle discount, content service discount, recharge card discount,
SMS discount, Tata to Tata discount, cash discount, etc.). It was also noticed that the
Company debited these discounts from revenue heads instead of expense heads as a result
of which the revenue considered for AGR was understated.
Since the commission/margin paid to the distributors/franchisees/dealers was in the nature
of business expenses (marketing expenses), therefore, set-off of such expenses from revenue
was against the licence condition.
The total amount netted off from the revenue on account of various discounts worked out
to ` 4814.16 crore and `1476.18 crore in respect of TTSL and TTML respectively for the
period from 2006-07 to 2009-10 (Annexures - 7.02 and 7.03).
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The Management stated that the discounts given by the company were discounts offered as
part of tariff plan filed with TRAI, discounts offered to employees and business associates
and internal lines discount.
Audit view on the management reply is as follows-
Management contention that above discounts were covered under tariff plan submitted to
TRAI is not acceptable since such tariff plans were neither shared with audit nor enclosed
with reply. Further, service revenue should be shown in gross and not be netted off with
any discounts/rebate while preparing the AGR statements as per Annexure-III of the licence
agreement.
Thus, total amount of ` 4814.16 crore and ` 1476.18 crore netted off from the revenue
on account of various discounts in respect of TTSL and TTML respectively resulted
in understatement of GR/AGR by same amount and in short payment of LF and SUC
amounting to ` 444.20 crore and ` 131.77 crore respectively by TTSL and ` 147.62 crore
and ` 48.42 crore respectively by TTML.
7.2.3 Netting of adjustments offered to customers from the GR in respect of TTSL
and TTML
Review of data/records furnished by TTSL/TTML for the period from 2006-07 to
2009-10 revealed that the Company was maintaining separate account heads for various
types of adjustments (billing adjustments, adjustments for collection waivers, bill back
out adjustments, round off adjustments, misc. Adjustments, etc.,) under revenue head of
accounts and all the adjustments made were debited to revenue.
It was also noticed that Companies in order to accommodate adjustments on account of
waivers given to the subscribers debited the value of these adjustments to revenue heads as
a result of which the revenue considered for AGR was understated to that extent.
Since “waivers” were a part of overall commercial strategy to enhance business, they were
in the nature of expenses and set-off such related items of expenses is not allowed as per
the licence agreement.
The total amount of adjustments for collection waivers netted off from the revenue worked
out to ` 128.00 crore and ` 147.73 crore in respect of TTSL and TTML respectively for
the period from 2006-07 to 2009-10 (Annexures - 7.04 and 7.05) leading to AGRs getting
understated by the same extent.
Company, in reply, stated that-
• Theaccountheadsincludeadjustments/waiversetc.giventothecustomers/employees/
outsourced employee etc., in the normal course of the business and revenue was
recognized net of such waivers.
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• Rectification/adjustments were made on account of dispute, wrong billing due to
configuration errors. These errors could relate to excess amount billed, erroneously
billed, payments done in time but still late payments charges levied which was
subsequently waived off. Adjustments to billings/errors in the billings were a normal
part of any business activity and does not result in gross inflow of cash, receivables
or other consideration as a result of wrong/error in billing and hence reversal needs
to be adjusted/setoff against the wrong billing.
Audit view on the Management reply is as follows -
• AspointedoutbyManagement,billingadjustmentandoperatordepositadjustments
have been considered and accordingly figures have been revised.
• Regarding other adjustment pertaining to collection waivers and miscellaneous
adjustments, etc., the contention of the Management is not tenable since they are
part of overall commercial strategy to enhance business; therefore, they were in the
nature of business expenses and set off of related items of expenses is not permitted
in terms of clause 19.1 of the licence agreement.
Thus, the total amount of adjustments for collection waivers/ miscellaneous adjustments,
etc. netted off from the revenue amounting to ` 128.00 crore and ` 147.73 crore in respect
of TTSL and TTML respectively resulted in understatement of GR/AGR and in short
payment of LF and SUC amounting to 11.20 crore and 3.48 crore respectively by TTSL
and ` 14.77 crore and ` 4.85 crore respectively by TTML.
7.2.4 Netting of the revenue from Start up Kit, recharge vouchers etc. by TTSL and TTML
Review of data/records furnished by TTSL/TTML for the period from 2006-07 to 2009-10
revealed that the Company offers various discount on bulk purchase on recharge vouchers
and start up kits to the wholesalers/dealers /retailer. It was also noticed that the Company
debited these discounts from revenue heads as a result of which the revenue considered
for AGR was understated. Since the discount on bulk purchase given to the distributors/
franchisees/dealers was in the nature of business expenses (marketing expenses) setoff of
such expenses with revenue was against the licence condition.
The total amount netted off from the Revenue by TTSL and TTML amounted to
` 104.82 crore and ` 8.50 crore respectively for the years 2008-09 to 2009-10
(Annexures 7.06 and 7.07) leading to AGR getting understated by the same extent.
Management stated that “transactions with the wholesaler/retailer were in the nature of
Principal to Principal and also there was no sub-licence/assignment/transfer of licence as
per clause 6 of the licence agreement. Hence trade discount or discount on bulk purchase
on recharge vouchers and start up kits paid to the wholesalers/dealers /retailer should not
be added back for the purpose of computing licence fee”.
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Audit view on the reply of the management regarding Principal to Principal is as explained
in para 3.2.1 (A).
Thus, the total amount of ` 104.82 crore and ` 8.50 crore netted off from the revenue by
TTSL and TTML respectively resulted in understatement of GR/AGR and in short payment
of LF and SUC of ` 8.90 crore and ` 2.82 crore by TTSL and ` 0.85 crore and ` 0.28
crore by TTML.
7.2.5 Non consideration of income received from infrastructure sharing in GR by
TTSL
During review of audited AGR statements along with notes on statements of TTSL, it was
noticed that during 2008-09 and 2009-10, income towards OPEX receipt for infrastructure
sharing received by the Company was not considered for GR as disclosed by the Statutory
Auditors.
As per terms of licence agreement, GR includes revenue from permissible sharing of
infrastructure without any set-off for related item of expense. Further, licence agreement
does not distinguish infrastructure sharing revenue between CAPEX and OPEX. Hence,
set-off of revenue from infrastructure sharing against the expenses was not allowed.
The total income received from other operators which was not considered for computation
of AGR during the years 2008-09 and 2009-10 amounted to ` 23.49 crore (Annexure - 7.08).
Management replied that :
• ReimbursementofOPEXshouldnotbepartofAGRsincecreditintheexpenses
were primarily on account of the re-classification of expenses, actualization of
accrual of expenses, reimbursement of expenses and insurance claim received which
do not form revenue to the Company in any respect/accounting practices.
• TDSATinitsjudgmentdated23April2015hadclearlylaiddownthatapayment
in the nature of reimbursement of an expense may not be taken as revenue.
While noting that DoT had filed an appeal before Hon’ble Supreme Court against the
TDSAT judgment dated 23 April 2015 as referred in the reply, Audit view on the issue is
as explained in para 3.2.4.
Thus total income received from other operators which was not considered for computation
of AGR amounting to ` 23.49 crore resulted in short payment of LF of ` 2.26 crore and
SUC of ` 0.65 crore.
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7.2.6 Non- inclusion of realized forex gain for computation of GR by TTSL and
TTML
Review of data/records furnished by TTSL/TTML for the period from 2006-07 to 2009-10 revealed that though there was a quarterly realised gain under forex account codes on account of foreign exchange fluctuations accounted in the books of the accounts, the same was not considered for GR /AGR.
Considering only the quarterly realised net gains of account heads operated for forex for the years from 2006-07 to 2009-10, it was seen that realised forex gain amounting to ` 261.75 crore and ` 59.26 crore for TTSL and TTML respectively (Annexures - 7.09 and 7.10) was not considered for AGR.
It is pertinent to mention here that the above realised gain calculated from the data extracted from the reports generated from SAP System did not represent the actual gain of that particular item since the company recasts the value of all the items included under the foreign exchange gains/losses head every year, the matured items are accounted under realised gains and the un-matured items remain under unrealised gain. Thus, the realised gain of a particular item in that year would not be the actual gain due to accounting of the gains/losses of that item during the intermediate period under unrealised. Audit could not arrive at the actual value of items accounted under realised gain every year for want of original value of each item. Further, audit has considered the quarterly net gain, head of account-wise and LSA-wise, as it was not possible for audit to segregate/collect the figures of gains only from the data made available. The operator should calculate the gain of each item with reference to its initial value of accounting and include the total forex gain in GR/AGR.
While confirming the figures pointed out by audit, it was replied by the Management that
• Foreignexchangefluctuationwasacontingencywhichhadimpactoneverybusinessand such gain had not accrued from primary or supplementary services of the Company i.e. providing telecom services to its customers/subscribers. Forex gains result when liabilities for payment in foreign exchange decrease on account of appreciation of domestic currency vis-à-vis foreign currency and such exchange differences arise when rates differ from those at which they were initially recorded in the books.
• Audithasconsideredonlygainignoringthenotionallossrecordedintheheadofaccounts. The forex gain loss, unlike telecom expenditure was not something where the notional gain was to be viewed in isolation of the loss, as these were recorded on the same principles adopted to account for the exchange rate differences at the end of each book closing period. This gets actualized only at the time of payment to the vendor.
• TDSATJudgment dated23April 2015passed inAUSPIvsUnionof India andothers held that “any gain or loss due to foreign exchange fluctuation should have no bearing on the licence fee”.
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Contention of the management was not acceptable as
• Forex gain realised by the Company was incidental to telecom activity. Audit
considered only quarterly net realized gains and unrealized account heads (notional)
were ignored. Further, as per the licence agreement “GR shall be inclusive of ……
any other miscellaneous revenue, without any set-off for related item of expense,
etc,” and forex gain was part of Miscellaneous Revenue.
• AuditnotedthatDoThadgoneonappealagainsttheTDSATjudgementofApril
2015 referred by the Company. While the matter was sub-judice at the Hon’ble
Supreme Court, Audit is of the view that non-consideration of forex gains in the GR
by the Company was a deviation from licence conditions.
Thus, realised forex gain of ` 261.75 crore and ` 59.26 crore not considered for AGR by
TTSL and TTML respectively resulted in short payment of LF of ` 23.59 crore and SUC
of ` 7.15 crore by TTSL and LF of ` 5.93 crore and SUC of ` 1.94 crore by TTML.
7.3 Under reporting of revenue in the statements of revenue and LF (AGR statements) though reported in the books of accounts.
7.3.1 Non consideration of interest income in GR/AGR by TTSL
From AGR statements and Profit and Loss account, it was noticed that interest income of
` 568.69 crore (Annexure - 7.11) accounted in the books of accounts of TTSL for the
period from 2006-07 to 2009-10 was not considered in the GR.
Management informed that entire amount of ` 568.69 crore had been considered for
GR/AGR in May 2011 and the consideration of the interest income was under protest. It
was further stated that these amounts were not to be included for calculation of revenue
share as the definition of AGR was under litigation and would be decided in due course
through judicial process.
The response of the Management was not tenable since definition of GR in licence agreement
expressly provides for inclusion of income from interest in GR/AGR for computation of
revenue share. Though the company replied (November 2015) that the same had been
considered for GR/AGR during May 2011, they failed to submit the document in support
of details of amounts considered for the earlier years and payment made thereto were
not provided to substantiate their claim of payments and in the absence of the same audit
could not verify. Further, in the audited AGR statements for the years 2006-07 to 2009-10
submitted to DoT, interest income as mentioned above were not considered for computation
of LF/SUC in the relevant years.
Thus, non consideration of interest income of ` 568.69 crore resulted in understatement of
GR/AGR for the years 2006-07 to 2009-10 and in short payment of LF and SUC by 51.22
crore and ` 15.53 crore respectively by TTSL.
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7.3.2 Profit on sale of investment not considered in GR/AGR
Format of statement of revenue and LF (AGR statement) prescribed as per Appendix-II to Annexure-II of the UASL agreement is an integral part of the licence agreement. In the statement, item 4 has been prescribed to reflect the “income from investments”. Clause 19.1 of UASL agreement defines GR which, inter alia states that, the revenue includes any other miscellaneous income and further, the revenue shall be without any set off for the related items of expenses.
Audit observed from audited AGR statements and Profit and Loss account of TTSL and TTML that profit on sale of investment (long term /current investment) was not considered for computation of GR for payment of LF/SUC during the years from 2006-07 to 2009-10. The total amount in respect TTSL worked out to ` 2082.87 crore and ` 0.63 crore in case of TTML (Annexures - 7.12 and 7.13). The Company replied that it paid licence fee in the respective financial year in the case of profit on sale of investment in Wireless TT Info Services Limited (WTTIL) (Amount pertaining to period 2008-09 and 2009-10) and licence fee on profit on sale of investment for period 2006-07 and 2007-08 was paid in May 2011.
The reply of the management is not tenable since licence agreement provides for inclusion of income from profit on sale of investment in GR/AGR for computation of revenue share. Though the company replied (November 2015) that the same had been considered for GR/AGR during May 2011, they failed to submit the document in support of details of amounts considered for the earlier years and payment made thereto to substantiate their claim of payments and in the absence of the same audit could not verify. Further, in the audited AGR statements for the years 2006-07 to 2009-10 submitted to DoT, income from profit on sale of investment as mentioned above were not considered for computation of LF/SUC in the relevant years.
Thus, non consideration of profit on sale of Investment of ` 2082.87 crore and ` 0.63 crore by TTSL and TTML respectively resulted in understatement of GR/AGR and short payment of LF of ` 187.63 crore and SUC of ` 56.93 crore by TTSL and LF of ` 0.06 crore and SUC of ` 0.02 crore by TTML.
7.3.3 Non consideration of profit on sale of assets for GR/AGR
From the data/documents (viz. trial balances, audited AGR statements, auditor’s report, notes on accounts/statements and revenue reconciliation statements etc.) provided by TTSL and TTML it was found that revenue received towards “Profit on sale of fixed assets” by both TTSL and TTML during the years 2007-08 to 2009-10 was not considered for computation of GR/AGR in the respective years.
The profit on sale of asset recorded in the books of account of TTSL and TTML for the period from 2007-08 to 2009-10 worked out to 121.25 crore and 35.49 crore respectively (Annexures - 7.14 and 7.15).
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It was replied by the Management that the Company had paid licence fee on profit on sale of assets though the Company firmly believes that this should not be part of AGR.
Reply of the Management is not tenable as Company did not provided any documentary evidence to substantiate their claim of payments and in the absence of the same, the reply could not be verified by Audit. Further, in the audited AGR statement submitted to DoT, the profit on sale of assets was not considered for computation of LF/SUC.
Thus non consideration of profit on sale of asset of ` 121.25 crore and ` 35.49 crore by TTSL and TTML respectively resulted in short payment of LF of ` 10.97 crore and SUC of ` 3.32 crore by TTSL and LF of ` 3.55 crore and SUC of ` 1.16 crore by TTML.
7.4 Short/ non-payment of revenue share due to other issues
7.4.1 Bad debts written off adjusted from the revenue by TTSL resulting in understatement of AGR
From review of data/documents furnished to audit, it was found that TTSL adjusted “Bad Debts written off” for the year ended 31 March 2010 from the respective components of revenue from services while considering the preparation of the statements for the computation of AGR of the respective circles.
The licence agreement does not provide deduction of bad debt from GR to arrive at AGR.
The total amount of “write off of subscriber bad debts” adjusted from the respective components of revenue from services was ` 272.29 crore (Annexure - 7.16).
Management accepted that an amount of ` 272.29 crore had been adjusted from the revenue as bad debts written off.
Thus, adjustment of Bad Debts written off from the respective components of revenue from services of ` 272.29 crore resulted in short payment of LF and SUC by ` 26.64 crore and ` 7.61 crore respectively.
7.4.2 Lease line and Port Charges included in deductions claimed by TTSL and TTML resulting in understatement of AGR
As per the disclosures by Statutory Auditors in the notes to the statements submitted along with the audited AGRs of TTSL for the years 2006-07 to 2009-10, “Access charges considered for computation of Adjusted Gross Revenue (AGR) include leased line charges and port charges actually paid to other carriers during the year concerned”.
Further, in respect of TTML, it was disclosed by the Statutory Auditors that during the years 2006-07 and 2007-08, the leased line and port charges were claimed along with PSTN charges and during 2008-09 and 2009-10, the expenditure towards lease line and port charges were claimed as separate deductions along with other eligible deductions.
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In terms of Clause 19.2 of the UASL agreement, the following shall be excluded from the GR to arrive at AGR.
i) PSTN related call charges (Access Charges) actually paid to other eligible/entitled telecommunication service providers within India.
ii) Roaming revenues actually passed on to other eligible/entitled telecommunication service providers and
iii) Service Tax on provision of services and Sales Tax actually paid to the Government if Gross Revenue had included as component of Service Tax and Sales Tax.
In respect of TTSL for the years 2006-07 to 2009-10, the total expenditure towards lease line and port charges included in the access charges and claimed as deduction worked out to ` 255.41 crore (Annexure - 7.17) whereas in respect of TTML, the same worked out to ` 87.26 crore (Annexure - 7.18).
Management stated that the payments on account of port charges and leased lines were for providing connectivity to the customers were a part of and similar to interconnection costs; which since included in the AGR in the hands of the receiver, would result in double taxation if the same was not allowed as deduction in the hands of the payer.
The reply of the Management is not tenable since lease line and port charges paid were actually an expense for hiring of infrastructure and not PSTN related call charges (Access charges). Therefore, it is not eligible for deduction under clause 19.2 of UASL agreement.
Thus, the total expenditure towards lease line and port charges included in the access charges and claimed as deduction for ` 255.41 crore and ` 87.26 crore respectively by TTSL and TTML resulted in short payment of LF of 22.10 crore and SUC of 6.94 crore by TTSL and LF of ` 8.73 crore and SUC of ` 2.86 crore by TTML.
7.4.3 Non consideration of revenue from sharing/leasing of infrastructure/bandwidth links for payment of SUC by TTSL
Format of statement of revenue and licence fee (AGR statement) prescribed as Appendix II to Annexure II as referred in Clause 20.4 of the UASL agreement is an integral part of the licence agreement. In the statement, item 1 A has been prescribed to reflect the “revenue from wire line subscribers”. Further, Clause 18.3.1 of UASL agreement provides that “While calculating AGR for limited purpose of levying spectrum charges based on revenue share, revenue from wire line subscribers shall not be taken into account”.
In respect of TTSL, the revenue from sharing/leasing of infrastructure/bandwidth links/R&G cases etc., which were considered in the AGR statements for computation of LF during the year 2006-07, 2007-08, 2008-09 and 2009-10 amounting to ` 1030.61 crore (Annexure - 7.19) was not considered for computation of SUC, which was in contravention of the provisions of the licence agreement. Management confirmed the facts and figures and stated that revenue from wireless services alone have been offered for CDMA SUC and the rest being income from wire line services, the same was not offered for SUC.
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Audit view on the non-inclusion of revenue from sharing/leasing of infrastructure/bandwidth links/R&G cases, etc. for payment of SUC has been explained under Para 3.4.3 of this report.
Thus, the revenue from sharing/leasing of infrastructure/bandwidth links/R&G cases, etc., which were considered in the AGR statements for computation of LF but not considered for computation of SUC amounting to ` 1030.61 crore resulted in short payment of SUC amounting to ` 28.05 crore by TTSL.
7.4.4 Non-consideration of Rental Income
Audit observed that an amount of ` 17.62 crore was credited to the expenditure head Rent. As the credits under expenditure head were in the nature of income, non-consideration of the same for computation of GR resulted in understatement of GR by ` 17.62 crore (Annexure - 7.20).
Management stated that TTSL was paying rent for office spaces. In certain places, space was taken by vendors who had to pay rent to the landlord. In such cases, TTSL was initially making the payment of rent and subsequently recovering the rent at actual from the vendors, thereby crediting the rent account. Hence, this did not constitute revenue but only reimbursement of expenditure.
The reply is not tenable because Management has not given any cogent reason as to why it should pay rent on behalf of the vendors and then subsequently get it reimbursed from them. Audit is of the view that any payment towards rent to TTSL by the vendors amounted to rental income which should be considered as part of shareable revenue in terms of the Licence Agreement.
Thus, non-consideration of rental income amounting to ` 17.62 crore for computation of GR resulted in short payment of LF and SUC ` 1.61 crore and ` 0.49 crore respectively
7.5 Interest on short/non-payment of LF and SUC
On issues raised above (from para 7.2 to 7.4) short/non-payment of LF and SUC worked out to be ` 1019.16 crore and ` 338.52 crore respectively. The interest on this short/ non-payment of LF and SUC by TTSL and TTML is ` 1857.71 crore (Annexure - 7.21). The calculation of interest was based on the rate prescribed in the licence agreement i.e. two per cent above the prime lending rate of State Bank of India existing as on the beginning of the financial year and the period considered for the calculation was from the end of the concerned financial year up to March 2015.
7.6 DoT’s response to the audit observations
Audit observations on the revenue shared by TTSL and TTML were communicated to DoT
in November 2015. Reply of DoT is awaited (January 2016).
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CHAPTER – VIIIRevenue shared by Aircel Group (Dishnet Wireless Limited,
Aircel Limited and Aircel Cellular Limited)
8.1 Brief Profile of Aircel Group
M/s Aircel Cellular Ltd (ACL) the erstwhile M/s RPG Cellular Ltd commenced its
telecommunication services in Chennai in 1994. Subsequently, M/s Aircel Ltd (AL)
promoted by Sterling group obtained CMTS Licence in Tamil Nadu service area during 1998
(erstwhile M/s Srinivasa Cellular Ltd. Coimbatore). AL has two wholly owned subsidiaries
namely ACL and M/s Dishnet Wireless Ltd (DWL), which also provide telecommunication
services in India. In 2006, Aircel was acquired by Maxis Communications Berhad, Malaysia
(Maxis). Aircel is a joint venture with Sindya Securities and Investment Pvt Ltd and Maxis
hold majority of the stake (74 per cent) in the Company. By the year 2010, the Company
was having a pan India presence with licences in all 23 LSAs. Brief profile of the company
is as follows:
8.1.1 Licences granted to Aircel Group
ACL obtained CMTS licence in 1994 for Chennai service area. AL obtained CMTS licence in
Tamil Nadu service area during 1998. Subsequently, it also got UAS licences in seven service
areas during 20061. DWL got UAS licences in 14 service areas during 20042 and 20063.
8.1.2 Spectrum allotted to Aircel group of companies
AL, ACL and DWL are GSM operators. Initial start-up spectrum for subscriber access
(Main Radio Spectrum) to a GSM operator was 2×4.4 MHz. LSA wise spectrum allotted
to Aircel group of companies as on 31 March 2010 is detailed below:
Table No. 8.1
Sl. No. Spectrum Licenced Service Area
1 2 × 9.8 MHz Tamil Nadu
2 2 × 8.6 MHz Chennai
3 2 × 6.2 MHz Assam
4 2 × 4.4 MHz Bihar, Himachal Pradesh, Jammu and Kashmir, North East, Orissa, West Bengal, Haryana, Kerala, MP, Punjab, UP(W), UP(E), Kolkata, AP, Delhi, Gujarat, Karnataka, Maharashtra, Mumbai and Rajasthan (20 LSAs)
1 Mumbai,Delhi,AndhraPradesh,Karnataka,Maharashtra,GujaratandRajasthan.2 HimachalPradesh,Orissa,JammuandKashmir,Bihar,WestBengal,AssamandNorthEast.3 Kolkata,UttarPradesh(West),Haryana,Kerala,MadhyaPradesh,UttarPradesh(East)andPunjab.
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8.1.3 Subscriber base of AL/ACL/DWL
The cellular subscribers of Aircel Group (AL, ACL and DWL) grew from 0.55 crore as
on 31 March 2007 to 3.69 crore as on 31 March 2010 registering a growth of 569 per
cent. Its market share grew from three per cent as on 31 March 2007 to six per cent as on
31 March 2010.
8.1.4 Gross Revenue (GR), Adjusted Gross Revenue (AGR) and Revenue share paid
by the Aircel Group
As brought out in Para 1.5, Telecom Service Providers are required to pay LF and SUC
at a percentage of AGR on quarterly basis on self-assessment basis. GR, deductions, AGR
reported and revenue share (LF and SUC) paid by Aircel Group during the four years
2006-07 to 2009-10 are as follows:
Table 8.2
(` in crore)
Year GR Deductions AGRPercentage of AGR to GR
Revenue share(LF+SUC)
2006-07 1389.40 205.45 1183.95 85.21 144.33
2007-08 2332.21 364.82 1967.39 84.36 226.22
2008-09 3116.51 579.67 2536.84 81.40 315.47
2009-10 4703.64 1222.58 3481.06 74.01 409.60
Total 11541.76 2372.52 9169.24 79.44 1095.62
8.2 Under reporting of revenue by Aircel Group
As mentioned in para 1.4 (a), the GR shall be inclusive of all types of revenue stated therein
without any set-off for related item of expense, etc. Further, Service Revenue (amount
billable) shall be shown gross and details of discount/rebate indicated separately.
Audit examination of records/Books of accounts (Vouchers, General Ledger, Trial Balance,
Profit and Loss Accounts, and Balance Sheet, etc.) of Aircel Group revealed that these
companies had not adhered to the provisions of the licence agreement as brought out in the
succeeding paras:
8.2.1 Under reporting of Prepaid/Post-paid revenue due to netting off of revenue
relating to various offers given to subscribers
From the examination of data/records pertaining to prepaid services furnished by Aircel
Group for the period from 2006-07 to 2009-10, it was observed that the Company offered
various schemes/discounts viz. waiver, discount, Promo talk time, Free Air Time (FAT),
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Promotional offers, Full talk time, etc. to subscribers without any charges. It was noticed
that to accommodate such offers, the value of the same was deducted from service revenue
upfront. As and when the same was used by subscriber, the revenue was credited by
the said amount. Resultantly, the revenue on account of these offers to subscribers was
not recognised in the GR/AGR. Since, offers made to customers were part of overall
commercial strategy to enhance business, such offers/discounts amount to expenses. In
terms of licence agreement, service revenue shall be shown without any set-off for related
item of expense, so they are not allowed to be deduced from GR. This was also in violation
of the licence agreement which clearly states that service revenue (amount billable) shall be
shown gross and details of discount/rebate indicated separately.
The item wise details are furnished below-
A. Waiver, Discount and Promos to customers
Review of data/records furnished by Aircel Group for the period from 2006-07 to 2009-10
revealed that the following items of expenses were netted off from the revenue:-
i) Waiver offered to customers (` 99.09 crore)
ii) Discount offered to customers (` 46.77 crore)
iii) Promo Talk Time Transfer (` 0.96 crore)
In addition to the above, ` 24.71 crore booked as Promo talk time/usage under expenses
was netted off from revenue while arriving at GR. However, ` 30.47 crore on account of
“Promo talk time given as discount/Goodwill waiver and royalty discount” was added back
to revenue while arriving at GR.
Resultantly, total amount netted off from revenue on account of waiver, discount and
promo was ` 141.06 crore (Annexure - 8.01). Consequently, GR/AGR was understated by
` 141.06 crore and LF and SUC amounting to ` 13.13 crore and ` 5.95 crore respectively
was not paid by the Company (Annexure - 8.02).
B. Full talk time scheme offered to subscribers
The revenue from the prepaid services was netted off by ` 153.33 crore on account of Full
talk time offer to prepaid subscribers. Resultantly, LF and SUC amounting to ` 9.76 crore
and ` 4.32 crore respectively (Annexure - 8.03) was not paid on the said revenue by the
Company.
C. Free talk time offered to subscribers
The revenue from the prepaid services was netted off by ` 33.36 crore on account of
various offers (Free Air Time Bonus/Free talk value (FTV) accounted, FTV offered to
subscribers on Recharge Coupons (RC), Additional Talk time, Extra Talk time, etc.). As a
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result, the revenue was reduced by ` 33.36 crore. Consequently, LF and SUC amounting
to ` 2.95 crore and ` 1.39 crore respectively (Annexure - 8.04) were not paid on the said
revenue by the Company.
D. Discounts
During 2009-10, revenue from the prepaid services pertaining to AL was netted off by
` 2.82 crore by crediting expenditure (Discount ER). Resultantly, LF and SUC amounting
to ` 0.28 crore and ` 0.06 crore respectively (Annexure - 8.05) were not paid on the said
revenue by the company.
On being pointed out by Audit, the Management stated that-
• Waiversofferedtocustomerswhichwereinthenatureofgoodwillgesturewere
already added back for computing AGR in the respective years. Balance waivers
which were in the nature of billing errors, were corrected by giving waivers.
• Discount/PromoTalktimetransfersareinthenatureofadditionaltalktimegiven
to subscribers based on their usage pattern to enhance subscriber experience or to
retain him on Aircel network etc. For these, liabilities were booked and revenue was
accounted as per usage on decrement over a period of time and revenue was included
for AGR purpose.
• FullTalktimeschemeofferedtosubscriberswereinthenatureoftalktimegivento
subscribers for more value, to retain him on Aircel network etc. or to pull/instigate
new subscribers to join Aircel Network.
• FAT-Bonus/Free talk value/FTV offered to subscribers on RC's/additional talk
time/extra talk time offered to subscribers are in the nature of talk time given to
subscribers, to retain him on Aircel network etc. or to pull/instigate new subscribers
to join Aircel Network.
• ThecompanyaccountsfortherevenueincompliancewiththeAccountingStandard
(AS) 9 issued by the Institute of Chartered Accountants of India.
• TDSAT also upheld the above definition and passed an order to this effect on
23 April 2015 stating that “There is no conflict between the definition of “revenue’
as provided in AS-9 and clause 19.1 and 19.2 of the licence agreement defining gross
revenue and adjusted gross revenue. As is evident from section 211 (3A), (3B) and
(3C) that in case of a telecom company, the licensee is legally mandated to maintain
its profit and loss account and the balance sheet in compliance with the Accounting
Standards. Accounting Standards are given due importance by the Supreme Court
as those are the codified recommendations by the Institute of Chartered Accountants
of India which is an expert body in a specialised field”.
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Reply of the Management is not acceptable as -
• Outoftotaldebitentrynoticedintherevenueheadsonaccountof"Waiveroffered
to customers" i.e.` 99.09 crore, ` 98.62 crore (i.e. 99.53%) relates to prepaid
revenue, where no bills are raised to the customers. Further, even in case of waivers
to Prepaid subscribers, out of total debit entry of 98.62 crore on account of waivers,
` 98.43 crore was debited to GL code “Prepaid-RC Processing Income”, which if,
had it been due to wrong deduction (from the Subscriber accounts) on account of
VAS, Talk Time, rental etc, debit on account of waiver should have been on those
GL codes only. In case of billing to the post-paid customers if it is subsequently
confirmed that there was a mistake in the bill, the same is reversed/adjusted in
the respective revenue codes. It was noticed that there are several reversal and
adjustment entries in the general ledger to this effect. Analysis of the data extracted
from general ledgers pertaining to these waivers clearly indicated that these were
on account of prepaid processing income, VAS, Talk Time, rental etc. It was not
mentioned that these entries were due to wrong billing. Out of waivers of ` 99.09
crore for prepaid customers, Aircel group has itself added back ` 7.7 crore in the
name of goodwill waiver to the customer in revenue while preparing GR.
• Discount/PromoTalk time transfers andwaivers are part of overall commercial
strategy to enhance business; therefore, such offers/discounts were in the nature of
expenses and hence, in terms of licence agreements, were not allowed to be deducted
from GR.
• In case of Full Talk Time/Free Talk Time etc.Management has itself accepted
that these offers were in the nature of discounts offered to customer retention and
maintaining relationship and formed part of service revenue. Therefore, such offers/
discounts were in nature of expenses and hence, in terms of licence agreements,
were not allowed to be deducted from GR.
• IncaseofFAT-Bonus/Freetalkvalue/FTVofferedtosubscribersonRC's/additional
talk time/extra talk time offered to subscribers also, Management accepted that it is
in the nature of talk time given to subscribers to retain them on Aircel network etc.
or to pull/instigate new subscribers to join Aircel Network. Therefore, such offers/
discounts were in nature of expenses and hence, in terms of licence agreements,
were not allowed to be deducted from GR.
• AuditisnotquestioningtheaccountinginaccordancewithAS-9butcontendsthat
since these expenses were not to be set-off against as per the licence agreement,
these should be added back to GR for computation of LF and SUC.
• Whilethematterissub-judiceatHon’bleSupremeCourt,Auditviewisthatasper
licence agreement, service revenue should be shown in gross without any set-off of
related promotional expenses like discounts/waivers/offers given to the subscribers.
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8.2.2 Short accounting of revenue due to upfront debit in the revenue heads
As per the procedure followed by the Company for accounting of revenue, while the
revenue received in advance was accounted under liability, the FAT/FOC on this amount
was debited to the current revenue. Due to this, the current revenue was short accounted to
the extent of FAT/FOC resulting in deferment of LF and SUC on this amount.
On being pointed out by Audit, the Management reiterated the reply as given against our
observations at para 8.2.1 above.
Reply of the Management is not tenable since the upfront debit of FAT/FOC of revenue
received in advance to the current revenue results in short payment of LF and SUC on the
current revenue to the extent of amount debited.
8.2.3 Under reporting of prepaid revenue due to set-off of revenue pertaining to
commission/discount allowed to the distributors
From the examination of data/records furnished by Aircel group for the period from
2006-07 to 2009-10, it was observed that revenue booked in the accounts was net of
commission/discount given to the distributors at the time of sale of electronic/paper recharge
coupon. Further, the aforesaid commission/discount given to the distributors was also not
added back while arriving at GR/AGR. This was in violation of the licence agreement which
clearly stated that GR (amount billable) shall be shown gross and details of discount/rebate
indicated separately and the GR shall be without any set-off for related item of expense.
In this connection, when Audit raised the query seeking the details of amount/percentage
of commission/discount paid to the distributors at the time of sale of electronic/paper
recharge coupon, relevant information was not furnished by the Management. In such
circumstances, on the basis of average of the prevailing percentage (i.e. 4 per cent4 of the
pre-paid revenue), Audit calculated ` 272.60 crore as commission paid to the distributors
during 2006-07 to 2009-10.
On being pointed out by Audit, it was stated by the Management that:-
• It is submitted that though thepre-paid vouchers carry aMaximumRetailPrice
(MRP), these vouchers were sold to the distributors on a lower price as per agreement
between the parties. It is contended that the sale of pre-paid vouchers was a Principal
to Principal transaction.
• Further,TDSATin its judgmentdated23April2015hasheld“Inourviewthe
definition of ‘gross revenue’ cannot be construed as to bar the licensee from fixing
a wholesale price for the service which is lower than its MRP. The test is how the
actual transaction takes place. If the sale and invoicing is on MRP and any discount
4 Fourper cent(averageofthree per centtofive per cent,theprevailingpercentageofcommissionduring2006-07to 2009-10)
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is given separately, then in terms of clause 19.1 such discount is not deductible even
if the revenue booked in the profit and loss account is after netting off the discount.
On the other hand, if the sale is on a stated/agreed price, invoiced at that agreed
price and booked under the revenue in the profit and loss account accordingly,
without netting off any discount, the actual selling price would be the revenue and
the difference between the MRP and this selling price cannot be added to ‘gross
revenue”.
Audit view on the reply of the Management is as explained in para 3.2.1 (A). While the
matter is sub-judice at Hon’ble Supreme Court, Audit view is that commission/margin
paid to the distributors/franchises/dealers is in the nature of marketing expenses, therefore,
set-off of such expenses with revenue was against the licence condition.
Thus, netting off of commission amounting to ` 272.60 crore given to distributors/agents/
dealers has resulted in understatement of GR/AGR and short payment of LF and SUC by
` 22.31 crore and ` 9.64 crore respectively (Annexure - 8.06).
8.2.4 Under reporting of revenue due to set-off on account of “Impact of Market
stock”
From the examination of data/records furnished by Aircel group for the period from
2006-07 to 2009-10, it was observed that during February 2009 and March 2010, the
revenue from prepaid services was netted off by ` 3.40 crore on account of “Impact of
Market stock/Impact of service tax rate change on market stock /etc.”
On being pointed out by Audit, it was stated by Management that this seems to be the
difference on account of market stock impact of increase in rate of service tax. The entries
for change in service tax rate are recorded at a later date, therefore while passing entry for
transfer of liability from market stock to customers, the liability is transferred based on the
old rate of service tax and accordingly revenue on account of such liability was recorded
in excess. Hence amount equivalent to the differential of service tax rate change have been
debited to revenue codes and credited to liability to rectify the excess revenue recorded.
Therefore, our submission is that the above should not be added back to revenue once again
in AGR for calculation of LF.
Reply of the Management is not tenable as rate of service tax was not revised during March
2010. Further, regarding cases pertaining to February 2009, it is stated that in all these
cases corresponding credit entries were made to processing fee/activation charge/other
provision, which is not related to service tax liability.
Thus netting off of revenue on account of “Impact of Market stock” has resulted in
understatement of GR/AGR by ` 3.40 crore in the year 2009-10 and short payment of LF
and SUC by ` 0.34 crore and ` 0.14 crore respectively (Annexure - 8.07).
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8.2.5 Non consideration of revenue from infrastructure sharing from other telecom
operators for GR/AGR
As mentioned in para 1.4 (a), the GR shall be inclusive of revenue from permissible sharing
of infrastructure and any other miscellaneous revenue without any set-off for related item
of expense, etc.
Telecom infrastructure (towers, network equipments, etc.) owned by Aircel Group were
shared with other telecom companies. They have entered into agreements with other telecom
companies for infrastructure (site) sharing. In terms of the agreements entered with the
other operators, charges for sharing cell site was recovered from other operators which was
based on a percentage of CAPEX cost of the sites and OPEX cost incurred by Aircel group.
From the examination of data/records furnished by Aircel group pertaining to Infrastructure
sharing charges for the period from 2006-07 to 2009-10, it was observed that Infrastructure/
site sharing charges recoverable/recovered on account of rent, fuel (diesel), electricity,
network expenses, repairs and maintenance and security amounting to ` 67.12 crore were
netted off from their respective expense heads.
On being pointed out by Audit, it was replied that -
• Therearetwotypeofpaymentsreceivedforsharingofinfrastructurei.e.,charges
levied for the usage of the facility and reimbursement of expenditure incurred such
as that on repairs and maintenance, electricity, diesel etc. The charge for the usage
of the facility was booked as revenue whereas the reimbursement of costs was
booked as a reduction in related expenditure. It is pertinent to note here that the
Company accounts for reimbursement of expenses in compliance with the AS 29.
• TDSAT vide its judgment on 23April 2015 has held that “As is evident from
section 211 (3A), (3B) and (3C) a telecom company, the licensee is legally mandated
to maintain its profit and loss account and the balance sheet in compliance with
the Accounting Standards. Accounting Standards are given due importance by
the Supreme Court as those are the codified recommendations by the Institute of
Chartered Accountants of India which is an expert body in a specialised field”. It
is important to note that, TDSAT has also in its judgment dated 23 April 2015 has
stated that “while any payment made towards the usage of the facility has to be taken
as revenue in the hands of the recipient, a payment in the nature of reimbursement
of an expense and which is clearly indicated separately in the invoice as such, may
not be taken as revenue provided that it is not booked in the profit and loss account
as revenue.”
Audit view on the reply of the Management is as explained in para 3.2.4. While the matter
is sub-judice at Hon’ble Supreme Court, Audit view is that revenue towards diesel expenses,
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security expenses, repair and maintenance expenses and electricity charges did not constitute
reimbursement since they had to be incurred irrespective of whether the towers were shared
or not. In fact, by sharing the expenditure the Company benefited through additional
income. Thus netting of infrastructure sharing revenue received/receivable from other
telecom operators from the cost relating to 2006-07 to 2009-10 resulted in understatement
of GR/AGR by ` 67.12 crore and short payment of LF and SUC by ` 5.45 crore and
` 2.26 crore respectively (Annexure - 8.08).
8.2.6 Short/Non-consideration of revenue from forex gain in GR/AGR
In the Profit and Loss account of Aircel Group, total net balances under the account heads
operated for booking transactions related to foreign exchange gain/loss were included in the
schedule of “Other Income” as Foreign Exchange Gain (net).
From the examination of data/records provided by Aircel group for the period from
2006-07 to 2009-10, it was observed that the total realized forex gain for the Aircel was
` 16.57 crore, out of which, forex gain amounting to ` 6.54 crore only was considered
during 2006-07 to 2008-09 in the AGRs under UASL/CMTS licences of the Aircel Ltd
and Aircel Cellular Ltd. Total realised forex gain amounting to ` 15.13 crore was not
considered for AGR.
The above realised gain did not represent the actual gain of that particular item since the
Company recasts the value of all the items included under the foreign exchange gains/losses
head every year, the matured items are accounted under realised gains and the un-matured
items remain under unrealised gain. Thus, the realised gain of a particular item in that year
would not be the actual gain due to accounting of the gains /losses of that item during the
intermediate period under unrealised. Audit could not arrive at the actual value of items
accounted under realised gain every year for want of original value of each item. Further,
Audit has considered the quarterly net gain, head of account-wise and LSA-wise, as it was
not possible for Audit to segregate/collect the figures of gains only from the data made
available. The operator should calculate the gain of each item with reference to its initial
value of accounting and include the total forex gain in GR/AGR.
On being pointed out by Audit, the Management stated that:-
• The gains are of two types. First, is the reduction of liability towards payments for
capital goods such as equipment and roaming charges for out-roamers. The other is
increase in receipts such as roaming charges for in- roamers. In the first case, the
reduction in liability on account of payment for capital goods is only a reduction of
cost. Since the cost of equipment has no impact on the LF as the same is calculated
on gross revenue, any gain arising on account of a decrease in such cost should also
not be taken into account for LF and cannot be treated as revenue for the purpose.
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As regards payment of roaming charges, since the same is allowed on actual basis and not accrual basis, the actual amount paid or set-off in case of netting, may be allowed to be deducted from gross revenue in terms of clause 19.2. On the issue of roaming revenue on account of in-roamers, since the same is to be accounted for in the revenue on accrual basis, the LF should be on the revenue that is booked in the profit and loss account as per AS-9. Subsequent changes in the book value of the receivable are only notional till the same is actually received. Further, the actual receipt may be less or more depending on the currency rate at the time of actual payment. Since no discount is given if actual receipt is less, no LF should be charged if the same is more.
• It is further submitted that the TDSAT Judgment pronounced on 23 April 2015 states that “……..any gain or loss due to foreign exchange fluctuation should have no bearing on the licence fee.”
• The Hon’ble Madras High Court by an order dated 22 June 2012 has directed as follows:
“No coercive steps shall be taken, by the respondents, to recover the LF payable by the petitioner, in respect of the non-telecom activities of the petitioner until further orders.”
Reply of the Management is not tenable as:-
• IntermsofthelicenceagreementGRshallbeinclusiveofanyothermiscellaneousrevenue.
• Whilethematterissub-judiceatHon’bleMadrasHighCourtandHon’bleSupremeCourt, Audit view is that any gain incidental to PSPs should be considered for GR.
Thus non-inclusion of realised foreign exchange gains pertaining to period from 2006-07 to 2009-10 resulted in understatement of GR/AGR by ` 15.13 crore and short payment of
LF and SUC amounting to ` 1.23 crore and ` 0.31 crore respectively (Annexure - 8.09).
8.2.7 Non/Short consideration of Interest Income for GR/AGR
From the examination of data/records provided by Aircel group for the period from 2006-07
to 2009-10, it was observed that out of total Income on account of interest on bank deposits
and fixed deposits of ` 200.20 crore, ` 98.89 crore was not considered as revenue during
2006-07 to 2009-10 in the GR/AGR (Annexure - 8.10), which was in violation of licence
agreement as definition of GR in licence agreements expressly provides for inclusion of
income from interest in GR/AGR.
On being pointed out by Audit, it was stated by the Management that-
• Theinterestearnedoninvestmentofsavingsmadebyalicenseeaftermeetingliability
on account of share of the government in the gross revenue is ought to be excluded
from AGR. Investment of saving from the income which has severed all its links
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with the licenced telecom activity was again an application of income, the revenue
where from did not come within the purview of AGR. Similarly, revenue derived
from any temporary surplus funds through use for any business other than telecom
service or for maximizing the value of money through fixed deposits, securities or
mutual funds cannot be termed as an income from telecom activity and hence cannot
be included in AGR for the purposes of computation of LF. Such interest, therefore,
cannot be treated as revenue generated from service or licensee’s business under the
licence or not even distantly related to the business being carried out to provide the
service under the licence.
• TheHon’bleMadrasHighCourtbyanorderdated22June2012hasdirectedas
follows:
“No coercive steps shall be taken, by the respondents, to recover the LF payable by
the petitioner, in respect of the non-telecom activities of the petitioner, until further
orders.”
Reply of the Management is not acceptable as -
• Whilethematterissub-judiceatHon’bleMadrasHighCourt,Auditviewisthat
definition of GR in licence agreements expressly provides for inclusion of interest
income for GR/AGR for computation of revenue share.
Thus non-inclusion of interest income pertaining to period from 2006-07 to 2009-10 has
resulted in understatement of GR/AGR by ` 98.89 crore and short payment of LF and SUC
amounting to ` 6.74 crore and ` 2.66 crore respectively (Annexure - 8.10).
8.2.8 Non consideration of income from investment for GR/AGR for payment of
revenue share
From the examination of data/records provided by Aircel group for the period from
2006-07 to 2009-10 it was observed that income from investments amounting to ` 9.01
crore was not considered as revenue during 2006-07 to 2009-10 for GR/AGR.
To an Audit query, the Management stated that -
• The nature of the income, being dividend, was not attributable to any licenced
activity. Hence, any dividend earned on account of investments of any nature
whatsoever, was not part of income accrued from the licenced activity.
• TheHon’bleMadrasHighCourtbyanorderdated22June2012hasdirectedas
follows:
“No coercive steps shall be taken, by the respondents, to recover the LF payable by
the petitioner, in respect of the non-telecom activities of the petitioner, until further
orders.”
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Reply of the Management is not tenable as while the matter was sub-judice at Hon’ble
Madras High Court, Audit view is that definition of GR in licence agreements expressly
provides for inclusion of income from dividend in GR/AGR for computation of revenue
share.
Thus non-inclusion of Income on investment pertaining to period from 2008-09 to 2009-10
has resulted in understatement of GR/AGR by ` 9.01 crore and short payment of LF and
SUC amounting to ` 0.90 crore and ` 0.37 crore respectively (Annexure - 8.11).
8.2.9 Non consideration of miscellaneous income for GR/AGR
From the examination of data/records provided by Aircel group for the period from
2006-07 to 2009-10, it was observed that certain items of miscellaneous income like income
from composite contract, income from software services, income from project Management,
notice pay (barring a few cases in some LSAs), income on account of sale of scraps,
reimbursement of cost etc. were not considered while computing AGR for the purpose of
revenue share:
(i) Corporate Income amounting to ` 93.63 crore was not considered for AGR in DWL
during 2006-07 and 2008-09. The short payment of LF and SUC on this amount
worked out to ` 5.70 crore and ` 2.16 crore respectively (Annexure - 8.12).
(ii) Recovery of Notice pay from the employees was not treated as revenue for the
purpose of GR/AGR (except for a few cases in DWL in 2009-10). During 2009-10
in some LSAs of DWL (viz. UP (West), Bihar and Jharkhand, Assam, North East
and NLD) notice pay was included in AGR and LF paid on it. The total amount of
recovery of notice pay was ` 5.56 crore, out of which ` 0.58 crore was considered
for AGR during 2009-10 and the total amount on which LF/SUC remains to be paid
was ` 4.98 crore. LF and SUC short paid works out to ` 0.40 crore and ` 0.13 crore
respectively (Annexure - 8.13).
(iii) Miscellaneous income/other income on account of sale of scraps, reimbursement
of cost etc. (excluding insurance claims) amounting to ` 1.59 crore had not been
considered as revenue while computing GR/AGR for the purpose of LF/SUC.
LF and SUC short paid works out to ` 0.11 crore and ` 0.03 crore respectively
(Annexure - 8.14).
To an Audit query, the Management stated that-
• Corporate incomesdonotarise fromthe licencedactivityandfordoing this,no
licence was required. Further, separate divisional books of account were maintained
for the non-telecom businesses which had no nexus with the licenced activities of any
telecom circles.
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“Notice Pay Recovery” consists of income received from employees on termination of
services which do not accrue either from subscribers or from other telecom service providers
for provisioning of telecom service, and therefore, should not be part of AGR.
“Miscellaneous income/other income” includes income from sale of scraps, insurance
claim, reimbursement of cost etc. which do not accrue either from subscribers or from
other telecom service providers for provision of telecom service, and therefore, should not
be part of AGR.
Furthermore, these incomes do not require even a telecom licence.
• TheHon’bleMadrasHighCourtbyanorderdated22June2012hasdirectedas
follows:
“No coercive steps shall be taken, by the respondents, to recover the LF payable by
the petitioner, in respect of the non-telecom activities of the petitioner, until further
orders.”
Reply of the Management is not tenable as -
• Definition of GR in licence agreement expressly provides for inclusion of
miscellaneous income in GR/AGR for computation of revenue share. As mentioned
earlier, the insurance claims have been excluded from AGR.
• Whilethematterissub-judice at Hon’ble Madras High Court, Audit view is that
miscellaneous income should be included in GR/AGR for computation of revenue
share, as per licence conditions.
8.2.10 Non consideration of income from profit on sale of fixed assets for payment of
revenue share
From the examination of data/records provided by Aircel group for the period from
2006-07 to 2009-10, it was observed that income from profit on sale of fixed assets was not
included in GR/AGR for computation of revenue share, as detailed below:
Table 8.3
Name of the company YearAmount not considered for GR/
AGR (` in crore)Annexure reference
Dishnet Wireless Ltd 2007-08 10.04 8.15
Aircel Ltd 2009-10 23.88 8.16
Aircel Cellular Ltd2007-08 0.01
8.172009-10 7.24
Total 41.17
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To an Audit query, the Management stated that -
• Saleoffixedassetsonwhichcapitalgainsweremadecannotbesaidtobepartof
licenced activity. The stage at which the funds were utilized for purchase of fixed
assets was after they had severed their connection with AGR. Hence, capital gains
made on account of sale of fixed assets etc. should not form part of AGR. The
capital gain made out of sale of asset was well within the purview of income tax and
are charged separately from the operator during its assessment by the tax authorities
and it was a common principle of law that the same cannot be charged twice by the
State. If the licensor also extends its right to claim a part of this capital gain as a
percentage of AGR from the licensee, then the State is indulging in double taxation,
which was legally impermissible.
• TheHon’bleMadrasHighCourtbyanorderdated22June2012hasdirectedas
follows:
“No coercive steps shall be taken, by the respondents, to recover the LF payable by
the petitioner, in respect of the non-telecom activities of the petitioner, until further
orders.”
• Further,TDSATinitsrecentjudgmentdated23April2015hasheldthat“Inlight
of the discussions made above and especially in view of the recognition of revenue
as per AS-9 “gain on sale of capital assets and receipt from sale of scrap” cannot be
included in “gross revenue” for computation of LF. As seen above, clause 19.1 of
the licence agreement mentions specific inflows as forming part of “gross revenue”.
The item under consideration evidently does not come under any of the inflows
enumerated in clause 19.1. Capital receipts are different from revenue receipts;
hence, receipts of capital nature cannot be added to the “gross revenue” (para 19.2).
Reply of the Management is not tenable as:
• Definition of GR in licence agreements expressly provides for inclusion of
miscellaneous income in GR/AGR for computation of revenue share.
• Whilethematterissub-judice at Hon’ble Madras High Court and Hon’ble Supreme
Court, Audit view is that any gain incidental to PSPs should be considered for GR.
Thus, income of ` 41.17 crore on account of profit on sale of fixed asset accounted in
the books of accounts of the company should be included in GR/AGR for computation of
revenue share payable by the company to DoT. Resultantly, LF and SUC amounting to
` 3.72 crore and ` 1.34 crore respectively (Annexure - 8.18) were not paid on the said
revenue by the Company.
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8.2.11 Non Inclusion of profit on revaluation of assets in GR
As per the Scheme of Arrangements (SoA) approved by the Hon’ble Madras High Court
in June 2010, the passive infrastructure assets of the three companies in the Aircel
group-Aircel Ltd (AL), Aircel Cellular Ltd (ACL) and Dishnet Wireless Ltd ( DWL)
were to be transferred to Chennai Network Infrastructure Limited (CNIL) for a lump
sum consideration. The appointed date of the Scheme was 1 January 2010. Accordingly,
the assets of all three companies were revalued as on 1 January 2010 and the profit on
revaluation of ` 3612.04 crore was accounted in 2009-10 under General Reserve which has
been treated as a free reserve for all purposes as per the SoA. The above profit included
profit from revaluation of the Company’s passive infrastructure assets and other assets. As
per the directions of the Hon’ble High Court, the SoA was to be effective from the date of
filing of the order with the Registrar of Companies. Accordingly the transfer of assets as
per the SoA became effective in July 2010.
Audit observed that the profit of ` 3390 crore earned on revaluation of the passive
infrastructure assets, transferred to CNIL was not considered for revenue share in the year
2009-10. The Management informed that recording of the transaction of sale/transfer of
asset prior to July 2010 i.e. before filing the order with the Registrar of Companies would
have amounted to contempt of court.
As the effective date of SoA was beyond the period covered in the present Audit, it could not
be ascertained whether the profit earned from the passive infrastructure assets transferred to
CNIL was offered for payment of LF and SUC in subsequent years.
8.3 Short/non-payment of revenue share due to irregular/excess deductions claimed
in the AGR statements
8.3.1 Irregular deduction of bad debts written off from GR to arrive at AGR
In terms of clause 19.2 of the licence agreement, only following three items are allowed to
be excluded from the GR for arriving at AGR-
• PSTNrelatedcallcharges(AccessCharges)actuallypaidtoothereligible/
entitled telecommunication service providers within India:
• Roaming revenues actually passed on to other eligible/entitled
telecommunication service providers and;
• Servicetaxonprovisionofserviceandsalestaxactuallypaidtothegovernment
if gross revenue had included as component of sales tax and service tax.
Review of data/records furnished by Aircel Group for the period from 2006-07 to 2009-10
revealed that during 2009-10, while arriving at GR for Aircel Cellular Ltd, Bad debt written
off amounting to 24.70 crore in Tamil Nadu LSA was deducted from the revenue resulting
in reduction of GR/AGR for 2009-10 by ` 24.70 crore.
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To an Audit query, the Management stated that-
• Thebaddebtswritten-offintheyear2009-10werereducedfromtheAGRpursuant
to the TDSAT judgment dated 30 August 2007 which stated that “Bad debts are actual
monies lost by the service provider. Therefore, such losses have to be excluded from
AGR. Allowing amounts on account of such losses to be included in AGR would
mean that while the party incurs loss it has to pay LF on the loss also”. The above
judgment still holds good since the new judgment of TDSAT dated 23 April 2015
has yet not attained the finality as the same is challenged by DoT before Supreme
Court.
• In our view, bad debts represent failure of the service provider to realize the
amounts. To impose LF on these items would mean subjecting the operators to
double jeopardy – by failing to realize the amounts they lose the revenue.
The contention of the Management is not tenable, as:
• TDSATjudgmentdated30August2007referredinthereplywassetasidebythe
Hon'ble Supreme Court vide judgement dated 11 October 2011.
• ThelicenceagreementdoesnotprovidedeductionofbaddebtfromGRtoarriveat
AGR.
• Whilethematterissub-judiceatHon’bleSupremeCourt,Auditviewisthatbad
debt should not be deducted from GR, as per licence conditions.
This has resulted in understatement of AGR by ` 24.70 crore and short payment of LF and
SUC by ` 2.47 crore and ` 1.05 crore respectively.
8.3.2. Excess Deductions claimed in ISP (IT) AGR
In terms of the amendment to “Terms and conditions of licence agreement for provision
of internet services (including Internet Telephony)” issued by DoT vide its letter dated
3 March 2006, “For the purpose of arriving at the AGR, the following shall be excluded
from the GR:
• Chargesfrominternetaccess,internetcontentandinternetaccessrelatedinstallation
charges.
• Servicetaxonprovisionofserviceandsalestaxactuallypaidtothegovernmentif
gross revenue had included as component of sales tax and service tax.”
During review of Audited AGR in respect of ISP (IT) Licence of DWL for the year
from 2006-07 to 2009-10, it was noticed that the total deduction claimed by DWL was
` 96.52 crore out of which, deduction amounting to ` 7.50 crore pertains to customer
premises equipment rental, mailbox solution to corporate, server co-location charges, etc.
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which do not fall under any of the category of deductions allowed in the licence agreement
for ISP(IT), consequently the AGR was understated by the same amount.
On being pointed out by Audit it was replied that-
Table-8.4
GL Description Remarks
Income from
Inter divisional
Services
The company is charging for the lease line (E1s) used by the clients. The
invoices raised by the Company and charges recovered are in the nature of lease
line though the same are billed as Port charges on account of lease lines. These
lease line charges are against the internet access charges and is grouped under
the same. Port is a technical arrangement of the company for the provision of
connectivity of the services for which the customers are not billed by any of
the private operators. Charges billed to customers are in the nature of lease line
only though billed with the nomenclature of port charges. Even the invoices
raised in the current periods also have the same nomenclature.
Income from
CPE rental -
Inter Company
The Company is installing equipment at the customer premises to provide the
internet services, for which the Company recovers installation charges from
the group company. The Company is charging installation charges which are
described as CPE rental charges in the invoices. The invoice does not contain
installation charges separately in the invoices, since it is charged under this
head. The same practice of invoicing is followed by the company during the
current years too.
Income from
CPE Rental
Therefore, from the above, it is evident that deductions claimed are as per the licensing
agreement and eligible for deduction from the calculation of AGR.
Audit view on the Management reply is as follows:
• ManagementcontentionthatincomefromInterdivisionalservicesincludesincome
from port charges, which was of the nature of internet lease line, was considered.
During 2006-07 to 2009-10 total income from such port charges was ` 2.37 crore.
Hence the amount of excess deduction claimed during 2006-07 to 2009-10 was
revised from ` 7.50 crore to ` 5.13 crore.
• RegardingIncomefromInterdivisionalServices,therevenuesrelatingtoMailbox
solution to corporate, server co-location charges, etc. amounting to ` 0.83 crore
was not at all eligible for deduction, as it did not fall under any of the category of
deductions allowed in the licence agreement for ISP (IT).
• Further,asperinvoiceshowntoAudit,installationchargesandCPErentalcharges
were separately shown in the invoice and also they do not fall under any of the
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category of deductions allowed in the licence agreement for ISP (IT) and hence did
not qualify for deduction.
In view of above, deduction amounting to ` 5.13 crore was claimed in excess by DWL and
consequently the AGR was understated by the same amount. Resultantly, LF amounting to
` 0.31 crore (Annexure - 8.19) was not paid by the Company.
8.4 Interest on short/non-payment of LF and SUC
On issues raised above (para 8.2 to 8.3) short/non-payment of LF and SUC worked out to
be ` 75.80 crore and ` 31.81 crore respectively. The interest on this short/non-payment of
LF and SUC is ` 155.22 crore (Annexure - 8.20). The calculation of interest was based
on the rate prescribed in the Licence agreement i.e. two per cent above the Prime Lending
Rate of State Bank of India existing as on the beginning of the financial year and the period
considered for the calculation was from the end of the concerned financial year up to March
2015. The interest has been compounded monthly as prescribed in the licence agreement.
8.5 DoT’s response to the Audit observations
Audit observations on the revenue shared by Aircel Group were communicated to DoT in
October 2015. Reply of DoT is awaited (January 2016).
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CHAPTER – IXVerification of deduction claims in the Offices of the Controllers
of Communications Accounts
9.1 Introduction
Offices of the Controllers of Communications Accounts (CsCA) are the interface between
DoT and the PSPs licensed to provide service in a Licensed Service Area (LSA). Besides
the Statutory1 and Administrative2 functions, CsCA revenue functions included collection
of LF and SUC from all licensees of various telecom services which is being paid by the
PSPs on their self - assessed revenue, scrutiny and verification of documents submitted by
the licensees in support of their claims for deduction.
Verification of deductions claimed by PSPs was delegated to CsCA from 2006-07 and on
completion of the verification exercise, the CsCA convey their findings through ‘verification
reports’ to the LF Wing of DoT.
Verification of proof of payment with respect to the deduction claims and determination
of actual AGR is an important pre-requisite for the accurate computation/assessment of
revenue share due from a PSP. Timely completion of the process of verification was to be
ensured to facilitate final assessment in DoT.
Records maintained by 21 CsCA out of 25 CsCA were test checked by audit to ensure that
LF and SUC due was collected from PSPs and the verification of their claims for deduction
from AGR was supported by due documents. The test check was conducted for the period
2006-07 to 2009-10 in respect of six operators viz BAL, Vodafone, RCL/RTL, ICL, Aircel
and TTSL/TTML. Audit observations emanating from the scrutiny of records and the
process of verification are as under:
9.2 Audit Observations
9.2.1 Deductions allowed in absence of required proof
From time to time, DoT issued clarifications regarding verification procedure for deductions
claimed by Telecom Service Providers. As per the issue no.7 of the clarification issued by
DoT on 05 July 2007, proof of payment included vouchers/bank statements/receipts etc.
Subsequently, DoT in November 2011, emphasized that submission of details including
payable invoices along with proof of payment/receipt was a pre-requisite for claiming
deductions by the licensees.
Test check of records in CsCA office revealed that CsCA had allowed claims for deduction
in respect of PSTN/roaming charges paid to other operators without proof of document as
1 Statutoryfunctionincludesbudgetingofpensionexpenditure,authorizationofretirementbenefitsonCDAandIDApayscale,maintenanceofGPF,recovercontributionforNPSandremittotrusteebank,PAOandotherDDOfunctions.
2 OtheradministrativefunctionsasHeadoftheDepartmentincludinghandlingofcourtcases
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prescribed by DoT. To an audit observation in this regard while 11 CsCA3 accepted the
lapse and replied that operators are being addressed to submit the required documents, other
CsCA replied that the deductions were allowed based on the instructions of DoT prevailing
during the relevant year.
DoT, in June 2013 and November 2014, provided detailed clarification on deduction
verification based on queries raised by CsCA. Prior to those clarifications from DoT, there
was no uniformity among CsCA as well as operators with regards to nature of documents
to be submitted as proof for deduction. This resulted in different CsCA adopting different
standards regarding documents to be submitted in support of deduction claims.
9.2.2 Ineligible deductions allowed from GR
As per the conditions of UASL agreement, for the purpose of arriving at the AGR of the licensee, the following three items of charges paid by the PSP were only permitted to be excluded from the GR.:-
i) PSTN related call charges (Access Charges) actually paid to eligible/entitled Telecom Service Providers within India.
ii) Roaming revenues actually passed on to other eligible/entitled telecom service providers.
iii) Service Tax/Sales Tax paid to Government, if the same had been included in the Gross Revenue.
Scrutiny of documents submitted as proof against claims for deduction and verification reports issued by CsCA for the period 2006-07 to 2009-10 revealed that, PSPs had claimed deductions for expenses incurred under Interest on delayed payment and leased line charges. CsCAs erroneously allowed these deductions from GR resulting in understating AGR in four LSAs as detailed below:
Table 9.1
(` in lakh)
Sl No. PSP LSA Year Amount Payment type
1 Vodafone Gujarat 2006-07 to 2009-10
10.58 Fixed Charges, Interest on delayed payments
Rajasthan 2006-07 to 2009-10
13.69
Maharashtra 2007-08 958.93 Deduction allowed including ST
Andhra Pradesh 2007-08 300.64 Excess deduction on account of typographical error
2 TTSL Karnataka andOdisha
2007-08 to2008-09
2.65 Interest for delayed payment of Interconnect Usage Charges (IUC)
3 Jharkhand,Karnataka,Odisha,Punjab,Rajasthan,Kerala,Kolkata,Delhi,Bhopal,HaryanaandMumbai
Report No. 4 of 2016
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On this being pointed out, CCA Karnataka replied that there was no clear cut indication on
non-admissibility of interest towards delayed payment, while CCA Odisha and CCA Gujarat
replied that the matter was being rechecked. Response from CCA Rajasthan is awaited.
This lacuna in the verification process adopted by the CsCA and non-adherence to the
conditions in the licence agreement and instructions issued by DoT resulted in allowing
ineligible deductions from the GR of the PSPs. As the DoT does the assessment based on
the verification reports sent by the CsCA, the impact of discrepancies, if any, in allowing
deduction would result in short realization of revenue share.
9.2.3 Inadmissible deduction on account of Service Tax
In terms of provisions in UASL agreement and as per clarifications issued in July 2007 by
DoT, if the GR includes Service Tax/ Sales Tax, then actual payments made by the licensee
to the Government during the Financial Year qualifies for deduction for that year.
It was observed that as per notes to audited AGR statements of BAL, Vodafone and ICL,
GR shown in the audited AGR does not include Service Tax component. However, on a
test check of records it was noticed that BAL, Vodafone and ICL had claimed deduction
including service tax component in four LSAs which was allowed by the respective CsCA
as below:
Table 9.2
(` in crore)
Name of the PSP LSA Year Gross Invoice ST component
Bharti Airtel Ltd Odisha 2007-08 21.32 2.35
Idea Cellular Ltd Andhra Pradesh 2007-08 16.42 1.81
Idea Cellular (Spice Communications Ltd)
Karnataka 2008-09 55.48 6.08
Vodafone Karnataka2006-07 to2009-10
41.17 4.52
Vodafone Maharashtra2007-08 to 2009-10
87.40 9.59
TOTAL 24.35
On this being pointed out by Audit, while CCA Bhubaneswar accepted the audit comments
and the Pr. CCA, Andhra Pradesh replied that claim of ICL would be reviewed. CCA
Karnataka has stated that the claim on inclusion of Service Tax in roaming related
deductions have been checked randomly and agreed with Audit. However, confirmation
of the observation raised by Audit on all the items is required to be done after thorough
verification.
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Thus allowing deduction including service tax component in violation of DoT’s instruction
led to excessive deduction of ` 24.35 crore resulting in short payment of revenue share.
9.2.4 Allowing deduction twice on same claim
As per conditions of licence agreement, operators shall submit claims for deduction towards
PSTN charges along with required proof as communicated by DoT from time to time. Test
check of records of CsCA revealed that in six LSAs, CsCA had allowed deduction twice
for invoice/voucher amounting to ` 11 crore in respect of three PSPs as detailed below.
Table 9.3
Name of the Pr. CCA/
CCA
Operator (Service Area)
Year of claim
Deduction Claim on First occasion
Year of claim
Claim on Second occasion
Amount claimed
Amount allowed by CCA
Amount claimed
Amount allowed by CCA
` in crore ` in crore
RaipurBAL (MP)
2007-08 (Q-4)
2.28 2.212008-09(Q-1)
2.28 2.21
LucknowBAL(UP(E))
2007-08(Q-4)
1.71 1.712008-09(Q-1)
1.71 1.71
MumbaiBAL (Mumbai)
2006-07 (Q-1)
2.09 2.092006-07(Q-2)
2.09 2.09
RajasthanBAL (Rajasthan)
2008-09 (Q-2)
0.94 0.942008-09(Q-3)
0.92 0.92
GuwahatiVodafone (Assam)
2008-09(Q-3)
2.35 2.652008-09(Q-4)
2.35 2.35
LucknowVodafone (UP(E))
2007-08 1.61 1.61 2007-08 1.61 1.61
BangaloreAircel (Karnataka)
2009-10 (Q-1)
0.10 0.102009-10(Q-2)
0.10 0.10
BangaloreAircel (Karnataka)
2009-10 (Q-2)
0.01 0.012009-10(Q-3)
0.01 0.01
TOTAL 11.00
On this being pointed out by Audit, three CsCA (Raipur, Lucknow and Bangalore) accepted
the audit observation and stated that the revision of verification would be carried out in
consultation with DoT as the assessment for the above period has already been completed.
Replies from remaining three CsCA (Mumbai, Assam and Rajasthan) are awaited.
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9.2.5 Excess deduction allowed by Pr.CCA Andhra Pradesh while restricting deduction
claims not supported by proof documents for TDS
In case of IUC payable to other operators, service tax is levied and TDS is also deducted
from the amount payable. However, only the IUC actually paid is eligible for deduction
from GR to arrive at AGR. In case of IUC deductions claimed by the PSP, proof documents
for amount paid (net of TDS) as well as proof for TDS deposited are required to be
submitted by the PSP at the office of the CsCA as per DoT’s instructions (July 2007 and
January 2012).
Audit scrutiny of records of Pr. CCA Andhra Pradesh revealed that BAL, RCL and TTSL
had not submitted the proof documents for TDS amount and hence the Pr. CCA office
disallowed TDS amount after recalculating the amount to be disallowed. While recalculating
the TDS related deduction, Pr. CCA allowed the deductible TDS amount including service
tax component, instead of limiting it to IUC alone. This resulted in allowing of excess
deductions amounting to ` 75.41 crore by the Pr. CCA Andhra Pradesh thereby reducing
AGR to that extent as detailed below:
Table 9.4
(` in crore)
YearExcess deduction allowed
TotalBAL RCL TTSL
2008-09
5.22 5.32 7.60 18.14
11.12 9.34 10.67 31.13
10.71 6.37 9.06 26.14
Total 27.05 21.03 27.33 75.41
On this being pointed out by Audit, Pr. CCA, Andhra Pradesh replied that TDS amount
would be disallowed during revision of deduction verification.
Further, response from the DoT was received (January 2016) wherein it was stated that in
respect of Reliance, revised report was received by DoT from Pr. CCA Andhra Pradesh.
However, in respect of Airtel, it was stated that reply from Pr. CCA Andhra Pradesh was
awaited. No reply has since been furnished by DoT regarding TTSL.
9.2.6 Allowance of deduction on account of TDS despite non-submission of TDS
certificate
As per the clarification for issue No.8 in their DoT letter No.1-28/2006/LF dated 5 July
2007, in case of adjustment of PSTN/Roaming charges between two PSPs the payment of
only net amount due is effected. However, the respective licensee can claim the deduction
Report No. 4 of 2016
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of the full amount. The licensee should however support this through proof of payment and
adjustment. The nature of proof of payment includes vouchers/bank statement/receipts.
While allowing the deduction claims submitted by the operators, for the portion of TDS
amount paid, CCA shall allow such portion of claim on the basis of submission of document
by the operator such as Form 16A duly attested/certified by the statutory auditor or TDS
certificate issued by tax deducting authority. If any of the said documents were not submitted
by the operator, the amount of TDS should be disallowed on the ground of non-submission
of proof documents for TDS amount.
Scrutiny of deduction claims of PSPs for the years 2006-07 to 2009-10, revealed that in
many CsCA, the deduction claims were allowed without production of proof documents for
TDS payments. DoT issued clarifications regarding the proof of documents to be accepted
for the TDS deductions and their admissibility during November 2014 wherein it was stated
that cases where deduction verification has been finalised may not be reopened by the
CsCA.
As most of the CsCA have completed the verification of deduction for the years
2006-07 to 2011-12, the short payment of licence fee on inadmissible deduction on account
of nonsubmission of proof for the TDS would not be recovered resulting in loss of LF to
the DoT to the extent of allowance of such claim.
On above issue, response from the DoT was received (January 2016) wherein it was stated
that in respect of CCA Chattisgarh, RCL/RTL had submitted the additional documents to
substantiate the TDS amount and the documents submitted were verified and revised report
sent to DoT. However CsCA Kolkata, Chennai, Bihar and Karnataka stated that verification
ofdeductionclaimedwascompletedonthebasisofguidelinesissuedbyDoTHQapplicable
at that time and there was no provision/instruction to separately confirm payment of TDS
when verification was conducted. In respect of Vodafone, too, it was stated by the CsCA
that the verification was carried out as per the DoT’s instruction prevailing at that time and
there was no provision/instruction to separately confirm payment of TDS when verification
was conducted. In respect of Airtel, it was stated that reply from CsCA was awaited.
Audit is of the view that there was lack of uniformity amongst CsCA in allowing deductions
on non-submission of proof documents for TDS.
9.2.7 Claims disallowed despite submission of proof documents
DoT clarified in July 2007 (Issue No.7) that proof of payment includes vouchers/bank
statements/receipts etc. and reiterated in November 2011 that submission of details including
payable invoices along with proof of payment/receipt is a pre-requisite for claiming
deductions by the licensees.
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On verification of deduction claimed by the licensee, it was noticed that in respect of five
PSPs (BAL, Vodafone, RCL, Idea and TTSL/TTML) in several LSAs despite availability
of proof of payment, various deduction claim of the PSPs like deduction on PSTN charges
and IUC were disallowed by CCA (Annexure - 9.01).
On this being pointed out by Audit, CCA Kolkata replied that regarding RCL the amount
was inadvertently disallowed by arithmetical mistake. The other CsCA also accepted the
audit observation and replied that the matter would be considered on request of the licensee
and the facts shall be intimated to DoT for further instructions. Further in its reply, DoT
stated that the claims were not rejected merely on technical grounds and it is also clear that
the verifications in most cases have been done as per DoT instructions.
9.2.8 CsCA permitted irregular deductions on inter-divisional adjustments of
` 432.64 crore.
DoT in July 2007 while clarifying admissibility of inter-divisional adjustments of PSTN
charges, specified that audited proof of adjustments certified by the statutory auditor was
required. In June 2013, DoT further clarified that proof of adjustment could be the extract
of ledger statement of adjustment on quarterly basis duly signed by the authorized signatory
of the licensee and at the end of the year account statement duly certified by the Statutory
Auditor of the licensee.
Audit scrutiny of records of ICL in five CsCA (Bhubaneswar, Lucknow, Meerut, Ahmedabad
and Ambala) revealed that CsCA allowed inter-divisional adjustments amounting to 432.64
crore for year 2007-08 to 2009-10 without obtaining prescribed proof of adjustments from
the licensee as detailed below:
Table 9.5
(` in crore)
Sl. No. Name of CCA Name of LSA Year Amount
1 Ahmedabad Gujarat2008-09 25.43
2009-10 128.76
2 Bhubaneswar Odisha 2009-10 5.97
3 Lucknow UP (East) 2007-08 13.67
4 Meerut UP (West) 2007-08 to 2009-10 188.92
5 Ambala Haryana 2006-07 to 2008-09 69.89
Total 432.64
On this being pointed out by Audit, CCA Bhubaneswar stated that the operator would be
directed to submit detailed operator-wise statement before re-verification is carried out,
while other CsCA replied that verification of deduction was done on the basis of DoT’s
clarification issued in July 2007.
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The reply is not tenable as DoT vide its letters dated 5 July 2007 and 10 January 2012 had
clarified that the licensed company was to furnish documents duly certified by the Statutory
Auditor at the end of the year to avail benefit of deduction on account of inter-division
payments/adjustments.
9.2.9 Miscellaneous Observations
9.2.9 (a) Excess allowance of deduction claim ` 3.87 crore to Dishnet Wireless Ltd.
(Aircel Group of companies) of Assam LSA.
Scrutiny of the statement of revenue and licence fee for the year 2009-10 in respect of DWL
(Aircel) in Assam LSA revealed that CCA had erroneously allowed ` 3.91 crore being the
payment made to BSNL against the invoice amount of ` 0.04 crore which had resulted in
excess allowance of deduction to the tune of ` 3.87 crore.
CCA replied that factual position would be furnished after verification of the records.
9.2.9 (b) Verification on the basis of Unaudited AGR and Estimated AGR
DoT instructed that verification of deduction based on quarterly documents submitted
by the PSPs shall be done after submission of annual audited accounts. Scrutiny of the
verification reports of Vodafone and TTSL alongwith audited and estimated AGRs revealed
that verification of deduction claimed for the period from 2006-07 to 2008-09 in Rajasthan,
Kerala and Madhya Pradesh service areas was conducted on the basis of unaudited AGR
while verification of deduction claimed for the year 2006-07 in Odisha service area was
conducted on the basis of estimated AGR.
On this being pointed out by Audit, CCA, Madhya Pradesh replied that facts and figures
would be confirmed; whereas CCA Odisha replied that verification was now being done on
the basis of Audited AGR.
In the absence of verification of deduction based on audited AGR, the authenticity of
deductions claimed by PSPs could not be verified.
9.2.9 (c) Improper permitting of claim of deduction
Test check of records of two CsCA (Andhra Pradesh and Bhubaneswar) revealed that
(i) In respect of claim for deduction for the year 2008-09 submitted by BAL, Pr. CCA
Andhra Pradesh allowed an amount of ` 0.18 crore without any adjustment details
by the operator.
(ii) CCA Bhubaneswar allowed claim of ` 4.86 crore of deduction for the year 2008-09
out of which an amount of ` 3.94 crore was passed without any claim of the same
by the operator and an amount of ` 0.92 crore already disallowed by the CCA was
wrongfully included as allowed amount in the verification report submitted to DoT.
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On being pointed out, Pr. CCA Andhra Pradesh accepted the audit observation and informed
that the same will be addressed in the verification report. CCA Bhubaneswar accepted the
audit observation relating to ` 0.92 crore of wrongly allowed claim and reply was still
awaited in respect of the balance ` 3.94 crore.
9.2.9 (d) Deductions claimed in advance
As per conditions of licence, claims on deduction of PSTN charges should be allowed on
actual basis. On a test check of the PSTN charges claimed as deduction by Vodafone and
Tata Group of Companies for the period from 2006-07 to 2009-10 along with the respective
verification reports of the CsCA, it was noticed that four4 CsCA had allowed deduction of
PSTN charges in advance of the year in which the payment was actually made.
On being pointed out,
• CCAChennairepliedthatasperissueno.5ofclarificationdated5July2007
of DoT, date of receipt of cheques by receiving licensee, was to be taken as
date of payment and accordingly the claims were allowed.
• CCAMadhyaPradeshcarriedoutre-verificationofdeductionsclaimedby
thePSPandrepliedthatadetailedreportthereonwassubmittedtoDoTHQ
• CCAOdisha replied that in view of audit observation and issue of new
instructions, re-verification of the claim was under process.
• CCAKolkatarepliedthatthelicenseeshallbeaddressedinthisregardand
outcome shall be intimated
The reply furnished by CsCA Chennai was not acceptable as the cheques were issued in
the year 2006-07 whereas the date of actual payment was in the next financial year i.e. in
2007-08. This could result in double deduction as there was possibility of deduction claims
being allowed again in the following year. With disclosure to this effect not being made by
statutory auditors, the eventuality needs further verification.
9.2.9 (e) Non-submission of operator-wise details of revenue receivable and actual
payments made.
As per condition 20.4 of the licence agreement, the licensees were required to furnish to
the licensor in their statement of revenue and licence fee (Appendix-II to Annexure-II of
License Agreement), operator-wise details of pass through revenue receivable in their GR
and operator-wise details of actual payments made against deductions claimed, for arriving
at the AGR. This information from the operators is an important input for final assessment
by DoT, since it facilitates cross examination of the claims made by PSPs.
4 Chennai,MP,Odisha,Kolkata
Report No. 4 of 2016
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Review of financial statements submitted by Vodafone for the period 2006-07 to
2009-10 revealed that operator-wise details of revenue receivable were not disclosed by the
company. Operator-wise pass through charges payable were also not furnished by Vodafone
from 2008-09 onwards. In absence of this information, which serves to cross check claims of
operator-wise revenue receivables/ payables, the possibility of PSPs erroneously including
revenue in GR after set-off (netting off receivable-payable) and then claiming deductions in
full with proof of actual payment cannot be ruled out.
Thus, the operator failed to submit correct and authentic documents containing prescribed
details relating to pass through revenue to the CsCA/DoT and as a result the pass through
revenue receivable and deductions based on actual payment of pass through charges paid to
other operators cannot be verified by the CsCA/DoT.
9.2.9 (f) Delay in submission of proof documents by service providers and delay in
process of verification/re-verification
The licence conditions stipulate time frame for payment of LF and submission of proof
documents by licensee. Reiterating Clause 22.3 (a) of UASL agreement which confers
right on licensor or TRAI to call for any book of accounts which the licensee maintains,
DoT directed (August 2010) all PSPs to submit details of payments made to other service
providers and service/sales tax paid along with necessary documents in support of deductions
in AGR statement.
In the light of verdict of Hon’ble Supreme Court of India (October 2011) setting aside
TDSAT order on claiming deductions on accrual basis, DoT granted extension of time upto
December 2011 to the operators to submit all requisite documents to support deductions
claimed from 2007-08 onwards. However, scrutiny of data (test checked for Vodafone)
available in CsCA revealed inordinate delays in submission of required proof documents
in various LSAs during 2007-08 to 2009-10. Documents were also submitted in staggered
manner affecting the timely completion of verification process.
Further CsCA also failed to adhere to the time frame stipulated by DoT for completion of
verification of deductions and submission of report on verification to LF Branch. Test check
in case of Vodafone revealed that none of the CsCA submitted verification reports within
time frame and delay in completion of verification of deductions claimed by Vodafone
ranged from 3 to 68 months (Annexure - 9.02).
Audit also observed delay in completion of re-verification based on SC judgment dated
11 October 2011 (Annexure - 9.02). Thus, delays in submission of required proof documents
by the operator and the inability of DoT to force the issue with the operator has led to a
situation where the Government could not correctly assess the actual revenue share.
Report No. 4 of 2016
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9.3 DoT’s response
DoT’s response in relation to verification process of deductions claimed by the three
operators (BAL, Vodafone and Reliance) at the offices of CsCA was received in January
2016. Reply specific to excess deduction allowed by Pr. CCA Andhra Pradesh and allowance
of deductions on account of TDS has been included in para 9.2.5 and 9.2.6 respectively.
In general, DoT stated that the verification work decentralized to CsCA’s had initial teething
troubles. One issue which directly impacted the process of deduction verification was the
disagreement between DoT and PSPs on whether deductions will be allowed on paid basis
or accrual basis. The licence agreement provides for deduction on paid basis while the PSPs
insisted on submitting documents to CsCA on accrual basis. The PSPs often taking the
shelter of litigation either did not provide the documents or provided them in un-acceptable
formats. The Department got judgment from Hon’ble Supreme Court in 2011 and only after
this did the PSPs started submitting documents which were also not complete. The PSPs
had to be provided with extra time in respect of production of documents which had to be
obtained from other parties like bank (for payment proof)/Government Departments (TDS
proof etc.).
Further, DoT stated that after the deduction verification work was decentralized to the
CsCA offices, there were several operational issues including interpretation of DoT
instructions on deduction verifications. Clarifications were sought from DoT by the CsCA
offices regarding various issues related to deductions claimed like international roaming
charges, lease line charges, Access charges etc and the documents mandatorily required for
submission. However, the process of submission of documents and verification in the recent
years has become relatively more timely and regular.
Audit is of the view that the issues highlighted by DoT are in its administrative domain and
DoT should take proactive action to streamline the process of verification of deductions
claimed by the operators. The licence agreement include penal provisions for violation of
licence terms and conditions. However, these provisions have not been used by DoT to
enforce the agreements.
As brought out in the earlier paragraphs, verification of deduction claims at CsCA level
was not done uniformly and CsCA have taken different approach in allowing/disallowing
deduction claims submitted by the PSPs. During the course of audit of records maintained
by CsCA for verification of deduction claims, discrepancies on various issues were noticed
among different CsCA. Also within the same CsCA, different yard sticks were adopted for
different operators due to lack of co-ordination within the CsCA. The main reason for these
discrepancies was the lack of proper monitoring of CsCA by DoT.
Report No. 4 of 2016
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CHAPTER – XAssessment of Licence Fee and Spectrum Usage Charges
10.1 Introduction
The Licence Finance (LF) wing in DoT is responsible for the assessment of GR and final
computation of the revenue share payable by the Licensees. Assessment of GR is done
taking into account the Audited AGR and reports/reconciliation statements received from
the PSPs. Final revenue share is to be calculated considering the collection details and
verification reports received from the Offices of the CsCA. Additional demands, if any,
based on the GR assessment and LF paid by PSPs are then to be raised by the LF Wing.
Penalty for delayed/short/non-payment of LFs is also to be levied by the LF wing. For
spectrum charges, the Wireless Planning Finance (WPF) Division of DoT was responsible.
Other duties in connection with revenue share realization for DoT included –
• CalculationandcollectionofpenaltyfordelayedpaymentofLF
• Computationofinterest/penaltyforshort/non-paymentofLF
• Maintenance/forfeitureoffinancial/performancebankguarantees
• Suspension,terminationoflicenses
• Levyofliquidateddamagesincaseoffailureonthepartofthelicenseein
meeting roll out obligation and target/commitment etc.
The process of assessment of LF and SUC undertaken by DoT in respect of the PSPs was
test checked and the findings are as given below:
10.2 Audit Findings
10.2.1 Under assessment of GR due to omission of revenues disclosed in reconciliation
statements
The UASL agreement conditions stipulated that every licensee should submit reconciliation
between the figures appearing in the quarterly statements of revenue and LF payable with
those appearing in annual accounts along with their audited annual accounts. Since the
final adjustment of LF payable was based on the GR figures certified by the auditors of
the licensee, the information presented in the reconciliation statement was an important
document which explained the variations between the GR computed for payment of LF with
the revenue appearing in the profit and loss account of the licensee company. The notes to
the accounts/disclosures of the Auditors and schedules in the annual accounts were other
documents which facilitated DoT in identifying those items of revenue which were not taken
into account for arriving at the GR as envisaged in the Licence agreements.
Report No. 4 of 2016
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A test check of the demands raised by DoT after assessment of the accounts of various
LSAs of Vodafone Group for the years 2006-07 to 2009-10 revealed that various items
of revenue which were disclosed by Auditors through reconciliation statements annexed
to AGR statements as well as schedules annexed to Profit and Loss Account etc., were
overlooked by DoT while assessing the GR of the company (Annexure - 10.01). Failure
of DoT to add back such revenue items, disclosed by the Statutory Auditors, to GR/AGR
resulted in short payment of LF/SUC.
DoT in reply (January 2016) agreed with the audit contention and informed that necessary
demands would be raised after verification.
10.2.2 Lack of coordination between LF and WPF Wing
As per licence conditions for using radio frequency spectrum allotted by DoT, PSPs in
addition to LF, shall also pay spectrum charges on revenue share basis. However, while
calculating ‘AGR’ for limited purpose of levying spectrum charges based on revenue share,
revenue from wire line subscribers shall not be taken into account.
It was seen from the assessments finalized by WPF wing of DoT towards SUC for the years
2006-07 to 2009-10, that they were carried out taking into account the AGR stated by the
operator in the audited AGR statements.
However, consequent to the assessments carried out by the LF wing of DoT, taking into
account the verification reports of CsCA and disclosures in the audited financial statements
of the PSPs there were certain revenue items added back to the AGR. These additions to
the AGR were not being considered by the WPF division for working out SUC as detailed
below:
i) Vodafone being a cellular mobile service provider, the revenue assessed for LF
should be the revenue for assessing the spectrum charges also. Short assessment of
SUC, on account of the failure to consider the revised assessment done by LF wing
for raising additional SUC worked out to ` 267 crore for the period 2006-07 to
2009-10.
ii) In respect of Aircel Group of companies for the years 2006-07 to 2009-10, while
for assessment of LF, AGR was revised by adding PSTN disallowed, un-reconciled
differences, rebates & discounts, dividend income, other income, foreign exchange
gains, profit on sale of fixed assets, Interest income etc., AGR submitted by the
Report No. 4 of 2016
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company was taken up by DoT for assessment of SUC. Thus the difference in AGRs
for the years 2006-07 to 2009-10, considered for LF and SUC was ` 973.59 crore
resulting in short recovery of SUC by DoT. To an audit query in this regard, it was
replied by DoT (January 2016) that SUC is being revised as per AGR intimated by
LF wing of DoT.
iii) DWL (Aircel) submitted ‘Nil’ AGR for Haryana and Punjab service area for the year
2009-10 since their services did not commence. While DoT raised the demand of
LF for Haryana and Punjab service area for the period by adding foreign exchange
gains, SUC was not revised. On being pointed out by Audit (September 2015), it
was replied by DoT (January 2016) that SUC is being revised as per AGR intimated
by LF wing of DoT.
iv) In respect TTSL and TTML, while the assessments carried out by the LF wing
of DoT for the years 2006-07 to 2009-10, had taken into account the verification
reports of CsCA and disclosures in the audited financial statements of the PSP the
WPF division did not consider the above information for working out the SUC.
v) Out of the total deductions of ` 228.62 crore claimed by RCL (Gujarat Circle),
` 167.46 crore was disallowed by CCA. While DoT had taken into account the
inadmissible deductions disallowed by CCA Ahmedabad and added back to AGR for
arriving at the short paid LF, assessment of SUC (CDMA and GSM) was finalized
by accepting the total deductions claimed by RCL (` 133.48 crore for CDMA and
` 82.21 crore for GSM) as admissible deduction without considering inadmissible
deductions disallowed by CCA (` 97.77 crore for CDMA and ` 60.22 crore for
GSM). The finalisation of assessment of SUC without considering inadmissible
deductions disallowed by CCA and considering total deductions claimed by RCL,
resulted in short payment of Spectrum Usage charges. (Annexure - 10.02)
Response to audit query seeking the reasons for not considering the assessment done by
LF wing for computing SUC was awaited from DOT, except for para (ii) and (iii) above.
10.2.3 Issue of demand notes based on special audit and provisional assessment without
proper due diligence.
Based on special audit/provisional assessment for the years 2006-07 and 2007-08, DoT
issued demand notes after adding back the respective amounts to AGR for computation of
LF. Discrepancies noticed in the demand notes are detailed in Table 10.1 below:
Report No. 4 of 2016
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Table 10.1
Year Name of the TSP Audit Observations2006-07 BAL In the demand note issued for the year 2006-07 based on special
audit, interest income of ` 20.23 crore was included twice in the demand and supplementary show cause notice. Further, instead of apportioning the corporate income amongst all the licences held by the TSP, it was included only under Delhi LSA.
` 87.38 Crore was added to AGR of Delhi LSA as income from IP1 services accounted in IP1 TBs. Inclusion of entire revenue of IP1 under Delhi LSA was not proper.
Vodafone As per the audited accounts of company the deduction claim was inclusive of ` 23.17 crore in respect of “Amounts paid/adjusted during the year ended 31 March 2007, against amounts claimed as deduction from GR for the financial year 2005-06 or earlier” which indicated that deduction on this account has already been claimed from GR through the respective CsCA. But, this disclosure was not considered in the final assessment which allowed the operator the benefit of claiming double deductions. DoT informed (January 2016) that service area wise demands were being issued on the above issue.
2007-08 BAL In the demand note issued for the year 2007-08, based on special audit, interest income of ` 65.01 crore, was included twice in the demand notes issued on provisional assessment and Special audit including supplementary demands. Further, instead of apportioning the corporate income amongst the licences held by the PSP its inclusion in Delhi LSA only was not proper.
` 38.75 crore being income from trading in VSAT equipment accounted in TB maintained for erstwhile Satcom Broadband Equipment Limited, a subsidiary of BAL was added to AGR of Delhi LSA. Inclusion of entire revenue under Delhi LSA was not proper as this should have been included in VSAT AGR.
` 100.92 crore added to AGR of Delhi LSA as income from IP1 services and inclusion of entire revenue of IP1 under Delhi was not proper.
In respect of audit observations relating to BAL, the DoT replied (January 2016) that the
audit observation was noted and the para was communicated to BAL for their comment. It also stated that items pointed out by Audit are pending in Kerala High Court and action would be taken after the judgement.
Thus, DoT did not exercise due diligence while issuing demand notes that may lead to
further litigation.
10.2.4 Delay in submission of documents by service providers and absence of proper
policy on time schedule leading to delay in verification of deductions by CsCA
DoT delegated (September 2006) verification of deductions to CsCA on quarterly basis. The above verification for each quarter was to be completed by the CCA within a stipulated
Report No. 4 of 2016
- 149 -
time frame, i.e. by 15 October, 15 January, 15 April and 30 June for quarters I, II, III and IV respectively of the financial year. Also DoT (April 2007) specified the documents to be submitted and the consequences of not submitting the documents within the specified time schedule.
On test check of the records at the offices of CsCA relating to verification of deductions, it was noticed that in seven1 CCA offices, there was considerable delay in submission of
documents by RCL and in verification of deductions claimed due to non-submission of
documents by the operator. This delayed the verification of deductions by the CCA office
by a period of one month to 59 months (Annexure – 10.03).
DoT issued (July 2008) instructions stating that operators should be given opportunity to
submit the missing documents and instructed the CsCA to furnish the details of inadmissible
deductions to the operator. Accordingly, RCL got extension for furnishing of the documents
ranging from 15 days to five months. Further, it was also observed that RCL after the
provisional assessment of LF again got extension of time for submission of documents
which ranged from 15 days to 6 months.
Thus due to the inconsistent policies of the DoT, the Telecom operator submitted the
documents on piece meal basis on various occasions resulting in delay in the process of
verification which needs a further review and proper instructions from DoT. Reply is
awaited from DoT on this observation.
10.2.5 Non assessment of LF of NLD, ILD and ISP for the year 2006-07 to 2009-10
DoT has not carried out assessment of licence fee for NLD, ILD and ISP for the year
2006-07 to 2009-10 in respect of DWL and Delhi Service area in respect of Aircel Ltd. for
the year 2009-10 despite lapse of more than five years.
DoT replied that assessment could not be done due to non-receipt of verification reports
from CCA as of September 2015.
Reply of the DoT is not acceptable as the CsCA are under administrative control of DoT
and DoT should have obtained the verification reports.
10.2.6 Non recovery of LF and SUC on international roaming claimed by the Telecom
Service Providers
Clause 2.2 (a) of the UASL agreement provides for the licensee to enter into an agreement
with other service provider(s) in India or abroad for providing roaming facility to its
subscriber under full mobility service unless advised/directed by licensor otherwise. As per
Clause 19.2 of the UASL/CMTS agreement, following shall be excluded from the GR to
arrive at AGR-
1 Odisha,Delhi,Patna,Bangalore,UP(West),UP(East)andKerala
Report No. 4 of 2016
- 150 -
• PSTNrelatedcallcharges(AccessCharges)actuallypaidtoothereligible/
entitled telecommunication service providers within India;
• Roaming revenues actually passed on to other eligible/entitled
telecommunication service providers and;
• Service tax on provision of service and sales tax actually paid to the
Government if GR had included as component of sales tax and service tax.
DoT issued (20 September 2006) instructions to all Telecom Service Providers intimating them about the decentralization of verification of deductions to office(s) of CsCA. They were directed to submit the proof of payment to CsCA on demand. In terms of the letter, deduction on account of “roaming revenues actually passed on to other eligible/entitled Telecommunication Service Providers (TSPs) within India” was permissible for the purpose of arriving at AGR. Therefore, roaming revenues actually passed on to Foreign Service Providers (International Roaming) was not eligible for deduction for the purpose of arriving at AGR.
DoT issued an internal letter to all CsCA on 21 September 2006 detailing the verification of deduction from the GR by the PSPs alongwith which letter dated 20 September 2006 addressed to all Telecom Service Providers was also enclosed.
It was seen that only in November 2014, DoT issued a specific clarification that the entire deduction claims on account of International Roaming to be inadmissible. The justification offered was that foreign operators were not eligible/entitled operators as licence to them was not issued by DoT. It was also mentioned that cases where deduction verification has been finalised/closed may not be opened by CsCA for the time being till further orders.
Audit observed during test check that international roaming charges actually passed on to the international operators were allowed as deduction by some CsCA2 whereas it was disallowed by some other CsCA3. Inconsistencies in the clarifications issued by DoT regarding deduction claims on account of international roaming charges has resulted in non-uniformity among CsCA regarding allowance/disallowance of deduction claims on account of International Roaming charges and possible loss of revenue to the exchequer in terms of revenue share.
In reply to above audit observation issued to DoT (April 2015), it stated (January 2016) that the verification of deduction on account of International Roaming claimed by Telecom Service Providers was carried as per order dated 5 July 2007 up to 6 November 2014. These were superseded by order dated 7 November 2014. It further stated that the issue was presently under review.
The above reply of the DOT confirms that the issue is still under review and has not reached its finality which may lead to continuance of non-uniformity among CsCA regarding
allowance/disallowance of deduction claims on account of International Roaming charges.
2 Karnataka,MadhyaPradeshandKerala3 Delhi,WestBengal
Report No. 4 of 2016
- 151 -
10.2.7 Lack of appellate mechanism resulting in high number of litigations
DoT has been contributing 13.76 to 20.17 per cent of total non-tax revenue in the form of
LF and SUC for Government of India during the period from 2012-13 to 2014-15 as detailed
in Table 10.2 below:
Table-10.2
(` in crore)
RevenueActual 2012-13
Actual 2013-14
Revised 2014-15
Budget 2015-16
Total Non-Tax revenue of Govt. of India 137354 198869 217831 221732
Non Tax Revenue from Communication service under head “Other Communication Services”
18902 40113 43161 42865
Percentage of Non-Tax Revenue contributed by Communication
13.76 20.17 19.81 19.33
(Source: Budget document)
As detailed in the earlier chapter, DoT, as the licensor, is required to assess the correctness of
revenue share due from the PSPs as per provisions in the licence agreements. This assessment
process includes verification of deductions claimed by the telecom service providers to arrive
at AGR and assessment of GR to ensure the correct reporting of all revenues as per relevant
licence agreements.
It has been observed that within few years of introduction of revenue share regime, service
providers challenged the definition of AGR in different courts of law. The service providers,
individually and through their associations, filed petitions during 2003 to 2005 before the
TDSAT questioning the validity of the AGR defined in the licence agreement. One of
the contentions of the service providers’ was that the definition of the AGR and certain
components included in the AGR is contrary to the Indian Telegraph Act, 1885, National
Telecom Policy of 1999, the recommendations made by the TRAI and the Migration Package
offered to the licensees.
TDSAT in August 2007 concluded that AGR shall be the revenue earned through
licensed activity and decided the items of revenue that would form part of AGR thereby
curtailing the scope of GR as defined in the license agreement. The pronouncement of
TDSAT was challenged by DoT in the Hon’ble Supreme Court of India which pronounced
(October 2011) in its judgment that “TDSAT had no jurisdiction to decide on the validity of
the definition of AGR in the licence agreement and to exclude certain items of revenue which
otherwise formed part of AGR as defined in the licence agreement”. However, Hon’ble
Supreme Court was of the opinion that in case of any disputes regarding demands raised by
DoT, PSPs shall approach TDSAT and TDSAT shall also give opinion as to whether the
demands are in line with agreement conditions.
Report No. 4 of 2016
- 152 -
During the course of audit at DoT, it was noticed that DoT raised demands on operators based
on its annual assessments and on the findings of the special audit which were challenged
in the TDSAT. While Vodafone, BAL/BHL and ICL have challenged/represented against
all the demands raised, M/s Aircel Ltd. had represented against three out of five demands
raised on them. The details of demands raised by DoT and paid by the PSPs are as under:
Table 10.3
(` in crore)
Name of the PSPTotal Demand raised by DoT (LF + SUC)
Amount paid Balance due
BAL/BHL 2294.33 0.00 2294.33
Vodafone 1320.00 0.72 1319.28
RCL/RTL 2394.89 0.00 2394.89
Idea 1047.24 0.00 1047.24
TTSL/TTML 1066.33 0.00 1066.33
Aircel 195.45 0.03 195.42
Besides, the operators filed another petition again challenging the validity of definition of
AGR in Kerala High Court and other High courts. In April 2015, TDSAT adjudicating on
the demands raised by DoT gave its ruling which exempted certain items of revenue from
the purview of AGR and set aside the demands raised by DoT. DoT has filed appeals in the
Supreme Court against the TDSAT’s order of April 2015 (July 2015).
Thus, even though the revenue share regime has been in force since 1999, even after lapse
of sixteen years the basic question of the definition of AGR on which revenue share is
computed has not reached finality with the result that Government of India has been left
with no option but to accept only what the PSPs pay as LF and spectrum charges.
By challenging all demands raised by DoT, even on disallowances on account of clear
deviations from the provisions of licence agreement, the efforts of the Government in
securing its dues as revenue share have been effectively hindered by the operators. The
increasing number of pending court cases indicate that the directions/procedures framed
by DoT for verification of AGR, imposition of interest/penalty etc., were susceptible to
different interpretations leaving room for numerous disputes.
Though DoT had revised the rates of LF and SUC from time to time, the definition of
GR/AGR was not reviewed despite the increasing numbers of disputes/litigation. Thus,
it is recommended that there is a need for clear, cogent and specific description of
the scope of GR/AGR. This is essential as even after 16 years since the introduction of
the revenue share regime, the correctness and completeness of revenue flowing into the
Consolidated Fund of India could not be ensured by DoT.
Report No. 4 of 2016
- 153 -
The absence of an appellate/redressal mechanism within DoT to address disputes with
operators contributes to the increasing number of litigations. To minimize the litigations on
the demands raised by DoT, it is recommended that an appellate mechanism within the
department should be established to address the disputes between DoT and the PSPs
on demands raised by DoT.
In reply to above audit observation issued to DoT (April 2015), it stated (January 2016)
that presently the appeals were dealt with through the administrative hierarchy of the
Department and the process of setting up a formal appellate structure was in process.
New DelhiDated : 8 February 2016
(Meera Swarup)Director General of Audit
(Post and Telecommunications)
Countersigned
New DelhiDated : 9 February 2016
(Shashi Kant Sharma)Comptroller and Auditor General of India
Report No. 4 of 2016
- 157 -
Airtel
ANNEXURE-1.01 [Para 1.2]List of Companies which migrated to Revenue Share Regime
Sl. No.
Name of Licensee Company Service Areas
1 Aircel Ltd. Tamil Nadu (excluding Chennai Service Area)
2 Aircel Cellular Limited Chennai
3 Bharti Airtel LimitedDelhi, Kolkata, Mumbai, Andhra Pradesh, Himachal Pradesh, Punjab, Karnataka, Gujarat, Haryana, Kerala, Madhya Pradesh, Maharashtra
4 Bharti Hexacom Ltd. Rajasthan, North East
5 HFCL Infotel Ltd. Punjab
6 Idea Cellular Ltd. AP, Delhi, Gujarat, Haryana, Kerala, MP, Maharashtra, UP-W, Punjab, HP, Rajasthan, UP (E)
7 Loop Mobile (India) Ltd. Mumbai
8 Reliance Telecom Ltd. Assam, Bihar, HP, MP, North East, Odisha, West Bengal, Kolkata
9 Reliance Communications Ltd.
Gujarat, AP, Delhi, Bihar, HP, Haryana, Karnataka, Kerala, Kolkata, MP, Maharashtra, Mumbai, Odisha, Punjab, Rajasthan, UP (E),UP (W), West Bengal, Tamil Nadu (including Chennai)
10 Spice Communications Ltd. Karnataka, Punjab
11 Sistema Shyam Teleservices Ltd. Rajasthan
12 Vodafone Essar Ltd. Mumbai
13 Vodafone Essar East Ltd. Kolkata
14 Vodafone Essar Mobile Services Ltd. Delhi
15 Vodafone Essar Digilink Ltd. Haryana
16 Vodafone Essar Gujarat Ltd. Gujarat
17 Vodafone Essar Cellular Kerala, Maharashtra, Tamil Nadu
18 Vodafone Essar South Ltd. Chennai, Karnataka, AP, Punjab
19 Tata Teleservices (Maharashtra) Ltd. Maharashtra, Mumbai
20 Tata Teleservices Ltd AP, Delhi, Gujarat, Karnataka, Tamil Nadu (including Chennai)
21 Mahanagar Telephone Nigam Ltd. Delhi, Mumbai
Note: Licences of Vodafone Group were originally with Essar/Hutch etc. Name Vodafone is used for easy identification
Report No. 4 of 2016
- 158 -
Airtel
AN
NE
XU
RE
3.0
1 [P
ara
3.2.
1 (A
)]Im
pact
on
paym
ent o
f LF
and
SUC
due
to n
on c
onsi
dera
tion
of r
even
ue fr
om C
omm
issi
on a
nd M
argi
n(A
mou
nt in
`)
Serv
ices
/LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
-pa
ctSU
C Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
AP
1207
8741
9662
9954
7167
1058
0444
184
6435
548
1410
290
6602
090
6602
4125
0425
6768
072
2567
6807
1168
2947
Ass
am
2613
6355
1568
181
7448
8690
9110
9854
5466
631
3643
311
5677
660
6940
660
3990
879
1352
6026
081
1561
646
6647
9B
ihar
20
9688
384
1258
1303
9079
507
3064
3728
818
3862
3713
9428
9753
7206
188
3223
2371
2444
2882
5244
3101
531
4658
6123
8616
11C
henn
ai
--
--
--
--
-11
6340
271
1163
4027
5642
503
Del
hi15
2358
530
1523
5853
6627
596
--
-46
4925
846
4926
2022
4330
6971
929
3069
7193
1335
3279
Guj
arat
-
--
--
--
--
2366
3372
623
6633
7386
3713
1H
arya
na
3324
7429
2659
794
1157
011
1990
666
1592
5368
678
1633
876
1307
1056
369
9930
9183
7944
735
3426
167
HP
1054
516
5272
636
381
7462
189
3731
0925
7446
2347
359
1408
4280
984
9749
3766
5849
626
3363
535
J& K
-
--
--
--
--
1048
2798
562
8967
936
1656
5K
arna
taka
-
--
4772
7771
938
1822
1822
1934
1498
8115
138
9881
1514
4594
7354
1007
9484
2310
0794
842
4686
9602
Ker
ala
-
--
4048
432
3238
7514
3719
5330
111
4264
0918
9219
2467
9152
219
7433
2287
6109
9K
olka
ta
4953
622
4953
6221
3006
1041
912
1041
9144
802
--
-11
2724
049
1127
2405
4847
134
Mah
aras
htra
74
2603
874
2604
2710
5026
9489
732
2694
8973
9836
375
1604
6002
116
0460
0264
9863
144
6703
043
4467
0304
2077
1692
MP
6907
6411
5526
113
2521
289
3175
5495
025
4043
9611
5907
5632
1367
123
2570
9370
1172
9900
1417
8739
111
3429
9151
7524
0M
umba
i 12
3075
296
1230
7530
5599
926
1773
1885
517
7318
8580
6800
892
1486
4192
1486
441
9276
325
3485
417
2534
8542
1153
3586
Odi
sha
-
--
2678
050
1606
8312
0512
1043
2679
6259
6146
9471
1546
6184
892
7971
169
5978
3Pu
njab
-
--
--
-56
1141
144
8913
2497
0830
9785
347
2478
2828
1378
5448
TN23
7084
223
7084
9009
2-
--
1127
1209
1127
121
5466
5426
8285
978
2682
8598
1301
1870
UPE
4563
0435
3650
435
1597
065
--
-72
0093
257
6075
2664
3495
3381
2176
2705
042
9021
5U
PW-
--
--
--
--
7876
3895
6301
112
2796
118
WB
--
-66
145
5292
1786
--
-17
0349
287
1362
7943
5962
225
TOTA
L B
AL
6870
9660
056
0232
8428
4849
7617
6208
1478
1416
9913
474
2189
2822
7251
7625
1938
0233
899
2759
9351
6466
0528
4529
5656
322
3014
230
NE
1125
6790
6754
0726
4535
4546
8753
2728
125
1068
516
9543
1725
5725
904
2528
941
1113
3919
066
8035
137
2986
3R
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than
-
--
--
--
--
4702
8970
337
6231
7621
3981
81TO
TAL
BH
L11
2567
9067
5407
2645
3545
4687
5327
2812
510
6851
695
4317
2557
2590
425
2894
158
1628
893
4430
3528
2512
8044
TOTA
L U
ASL
6983
5339
056
6986
9228
7495
1018
0755
0231
1444
2725
975
2874
4323
6794
9350
1995
2824
210
1804
934
5746
2894
2249
7260
091
2481
4227
4
(` in
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re)
Serv
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/Com
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Tota
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0
89.
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45.
40
Report No. 4 of 2016
- 159 -
Airtel
AN
NE
XU
RE
3.0
2 [P
ara
3.2.
1 (B
)]Im
pact
on
paym
ent o
f LF
and
SUC
due
to n
on c
onsi
dera
tion
of r
even
ue fr
om F
ree A
ir T
ime
(FAT
)(A
mou
nt in
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ices
/LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im-
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im-
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
AP
--
--
--
5470
9206
954
7092
0724
8926
8919
4072
0419
4072
088
3028
Ass
am
3767
350
2260
4110
7369
--
--
--
2091
0365
1254
622
7214
08B
ihar
32
0978
6219
2587
213
8983
741
2356
6624
7414
018
7622
310
0460
834
6027
650
4570
968
1030
9534
161
8572
046
9083
8C
henn
ai
--
--
--
--
-19
4407
419
4407
9428
8D
elhi
1744
3564
517
4435
6575
8795
122
5559
684
2255
5968
9789
290
2866
0720
628
6607
2112
4674
1352
2353
8152
2353
822
7223
9G
ujar
at
--
-13
0013
613
0014
4745
5-
--
1903
7652
1903
765
6948
74H
arya
na
--
--
--
--
-60
5902
848
4722
2090
36H
P-
--
--
-88
000
5280
3036
9042
525
5425
5231
1967
J& K
-
--
--
-39
9890
023
9934
1379
6219
8022
2311
8813
368
3177
Kar
nata
ka
8915
3807
7132
305
4145
652
1166
6963
0193
3357
0454
2513
7813
7504
9131
1375
0491
363
9397
8584
4038
106
8440
3811
3924
7772
Ker
ala
33
8326
2706
612
011
0
087
4431
6995
431
042
9817
797
7854
2434
8532
Kol
kata
-
--
2233
750
2233
7596
051
--
-10
2135
0210
2135
043
9181
Mah
aras
htra
-
--
--
--
--
4277
4589
4277
459
1989
018
MP
6947
7825
5558
226
2535
941
3869
4734
3095
579
1412
358
1971
6409
915
7731
2871
9649
010
1998
4181
5987
3722
94M
umba
i 23
4223
439
2342
2344
1065
7166
1981
1582
1981
158
9014
27-
--
1861
1751
1861
175
8468
35O
dish
a
4849
2315
2909
539
1939
693
2120
2747
1272
165
9541
2423
1001
9413
8601
210
3950
922
9907
3513
7944
410
3458
3Pu
njab
-
--
--
--
--
1440
9601
1152
768
6412
27TN
--
--
--
--
-48
1127
648
1128
2333
47U
PE-
--
--
--
--
9495
664
7596
5342
7305
UPW
--
-30
632
2451
1087
--
-30
4972
324
3978
1082
65W
B-
--
3259
500
2607
6088
007
--
-10
1525
4681
2204
3553
39TO
TAL
BA
L65
1986
569
5864
4957
2837
5620
1520
0247
3312
5331
313
6941
7400
2534
4348
6424
4376
799
1142
7889
412
5209
8924
1169
1256
156
6045
53N
E60
7707
3646
214
281
--
--
--
1424
5367
8547
2247
7220
Raj
asth
an
--
--
--
--
-12
2715
5398
1724
5583
56TO
TAL
BH
L60
7707
3646
214
281
--
--
--
2651
6920
1836
446
1035
575
TOTA
L U
ASL
6525
9427
758
6814
1928
3899
0115
2002
4733
1253
3131
369
4174
0025
3443
4864
2443
7679
911
4278
894
1278
6158
4411
8749
007
5764
0128
(` in
cro
re)
Serv
ices
/Com
pany
Tota
l am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
BA
L
5
95.8
6
54
.52
26.8
7
BH
L
2.7
1
0
.19
0.1
0
Tota
l UA
SL
5
98.5
7
54
.71
26.9
7
Report No. 4 of 2016
- 160 -
Airtel
AN
NE
XU
RE
3.0
3 [P
ara
3.2.
1 (B
)]Im
pact
on
paym
ent o
f LF
and
SUC
due
to n
on c
onsi
dera
tion
of r
even
ue fr
om F
ree
of C
ost C
ards
/Cou
pons
/SIM
s (FO
C)
(Am
ount
in `
)
Serv
ices
/LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
-pa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C
Impa
ctA
mou
nt o
f GR
/A
GR
LF
Impa
ctSU
C Im
-pa
ct
Ass
am
--
-11
2842
6771
3893
--
-34
3945
2063
711
866
Bih
ar
--
-85
2454
5114
738
787
--
--
--
Del
hi52
0967
6452
0967
622
6620
924
2686
5224
2686
510
5325
9-
--
8133
9081
339
3538
2
Guj
arat
56
1180
9056
1180
920
4831
0-
--
--
--
--
HP
1005
8789
5029
3934
7028
2102
539
1051
2772
538
--
--
--
J& K
-
--
1239
987
7439
942
904
1542
0192
5253
20-
--
Kar
nata
ka
2529
8475
2023
878
1176
379
--
--
--
9026
3690
264
4197
3
Ker
ala
33
5858
126
8687
1192
3046
5290
937
2233
1651
7832
3099
725
8480
1147
0041
0112
732
8090
1455
90
Kol
kata
21
1107
521
1107
9077
6-
--
4212
142
1218
1158
4145
5841
425
118
Mah
aras
htra
59
2668
6959
2668
721
6324
115
6636
0015
6636
057
1721
--
-97
7185
9771
845
439
MP
1315
7250
1052
580
4802
40-
--
--
--
--
Mum
bai
2712
346
2712
3512
3412
--
--
--
--
-
Odi
sha
-
--
--
--
--
2263
279
1357
9710
1848
Punj
ab
9589
172
5753
5042
6718
--
--
--
--
-
TN75
7494
7574
928
785
--
-78
6585
978
6586
3814
9499
3048
199
3048
4816
28
UPE
3399
1915
2719
353
1189
717
--
--
--
--
-
UPW
2230
9918
1784
793
7920
02-
--
--
--
--
WB
5727
723
4582
1814
3193
--
-38
6361
330
9089
1352
2622
2669
217
8135
7793
4
TOTA
L B
AL
2965
5445
926
6920
6211
3952
4048
8929
8346
0290
219
4828
015
1567
9213
6761
963
8552
2214
2879
1983
443
9667
79
NE
--
--
--
--
-20
595
1236
690
Raj
asth
an
2010
9729
1206
584
7098
73-
--
--
-32
9240
126
3392
1498
04
TOTA
L B
HL
2010
9729
1206
584
7098
73-
--
--
-33
1299
626
4628
1504
94
TOTA
L U
ASL
3166
6418
827
8986
4612
1051
1348
8929
8346
0290
219
4828
015
1567
9213
6761
963
8552
2545
5875
2248
070
1117
273
(` in
cro
re)
Serv
ices
/Com
pany
Tota
l am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ct
BA
L
38.
28
3
.46
1
.49
BH
L
2
.34
0.1
5
0.0
9
Tota
l UA
SL
40.
62
3.6
1
1.5
8
Report No. 4 of 2016
- 161 -
Airtel
AN
NE
XU
RE
3.0
4 [P
ara
3.2.
1 (B
)]Im
pact
on
paym
ent o
f LF
and
SUC
due
to n
on c
onsi
dera
tion
of r
even
ue fr
om P
rom
otio
nal o
ffer
s to
cust
omer
s(A
mou
nt in
`)
Serv
ices
/LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Im-
pact
SUC
Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im-
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
AP
--
--
--
--
-23
5107
1323
5107
110
6973
7A
ssam
-
--
--
--
--
4345
139
2607
0814
9907
Bih
ar
--
--
--
--
-27
7015
616
6209
1260
42C
henn
ai
--
--
--
--
-18
4116
818
4117
8929
7D
elhi
--
--
--
--
-20
4821
4320
4821
489
0973
Guj
arat
-
--
--
--
--
4059
124
4059
1214
8158
Har
yana
-
--
--
--
--
1482
5211
860
5115
HP
1123
500
5617
538
761
--
-32
2821
4719
3692
911
1373
411
0161
7066
0970
3800
58J&
K
--
--
--
2711
6416
270
9355
8743
352
4630
16K
arna
taka
-
--
--
--
--
1389
1402
1389
140
6459
50K
eral
a
--
--
--
--
-63
6113
5088
922
582
Kol
kata
-
--
--
--
--
2973
665
2973
6712
7868
Mah
aras
htra
-
--
--
--
--
1157
1810
1157
181
5380
89M
P-
--
--
--
--
7571
981
6057
5827
6377
Mum
bai
2814
0028
140
1280
423
2929
923
2930
1059
83-
--
1752
150
1752
1579
723
Odi
sha
-
--
--
--
--
1673
9398
1004
364
7532
73Pu
njab
-
--
--
--
--
5181
9541
456
2306
0TN
--
--
--
--
-38
1679
5038
1679
518
5114
6U
PE11
0568
9888
4552
3869
91-
--
1679
2117
113
4336
9462
1308
319
2368
5915
3894
986
5659
UPW
1182
1608
394
5728
741
9667
139
8183
231
8547
1413
5533
1797
0326
5437
611
7787
945
8422
236
6738
1627
40W
B-
--
--
--
--
8875
771
7100
6231
0652
TOTA
L B
AL
1306
7788
110
4261
5346
3522
763
1113
155
1476
2473
3823
3654
185
1804
1269
8514
052
1947
7981
317
2482
2285
1942
1N
E-
--
--
--
--
2108
586
1265
1570
638
Raj
asth
an
2951
7926
1771
076
1041
983
6810
9104
4086
546
2417
873
6158
9237
4927
139
2371
186
2083
5907
1666
873
9480
34TO
TAL
BH
L29
5179
2617
7107
610
4198
368
1091
0440
8654
624
1787
361
5892
3749
2713
923
7118
622
9444
9317
9338
810
1867
1TO
TAL
UA
SL16
0195
807
1219
7229
5677
210
7442
0235
4638
023
2665
211
2952
4342
222
9684
0810
8852
3821
7724
306
1904
1609
9538
093
(` in
cro
re)
Serv
ices
/Com
-pa
nyTo
tal a
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
BA
L
5
6.54
4.6
3
2.1
9
BH
L
1
8.22
1.2
5
0.6
9
Tota
l UA
SL
7
4.76
5.8
8
2.8
8
Report No. 4 of 2016
- 162 -
Airtel
AN
NE
XU
RE
3.0
5 [P
ara
3.2.
1 (B
)]Im
pact
on
paym
ent o
f LF
and
SUC
due
to n
on c
onsi
dera
tion
of r
even
ue fr
om F
ull T
alk
Tim
e (F
TT
)(A
mou
nt in
`)
Serv
ices
/LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Im-
pact
SUC
Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
Am
ount
of
GR
/AG
RL
F Im
-pa
ctSU
C Im
pact
Del
hi-
--
--
--
--
3790
0537
901
1648
7
J& K
-
--
--
-12
0079
6372
0478
4142
7528
3629
317
0178
9785
2
Mah
aras
htra
-
--
--
--
--
1932
1901
1932
190
8984
68
Mum
bai
6521
510
6521
5129
6729
(661
9204
9)-
--
--
--
-
UP
(E)
2152
4873
1721
990
7533
7154
2496
9043
3997
518
9873
9-
--
--
-
UP
(W)
5437
102
4349
6819
3017
2442
8699
1954
296
8672
19-
--
--
-
TOTA
L B
AL
3348
3485
2809
109
1243
116
1248
6340
6294
271
2765
958
1200
7963
7204
7841
4275
2253
7199
2140
268
1012
807
Raj
asth
an
2577
3263
1546
396
9097
96-
--
--
--
--
TOTA
L B
HL
2577
3263
1546
396
9097
96-
--
--
--
--
TOTA
L U
ASL
5925
6748
4355
505
2152
913
1248
6340
6294
271
2765
958
1200
7963
7204
7841
4275
2253
7199
2140
268
1012
807
(` in
cro
re)
Serv
ices
/Com
pany
Tota
l am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im-
pact
BA
L
8.0
5
1.2
0
0.5
4
BH
L
2.5
8
0.1
5
0.0
9
Tota
l UA
SL
1
0.63
1.3
5
0.6
3
Report No. 4 of 2016
- 163 -
Airtel
AN
NE
XU
RE
3.0
6 [P
ara
3.2.
1 (B
)]Im
pact
on
paym
ent o
f LF
and
SUC
due
to n
on c
onsi
dera
tion
of r
even
ue fr
om A
djus
tmen
ts(A
mou
nt in
`)
Serv
ices
/LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
-pa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
-pa
ctA
mou
nt o
f GR
/A
GR
LF
Impa
ctSU
C Im
-pa
ctA
P-
--
--
--
--
2461
3011
224
6130
1111
1989
20A
ssam
-
--
--
-99
9070
3859
9442
234
4679
327
3511
9316
4107
294
3616
Bih
ar
1735
2703
110
4116
2275
1372
016
0309
662
9618
580
7294
090
--
-56
0311
633
6187
2549
42C
henn
ai
1778
0547
1778
055
7823
4484
2598
7884
2598
841
7086
411
5643
271
1156
4327
5608
699
3265
3669
3265
367
1583
703
Del
hi-
--
--
--
--
4601
549
4601
5520
0167
Guj
arat
-
--
--
--
--
4337
464
4337
4615
8317
Har
yana
-
--
--
-79
4656
6357
327
416
8329
9066
639
2873
8H
P-
--
--
-27
5036
316
5022
9488
823
0761
1384
679
61J&
K
--
--
--
1224
1009
7344
6142
2315
3590
2621
542
1238
6K
arna
taka
-
--
--
-57
6318
5763
226
799
2674
131
2674
1312
4347
Ker
ala
40
3525
3232
2820
314
3251
5-
--
3325
0679
526
6005
4411
8039
9117
1456
2213
7165
060
8670
Kol
kata
-
--
--
--
--
2857
426
2857
4312
2869
Mah
aras
htra
-
--
--
--
--
8183
7601
8183
760
3805
448
MP
--
--
--
--
-97
3877
777
9102
3554
65M
umba
i -
--
--
--
--
8608
271
8608
2739
1676
Odi
sha
-
--
--
-75
7433
545
4460
3408
4553
6802
132
2081
2415
61Pu
njab
-
--
--
--
--
2478
791
1983
0311
0306
TN10
6201
044
1062
0104
4035
640
3426
9591
534
2695
9116
9634
4844
9751
402
4497
5140
2181
2943
1354
2975
713
5429
7665
6834
3U
PE86
8724
9369
4979
930
4053
7-
--
7585
6506
6068
520
2806
691
3825
7230
606
1721
6U
PW-
--
--
-37
6066
1330
0852
913
3503
511
1659
8933
3964
WB
7881
3863
051
1970
3-
--
--
-38
6570
930
9257
1353
00TO
TAL
BA
L42
5521
785
3305
0834
1682
4460
5872
6545
552
3141
5928
4284
0111
3520
8307
9968
6629
4772
6413
5925
9821
657
0122
1526
8739
18N
E-
--
--
-62
8094
9237
6857
016
6445
221
9847
8313
1908
773
6490
Raj
asth
an
--
--
--
--
-11
1354
889
084
5066
6TO
TAL
BH
L-
--
--
-62
8094
9237
6857
016
6445
223
0983
3214
0817
178
7157
TOTA
L U
ASL
4255
2178
533
0508
3416
8244
6058
7265
455
5231
4159
2842
8401
1198
0177
9910
3455
199
4939
0865
6156
9654
858
4203
8527
6610
74
(` in
cro
re)
Serv
ices
/Com
pany
Tota
l am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
BA
L
274
.06
24
.20
11
.99
BH
L
8.59
0.5
2
0.2
4
Tota
l
282
.65
24
.72
12
.23
Report No. 4 of 2016
- 164 -
Airtel
AN
NE
XU
RE
3.0
7 [P
ara
3.2.
2]Im
pact
on
paym
ent o
f LF
and
SUC
due
to n
on c
onsi
dera
tion
of r
even
ue fr
om D
isco
unts
(Am
ount
in `
)
Serv
ices
/LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Im-
pact
SUC
Im
pact
Am
ount
of
GR
/AG
RL
F Im
-pa
ctSU
C
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Im-
pact
SUC
Im
pact
AP
5055
7315
4044
585
2290
246
2461
0145
1968
812
1119
762
3224
9923
3224
992
1467
372
6403
5941
464
0359
4129
1363
53
Bih
ar
5438
3632
630
2354
8-
--
--
--
--
Che
nnai
25
2104
509
2521
0451
1109
2598
--
--
--
--
-
Del
hi25
9175
0825
9175
111
2741
2-
--
--
-26
9889
126
9889
1174
02
Har
yana
-
--
--
--
--
4212
533
7014
53
HP
--
--
--
--
-11
9492
7170
4122
Kar
nata
ka
5328
912
4263
1324
7794
4948
611
3958
8923
0110
5035
572
5035
5723
4154
--
-
Kol
kata
56
9855
5698
624
504
--
--
--
--
-
MP
--
--
--
7715
3461
723
2816
1-
--
Odi
sha
10
788
647
432
--
-
-
-
- -
--
Punj
ab
--
--
--
2054
3516
435
9142
--
-
TN22
9026
742
2290
2674
8703
016
4087
7181
740
8771
8220
2342
0592
5868
5992
5868
644
9046
3-
--
UPW
2984
7592
2387
807
1059
590
1066
490
8531
937
860
--
--
--
TOTA
L U
ASL
(B
AL
)59
3907
057
5765
3844
2456
9140
4393
9706
343
3272
0121
6219
3713
0849
323
1306
5393
6229
291
6432
1992
364
3163
7029
2593
31
(` in
cro
re)
Serv
ices
/Com
pany
Tota
l am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
Tot
al U
ASL
(BA
L)
180
.74
17.
84
8.
17
Report No. 4 of 2016
- 165 -
Airtel
AN
NE
XU
RE
3.0
8 [P
ara
3.2.
2]Im
pact
on
paym
ent o
f LF
and
SUC
due
to n
on c
onsi
dera
tion
of r
even
ue fr
om W
aive
rs (R
even
ue)
(Am
ount
in `
)
Serv
ices
/LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f GR
/A
GR
LF
Impa
ctSU
C Im
-pa
ctA
mou
nt o
f G
R/A
GR
LF
Im-
pact
SUC
Im
pact
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Im
pact
AP
4200
559
3360
4519
0285
2121
2099
1696
968
9651
51-
--
3528
5948
435
2859
4816
0551
07A
ssam
34
6607
0020
7964
298
7830
4772
5904
2863
554
1646
544
2892
3067
1735
384
9978
4649
7776
8529
8666
117
1733
0B
ihar
34
8506
720
9104
1509
0350
4862
3029
222
971
2998
562
1799
1413
6435
3123
0957
1873
857
1421
009
Che
nnai
31
200
3120
1373
--
--
--
1041
6568
0110
4165
680
5052
0355
Del
hi-
--
--
-24
9966
888
2499
6689
1087
3560
1772
4306
2017
7243
062
7710
0732
Guj
arat
45
5045
516
6-
--
--
-27
1132
115
2711
3212
9896
322
Har
yana
17
0702
6213
6562
159
4045
6144
388
4915
5121
1981
9290
390
7432
3132
0518
1284
3729
910
2749
8444
3108
7H
P14
6776
2173
3881
5063
7810
1298
2050
6491
3494
7940
9888
124
5933
1414
1139
2027
7823
5216
713
5249
6J&
K
2222
8966
1333
738
7335
5610
5108
9363
0654
3636
7710
6665
0863
9990
3679
9553
9805
0232
3883
018
6232
7K
arna
taka
21
0944
863
1687
5589
9808
936
1735
4453
313
8835
6380
6982
112
1831
447
1218
3145
5665
162
9340
6530
593
4065
3143
4340
37K
eral
a
--
--
--
--
-16
0584
865
1284
6789
5700
763
Kol
kata
-
--
--
-12
6676
712
6677
5447
119
2895
303
1928
9530
8294
498
Mah
aras
htra
32
7848
3278
511
966
--
-17
3481
1734
870
2624
3202
520
2432
0252
1130
8917
MP
3793
303
138
1396
6578
1117
326
5097
8014
9588
9911
9671
254
6000
1034
2820
782
7425
737
7513
0M
umba
i -
--
--
-20
5132
2051
393
3432
0184
617
3201
8462
1456
8400
Odi
sha
42
9145
7725
7487
517
1658
361
0356
9536
6214
227
4660
670
5097
9542
3058
831
7294
167
5694
6140
5416
830
4062
6Pu
njab
11
7600
062
7056
004
5233
203
7729
4267
4637
656
3439
595
2593
7779
2075
022
1154
231
4792
7921
738
3423
3721
3279
25U
PE-
--
--
-63
9968
151
1974
2367
8815
3849
304
1230
7944
6923
219
UPW
--
--
--
2083
123
1666
5073
951
1190
2989
895
2239
242
2556
1W
B-
--
--
-60
9723
4877
821
340
3968
3054
3174
644
1388
907
TOTA
L B
AL
4681
5006
832
6011
6119
9353
6342
2069
039
2952
0196
1832
5605
5499
2012
349
1185
4823
7790
0865
5447
9992
6220
9170
728
8344
746
NE
1451
5648
8709
3934
1118
2290
0586
1374
035
5381
6414
7837
2888
7024
3917
6928
9434
0117
3660
496
9604
Raj
asth
an
5165
2588
3099
155
1823
336
4294
7423
2576
845
1524
634
3397
5761
2718
061
1308
067
2168
4670
717
3477
3798
6652
5TO
TAL
BH
L66
1682
3639
7009
421
6445
465
8480
0939
5088
120
6279
748
7594
8936
0508
516
9983
624
5790
108
1908
4341
1083
6129
TOTA
L U
ASL
5343
1830
436
5712
5522
0998
1748
7917
048
3347
1077
2038
8402
5986
7961
252
7236
3225
4788
4468
0027
0100
6411
7604
829
9180
875
(` in
cro
re)
Serv
ices
/Com
-pa
nyTo
tal a
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
BA
L
7
99.4
6
7
3.33
3
5.04
BH
L
42.6
6
3.0
6
1.67
Tota
l UA
SL
8
42.1
2
7
6.39
3
6.71
Report No. 4 of 2016
- 166 -
Airtel
AN
NE
XU
RE
3.0
9 [P
ara
3.2.
2]Im
pact
on
paym
ent o
f LF
and
SUC
due
to n
on c
onsi
dera
tion
of r
even
ue fr
om W
aive
rs (E
xpen
ditu
re)
(Am
ount
in `
)
Serv
ices
/LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im-
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
AP
4780
964
3824
7721
6578
8507
484
6805
9938
7091
5453
968
5453
9724
8156
1098
7878
1098
788
4999
48A
ssam
43
6698
126
2019
1244
5937
8309
522
6986
1305
1723
4851
214
0911
8102
455
5698
3334
219
172
Bih
ar
5597
6133
586
2423
820
4834
812
2901
9320
014
7490
8849
6711
7941
347
6536
13C
henn
ai
3252
6968
3252
697
1431
187
4133
0406
4133
041
2045
855
1952
5319
1952
532
9469
7815
4184
2415
4184
274
7794
Del
hi12
1559
368
1215
5937
5287
832
6537
0911
6537
091
2837
098
9033
0770
9033
077
3929
389
1255
3292
212
5532
9254
6068
2G
ujar
at
8139
171
8139
1729
7080
1551
067
1551
0756
614
1258
222
1258
2245
925
1541
141
1541
1456
252
Har
yana
37
2454
029
7963
1296
1431
9943
125
5954
1103
8028
7331
822
9865
9912
911
6458
893
167
4017
8H
P11
1407
055
704
3843
541
1499
2057
514
197
1406
3684
3848
5226
023
1561
898
J& K
-
--
2268
613
6178
592
1055
331
812
078
725
417
Kar
nata
ka
1613
6110
1290
889
7503
2939
4999
5631
5999
618
3674
831
1515
2331
1515
214
4854
628
9945
6928
9945
713
4824
7K
eral
a
2650
081
2120
0694
078
4947
710
3958
1717
5644
9482
808
7586
2533
6640
5408
258
4326
6119
1993
Kol
kata
53
3119
553
3120
2292
4127
3097
427
3097
1174
3255
3226
055
3226
2378
8794
7784
394
7784
4075
47M
ahar
asht
ra
1429
9465
1429
947
5219
3010
0905
6110
0905
636
8305
1083
5714
1083
571
4388
4694
8668
9486
744
113
MP
6365
7427
5092
594
2323
496
4946
6304
3957
304
1805
520
4729
4029
3783
522
1726
232
2477
2619
1981
810
9042
01M
umba
i 59
8478
759
8479
2723
0887
9671
087
9671
4002
5011
0072
5611
0072
650
0830
2623
9309
2623
931
1193
889
Odi
sha
54
075
3245
2163
2026
8712
161
9121
2856
3517
138
1285
427
5166
1651
012
382
Punj
ab
3257
9029
1954
742
1449
767
8816
414
5289
8539
2330
8888
488
7110
7939
5538
5099
935
4079
9522
6947
UPE
6228
941
4983
1521
8013
5062
641
4050
1117
7192
3564
203
2851
3613
1876
2719
452
2175
5612
2375
UPW
2701
528
2161
2295
904
2534
907
2027
9389
989
1622
732
1298
1957
607
1998
317
1598
6570
940
WB
3408
6927
269
8522
727
5820
1128
4990
2839
5026
5916
2127
393
07TO
TAL
BA
L32
6735
329
2911
1026
1351
5174
2583
7451
922
9575
6411
0482
8825
1864
942
2359
2466
1065
3286
2615
1822
025
2853
0511
3608
96N
E15
5575
393
345
3656
024
6553
114
7932
5794
014
5556
587
334
3857
223
6931
1421
679
37R
ajas
than
77
8942
546
7366
2749
6713
0814
378
489
4643
970
7417
956
5934
2723
5689
5999
271
6799
4076
80TO
TAL
BH
L93
4517
856
0711
3115
2737
7367
422
6420
1043
7985
2974
465
3268
3109
2891
9692
373
1015
4156
17TO
TAL
UA
SL33
6080
507
2967
1737
1382
6701
2621
4819
323
1839
8511
1526
6726
0394
686
2424
5735
1096
4214
2707
1514
226
0163
2011
7765
13(`
in c
rore
)
Serv
ices
/Com
pany
Tota
l am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ct
BA
L
10
9.85
1
0.09
4.
66
BH
L
3.0
8
0.2
2
0.
11
Tota
l UA
SL
11
2.93
1
0.31
4.
77
Report No. 4 of 2016
- 167 -
Airtel
AN
NE
XU
RE
3.1
0 [P
ara
3.2.
3]Im
pact
on
paym
ent o
f LF
and
SUC
due
to n
on c
onsi
dera
tion
of r
even
ue fr
om In
ter
Ope
rato
r Tra
ffic
(IO
T) d
isco
unts
to o
ther
Ope
rato
rs(A
mou
nt in
`)
Serv
ices
/LSA
FY 2
006-
07FY
200
7-08
FY 2
008-
09FY
200
9-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im-
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
AP
1335
3110
1068
249
6048
9628
4125
0022
7300
012
9276
949
7896
6549
7896
722
6543
043
7784
243
7784
1991
92B
ihar
21
3512
912
8108
9245
132
9851
019
7911
1500
8262
4752
937
4852
2842
6369
1703
4150
231
472
Che
nnai
19
5766
0319
5766
086
1371
3416
8255
3416
826
1691
329
4832
2167
4832
217
2343
625
8251
505
8251
5140
0198
Del
hi79
3339
1579
3339
234
5102
580
9844
9880
9845
035
1472
733
4934
899
3349
3490
1456
9668
2290
5909
2290
591
9964
07G
ujar
at
3808
764
3808
7613
9020
1171
5822
1171
582
4276
2821
3531
2921
3531
377
9389
-
-
-
Har
yana
78
3391
6267
127
262
1667
210
1333
7757
519
3189
143
2551
3111
0025
1041
878
8335
035
945
HP
8644
0143
220
2982
216
0131
480
066
5524
523
5290
814
1174
8117
518
7655
711
2593
6474
1J&
K
4096
246
135
--
--
--
--
-K
arna
taka
54
8790
2943
9032
225
5187
581
9662
7465
5730
238
1143
293
9029
8693
9029
943
6648
973
4405
673
4406
3414
99K
eral
a
6873
415
5498
7324
4006
1128
1757
9025
4140
0502
1999
7281
1599
782
7099
03-
--
Kol
kata
75
1427
575
1428
3231
1410
0181
3610
0181
443
0780
1789
8480
1789
848
7696
3518
8897
218
8897
8122
6M
ahar
asht
ra
2076
0067
2076
007
7577
4218
5008
3718
5008
467
5281
5511
1716
5511
172
2232
024
3890
648
3890
6518
0915
MP
2067
891
1654
3175
478
5145
918
4116
7318
7826
8617
496
6894
0031
4539
1463
085
1170
4753
403
Mum
bai
6122
1389
6122
139
2785
573
6131
4013
6131
401
2789
788
1210
4538
912
1045
3955
0756
5-
--
Odi
sha
11
1073
066
644
4442
910
8117
364
870
4865
346
8499
728
1100
2108
2580
2613
4815
736
118
Punj
ab
3751
177
2250
7116
6927
8913
472
5348
0839
6650
1099
8595
8798
8848
9437
5543
841
4435
0724
6701
TN64
5287
664
5288
2452
0910
7125
4810
7125
553
0271
3633
1121
3633
112
1762
059
4354
690
4354
6921
1202
UPE
2027
531
1622
0270
964
3629
319
2903
4612
7026
5878
127
4702
5021
7491
1358
634
1086
9161
139
UPW
3403
082
2722
4712
0809
5158
467
4126
7718
3126
1175
4371
9403
5041
7280
3097
783
2478
2310
9971
WB
1181
815
9454
529
545
1731
089
1384
8746
739
3800
587
3040
4713
3021
1879
4215
035
6578
TOTA
L B
AL
2911
0268
627
0956
1812
6216
5538
1301
112
3473
8469
1681
7371
8562
1058
683
8049
2937
5638
4469
0776
5865
1906
830
5670
6R
ajas
than
12
2348
6973
4092
4318
9117
5053
3410
5032
062
1439
2486
5450
1989
236
9573
2035
6436
228
5149
1621
78TO
TAL
BH
L12
2348
6973
4092
4318
9117
5053
3410
5032
062
1439
2486
5450
1989
236
9573
2035
6436
228
5149
1621
78TO
TAL
UA
SL59
4440
241
5492
5328
2567
5200
7801
0755
870
5272
5734
2561
8117
3728
6622
1695
9909
476
0850
0814
1719
678
1332
3284
6275
591
(`
in c
rore
)
Serv
ices
/Com
-pa
nyTo
tal a
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nt o
f G
R/A
GR
LF
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ctSU
C Im
pact
BA
L
15
9.77
1
5.21
7
.00
BH
L
5.8
2
0.4
1
0.2
2
Tota
l UA
SL
16
5.59
1
5.62
7.2
2
Report No. 4 of 2016
- 168 -
Airtel
AN
NE
XU
RE
3.1
1 [P
ara
3.2.
4]Im
pact
on
paym
ent o
f LF
and
SUC
due
to n
on c
onsi
dera
tion
of r
even
ue fr
om in
fras
truc
ture
shar
ing
from
oth
er te
leco
m o
pera
tors (A
mou
nt in
`)
Serv
ices
/LSA
FY 2
006-
07FY
200
7-08
FY 2
008-
09FY
200
9-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
Ass
am
--
-27
0081
016
2049
9317
823
1108
1386
679
73-
--
Che
nnai
21
0309
7421
0309
792
5363
4253
1416
4253
142
2105
305
--
--
--
Del
hi-
--
9412
3769
9412
377
4084
972
3455
585
3455
5915
0318
5963
669
5963
6725
9420
Guj
arat
53
0244
8753
0244
919
3539
411
5125
272
1151
2527
4202
072
1225
4766
1225
477
4472
99-
--
Har
yana
39
0385
5631
2308
413
5854
295
3722
7476
2978
232
9034
3-
--
--
-H
P11
1688
855
844
3853
312
1602
2760
8011
4195
2880
153
4809
2765
--
-J&
K
--
-59
6765
935
8060
2064
81-
--
--
-K
arna
taka
-
--
1862
3791
214
8990
3386
6006
322
6009
3722
6009
410
5094
4-
--
Ker
ala
44
6980
6535
7584
515
8678
112
3937
478
9914
998
4399
780
1798
4410
1438
753
6384
4713
2373
1059
046
99K
olka
ta
4178
8691
4178
869
1796
914
3390
3519
3390
352
1457
851
2195
7066
2195
707
9441
5477
4808
077
4808
3331
67M
ahar
asht
ra
--
-25
3789
979
2537
8998
9263
334
--
--
--
Mum
bai
--
--
--
7022
291
7022
2931
9514
3185
357
3185
3614
4934
Odi
sha
10
1745
261
047
4069
814
5069
7487
0418
6528
14-
--
--
-Pu
njab
40
1308
3524
0785
017
8582
296
5252
6757
9151
642
9537
4-
--
--
-TN
1181
4895
1181
489
4489
6611
7835
305
1178
3531
5832
848
--
--
--
UPE
4139
432
3311
5514
4880
1022
1611
581
7728
935
7756
419
3118
1544
971
45-
--
UPW
--
-93
3717
5774
6974
133
1469
7-
--
--
-W
B10
8928
0087
1424
2723
2080
3401
0364
2720
821
6918
3-
--
--
-To
tal B
AL
2686
9307
523
1921
5510
3342
1214
7064
5835
1280
3903
158
0253
8885
7794
3482
0194
235
6855
917
0294
7917
0030
074
2220
NE
--
-34
5310
2071
981
1513
5560
581
336
3592
452
0721
931
2433
1744
42R
ajas
than
-
--
--
--
--
3931
7238
831
4537
9117
8893
44To
tal B
HL
--
-34
5310
2071
981
1513
5560
581
336
3592
439
8379
606
3176
6224
1806
3785
Tota
l UA
SL26
8693
075
2319
2155
1033
4212
1470
9911
4512
8059
750
5803
3503
8713
5040
8283
279
3604
483
4154
0908
633
4665
2518
8060
06
(` in
cro
re)
Serv
ices
/Com
pany
Tota
l am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
BA
L
184
.21
16
.11
7.
27
BH
L
40
.01
3
.19
1.
81
Tota
l UA
SL
224
.22
19
.30
9.
08
Report No. 4 of 2016
- 169 -
AirtelA
NN
EX
UR
E 3
.12
[Par
a 3.
2.5]
Impa
ct o
n pa
ymen
t of R
even
ue S
hare
(LF
and
SUC
) on
Fore
x ga
in n
ot c
onsi
dere
d by
BA
L/B
HL
(Am
ount
in `
)Se
rvic
es/L
SAFY
200
6-07
FY 2
007-
08FY
200
8-09
FY 2
009-
10A
mou
nt o
f GR
/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f GR
/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ct
AP
5087
038
4069
6323
0443
1029
1882
3346
8367
4296
0567
4296
130
6804
779
8627
4079
8627
436
3375
5A
ssam
6564
4739
387
1870
923
11
9462
971
5677
7832
6472
1301
0958
7806
5744
8878
Bih
ar21
8627
213
1176
9466
682
54
3763
5900
2258
154
1712
433
5070
0922
3042
055
2306
892
Del
hi13
5396
8913
5396
958
8976
1403
114
0360
971
0674
6571
0674
730
9143
578
3271
1978
3271
234
0723
0G
ujar
at17
3147
217
3147
6319
950
9505
5095
118
597
2423
9974
2423
997
8847
5928
9539
5428
9539
510
5681
9H
arya
na97
8270
7826
234
044
242
191
4167
473
1334
3153
8898
3935
878
7149
3394
58H
P93
9593
4698
032
416
201
170
2470
042
1482
2423
5281
4378
648
8627
2809
61J &
K89
3346
5360
129
480
332
113
4730
3180
8382
4648
2012
3494
7674
0969
4260
57K
arna
taka
8219
068
6575
2538
2187
217
1710
8204
8776
8204
878
3815
268
9133
8757
9133
876
4247
252
Ker
ala
1688
597
1350
8859
945
494
219
6811
4115
7449
169
8681
2214
5741
1771
659
7861
74K
olka
ta16
0415
116
0415
6897
851
52
1799
2920
1799
292
7736
9619
5065
0919
5065
183
8780
Mah
aras
htra
3665
559
3665
5613
3793
2291
9357
2291
936
8365
5737
6195
4837
6195
515
2359
240
9492
5640
9492
619
0414
0M
P22
8217
218
2574
8329
961
506
4920
2245
2736
6803
2189
344
9988
8831
9363
5225
5490
811
6567
7M
umba
i52
6476
852
6477
2395
4742
6138
4261
419
389
3569
2106
3569
211
1623
991
3655
9049
3655
905
1663
437
Odi
sha
1070
919
6425
542
837
372
216
3273
1597
9639
7347
2919
8031
3811
8818
889
1141
Punj
ab41
7833
925
0700
1859
3686
0694
5164
238
301
3260
5754
2608
460
1450
956
3793
2550
3034
604
1687
998
TN63
2490
463
2490
2403
4699
8793
199
8793
4944
0364
0304
7164
0304
731
0547
874
9469
5374
9469
536
3492
7U
PE17
8077
214
2462
6232
766
52
3088
8643
2471
091
1142
880
3995
8992
3196
719
1798
155
UPW
1280
527
1024
4245
459
383
114
8623
7211
8899
052
7614
1836
6415
1469
313
6520
08W
B77
5611
6204
919
390
353
115
6301
3612
5041
154
7055
2008
7138
1606
971
7030
50TO
TAL
BA
L64
1475
1355
6651
826
5597
734
8827
5634
5054
214
1481
263
4221
305
5706
1644
2704
8534
7347
1916
365
7062
5331
8727
89N
orth
Eas
t-
--
9457
985
5674
7922
2263
8493
250
9622
5170
6312
542
3787
2366
15R
ajas
than
8914
5853
487
3146
857
9065
7834
7439
520
5568
453
2309
4258
520
494
3974
3535
3179
483
1808
331
TOTA
L B
HL
8914
5853
487
3146
867
3645
6240
4187
422
7794
661
7241
4768
122
745
4680
6660
3603
270
2044
946
Tota
l UA
SL65
0389
7156
2000
526
8744
510
2247
318
7492
416
3692
758
6348
3854
757
1093
2527
0712
7978
1525
823
6930
9523
3391
7735
NL
D (i
/c IP
1)97
0687
558
2412
-19
612
-10
1568
887
6094
133
-13
1673
815
7900
429
-IL
D (i
/c B
ILG
O)
(125
2635
)-
-99
1521
3859
4912
8-
5388
7195
3233
232
-60
6183
3936
3710
0-
ISP
(i/c
BB
L)
(106
5792
7)-
-86
3116
2351
7869
7-
2510
2211
1506
133
-32
1360
719
2816
-V
SAT
(i/c
Satc
om)
2143
2712
860
-11
1951
1267
1707
-10
2197
661
319
-10
8984
365
391
-G
RA
ND
TO
TAL
7496
0173
6215
277
2687
445
2989
0638
719
2919
6036
9275
881
6418
816
6800
4142
2707
1279
9781
2142
781
1052
5933
9177
35
Not
e: N
egat
ive
figur
es n
ot c
onsi
dere
d fo
r cal
cula
tion
of G
R/A
GR
.
(`
in c
rore
)Se
rvic
es/C
ompa
nyTo
tal a
mou
nt o
f GR
/AG
RL
F Im
pact
SUC
Impa
ct
BA
L
146
.80
13.
18
6
.30
BH
L
1
1.57
0.77
0.4
4 To
tal U
ASL
1
58.3
7
1
3.95
6.7
4 N
LD
(i/c
IP1)
24.
29
1.
46
-
ILD
(i/c
BIL
GO
)
2
1.37
1.28
-
IS
P (i/
c B
BL
)
1
1.46
0.69
-
V
SAT
(i/c
Satc
om)
1.
35
0.
08
-
GR
AN
D T
OTA
L
216
.84
17.
46
6
.74
Report No. 4 of 2016
- 170 -
Airtel
AN
NE
XU
RE
3.1
3 [P
ara
3.3.
1]Im
pact
on
paym
ent o
f Rev
enue
Sha
re (L
F an
d SU
C) o
n in
tere
st in
com
e no
t con
side
red
by B
AL
& B
HL
(Am
ount
in `
)
Serv
ices
/LSA
FY 2
006-
07FY
200
7-08
FY 2
008-
09FY
200
9-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
AP
1441
7618
1153
409
6531
1856
5061
7045
2049
425
7103
112
6026
902
1260
2690
5734
224
8841
9845
8841
985
4023
103
Ass
am18
6049
411
1630
5302
475
8335
345
5001
2616
2617
6821
7910
6093
161
0035
1437
4796
8624
8849
5930
Bih
ar61
9630
537
1778
2683
0026
6938
8916
0163
312
1457
270
2627
2842
1576
431
9695
456
0059
8533
6035
925
4827
2D
elhi
2650
1919
2650
192
1152
833
7199
3623
7199
362
3124
523
1334
0086
013
3400
8658
0293
788
1592
8088
1592
838
3492
9G
ujar
at49
0731
249
0731
1791
1718
1862
8418
1862
866
3799
4526
1748
4526
175
1652
054
3201
1984
3201
198
1168
437
Har
yana
2767
344
2213
8896
304
7946
242
6356
9927
4145
1706
6655
1365
332
5888
0010
8688
9486
9512
3749
77H
P23
6237
211
8119
8150
266
4878
033
2439
2293
8313
1144
6278
6868
4524
4989
9590
653
9754
3103
59J &
K25
3190
915
1915
8355
310
6819
9664
0920
3695
9725
1948
3315
1169
086
9222
1368
4613
8210
7747
2119
Kar
nata
ka22
4620
2717
9696
210
4448
471
0009
5656
8007
633
0154
415
3199
590
1531
9959
7123
781
1011
2064
210
1120
6447
0211
0K
eral
a41
5441
333
2353
1474
8215
8822
2912
7057
856
3819
3679
3995
2943
520
1306
187
2450
1900
1960
152
8698
17K
olka
ta45
4491
845
4492
1954
3117
3251
8217
3251
874
4983
3442
6458
3442
646
1480
338
2228
1693
2228
169
9581
13M
ahar
asht
ra91
5686
491
5686
3342
2631
1249
2531
1249
311
3606
070
2321
9970
2322
028
4440
445
2339
5945
2339
621
0337
9M
P59
7580
347
8064
2181
1721
9351
7317
5481
480
0634
5124
7010
4099
761
1870
516
3606
3245
2885
060
1316
308
Mum
bai
1115
2194
1115
219
5074
2534
1039
4134
1039
415
5172
966
7804
3466
7804
330
3851
040
3933
8540
3933
918
3789
9O
dish
a30
3518
418
2111
1214
0712
0959
5072
5757
5443
1830
5080
5118
3048
313
7286
221
9290
3813
1574
298
6807
Punj
ab11
5947
6569
5686
5159
6730
8313
9818
4988
413
7199
760
8761
9448
7009
627
0899
141
9016
0133
5212
818
6462
1TN
1678
2687
1678
269
6377
4254
8279
6654
8279
727
1398
411
9538
937
1195
3894
5797
638
8294
8910
8294
891
4023
022
UPE
5047
041
4037
6317
6646
2145
2639
1716
211
7508
4257
9181
2846
3345
021
4297
144
2789
3435
4231
519
9255
2U
PW36
5056
329
2045
1295
9512
6760
3010
1408
244
9999
2729
7528
2183
802
9690
6220
2881
7516
2305
472
0230
WB
2213
755
1771
0055
344
1160
5076
9284
0631
3337
2919
7309
2335
785
1021
906
2221
0655
1776
852
7773
73TO
TAL
BA
L16
1315
487
1379
0912
6651
617
5411
0180
245
8821
8622
9519
2211
8602
6200
1067
2419
550
5838
4181
5673
440
7296
5463
3538
0357
NE
--
--
--
--
-33
0143
719
8086
1105
98R
ajas
than
--
-63
0152
037
8091
2237
0412
3198
7098
5590
4743
1536
2992
8329
0394
316
5161
7TO
TAL
BH
L-
--
6301
520
3780
9122
3704
1231
9870
9855
9047
4315
3960
0720
3102
029
1762
216
TOTA
L U
ASL
1613
1548
713
7909
1266
5161
754
7403
322
4626
0277
2317
5626
1198
3460
7010
7709
785
5105
8156
8552
7416
076
0674
9237
1425
73N
LD
(i/c
IP1)
2498
8611
1499
317
-64
8209
6938
8925
8-
1903
0311
311
4181
87-
1459
1847
987
5510
9-
ILD
(i/c
BIL
GO
)17
7817
5410
6690
5-
5175
1056
3105
063
-10
5215
478
6312
929
-70
4908
2242
2944
9-
ISP
7623
545
74-
1850
825
1110
50-
5685
287
3411
17-
3745
035
2247
02-
VSA
T (i/
c Sa
tcom
)51
3916
3083
5-
9689
5958
138
-19
0793
411
4476
-12
0387
872
233
-G
RA
ND
TO
TAL
2046
7600
316
3925
4366
5161
766
6795
131
5342
3786
2317
5626
1501
4578
8212
5896
494
5105
8156
1076
6323
7489
3489
8537
1425
73
(` in
cro
re)
Serv
ices
/Com
pany
Tota
l am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
BA
L
2
70.4
1
23.9
4
1
1.55
B
HL
5
.82
0
.45
0.
25
Tota
l UA
SL
2
76.2
3
24.3
8
1
1.80
N
LD
(i/c
IP1)
42
.60
2
.56
-
ILD
(i/c
BIL
GO
)
24.5
2
1.4
7
-
IS
P (i/
c B
BL
)
1.1
4
0.0
7
-
V
SAT
(i/c
Satc
om)
0
.46
0
.03
-
GR
AN
D T
OTA
L 34
4.95
334
4.95
5
28.5
1
1
1.80
Report No. 4 of 2016
- 171 -
Airtel
AN
NE
XU
RE
3.1
4 [P
ara
3.3.
3]Im
pact
on
paym
ent o
f Rev
enue
Sha
re (L
F an
d SU
C) o
n in
com
e fr
om In
vest
men
t not
con
side
red
by B
AL
(
Am
ount
in `
)
Serv
ices
/LSA
FY 2
006-
07FY
200
7-08
FY 2
008-
09FY
200
9-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
-pa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C
Impa
ctA
P24
3260
9119
4608
711
0197
246
5205
9237
2164
721
1668
720
0161
236
2001
6124
9107
336
1576
2806
315
7628
0671
7207
7A
ssam
3139
114
1883
4789
465
6722
449
4033
4723
1924
2809
0332
1685
420
9691
1625
6802
1215
4081
388
5967
Bih
ar10
4547
0062
7282
4526
8923
7117
1914
2270
310
7888
311
1720
192
6703
212
5083
269
1000
7029
860
0421
845
5319
9D
elhi
4471
5300
4471
530
1945
116
6298
9965
6298
997
2733
764
2109
6003
321
0960
0391
7676
115
4597
151
1545
9715
6724
976
Guj
arat
8279
850
8279
8530
2215
1615
4561
1615
456
5896
4171
9550
8871
9550
926
2636
157
1474
9657
1475
020
8588
4H
arya
na46
6919
537
3536
1624
8870
5320
156
4256
2433
3527
1365
7821
7092
693
6212
1942
0308
1553
625
6700
01H
P39
8590
719
9295
1375
1459
0599
629
5300
2037
5720
8524
5212
5114
771
9410
1607
3693
9644
2255
4542
J & K
4271
957
2563
1714
0975
9450
969
5670
5832
7004
3999
3984
2399
639
1379
792
2437
4620
1462
477
8409
24K
arna
taka
3789
9003
3031
920
1762
304
6303
3830
5042
706
2931
073
2435
5747
824
3557
4811
3254
2318
0278
705
1802
7871
8382
960
Ker
ala
7009
523
5607
6224
8838
1410
7909
1128
633
5008
3158
4224
3346
7379
520
7399
643
7098
7434
9679
015
5170
1K
olka
ta76
6840
376
6840
3297
4114
6709
0514
6709
163
0849
5341
1036
5341
104
2296
675
3850
0724
3850
072
1655
531
Mah
aras
htra
1544
9897
1544
990
5639
2127
6477
3127
6477
310
0914
211
1671
651
1116
7165
4522
702
8082
3072
8082
307
3758
273
MP
1008
2659
8066
1336
8017
1880
8848
1504
708
6865
2381
2369
1564
9895
329
6514
763
0339
6650
4271
723
0074
0M
umba
i18
8165
1318
8165
185
6151
3011
6416
3011
642
1370
297
1059
5013
910
5950
1448
2073
172
1579
5772
1579
632
8318
7O
dish
a51
2110
730
7266
2048
4410
6721
9764
0332
4802
4948
4667
7729
0800
721
8100
539
0861
9123
4517
117
5887
9Pu
njab
1956
3239
1173
794
8705
6427
3431
5516
4058
912
1677
096
7884
6777
4307
743
0708
774
8688
8759
8951
133
3166
5TN
2831
6549
2831
655
1076
029
4870
2732
4870
273
2410
785
1900
7108
719
0071
0992
1844
814
7925
592
1479
2559
7174
391
UPE
8515
608
6812
4929
8046
1905
6008
1524
481
6669
6091
6913
1273
3530
533
9257
978
8685
5063
0948
435
4908
5U
PW61
5940
449
2752
2186
5911
0613
3788
4907
3926
7743
3767
6634
7014
115
3987
536
2504
7729
0003
812
8689
2W
B37
3515
429
8812
9337
910
2228
2181
7826
2760
1646
3972
3737
1177
916
2390
339
6467
3231
7173
913
8763
6TO
TAL
UA
SL (B
AL
)27
2179
173
2326
8683
1122
2927
4739
5334
140
1867
2520
0971
6718
8191
1193
1693
2517
780
2658
2814
5014
2568
1296
8688
162
9085
10N
LD
(i/c
IP1)
3823
3480
2294
009
-56
7316
8234
0390
1-
3015
0190
118
0901
14-
2598
8951
115
5933
71-
ILD
(i/c
BIL
GO
)30
0022
2318
0013
3-
4442
4800
2665
488
-15
9961
306
9597
678
-11
9644
673
7178
680
-IS
P12
8628
7718
-15
3451
792
071
-84
3199
750
5920
-63
4281
638
0569
-V
SAT
(i/c
Satc
om)
8671
0352
026
-86
0710
5164
3-
3033
682
1820
21-
2151
064
1290
64-
GR
AN
D T
OTA
L34
1410
607
2742
2569
1122
2927
5775
0505
046
3998
2820
0971
6723
5484
0079
1977
0091
080
2658
2818
3817
0632
1529
6856
562
9085
10
(` in
cro
re)
Serv
ices
/Com
pany
Tota
l am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
Tota
l UA
SL
407
.82
36.2
5
17.4
5 N
LD
(i/c
IP1)
65.
64
3.9
4
-
ILD
(i/c
BIL
GO
)
3
5.40
2
.12
-
IS
P (i/
c B
BL
)
1.64
0
.10
-
V
SAT
(i/c
Satc
om)
0.
69
0.0
4
-
GR
AN
D T
OTA
L
511
.19
42.4
5
17.4
5
Report No. 4 of 2016
- 172 -
Airtel
AN
NE
XU
RE
3.1
5[Pa
ra3.
3.4]
Bha
rti A
irte
l Ltd
, its
subs
idia
ries
and
shar
e ho
ldin
g pa
tter
n(`
in c
rore
)
Sl. N
o.N
ame
of th
e co
mpa
nyC
ount
ry o
f in
corp
.Pr
inci
pal s
ervi
ceR
elat
ion
ship
Sh
are
hold
ing
Profi
t aft
er ta
xPr
opos
ed
divi
dend
1B
harti
Hex
acom
Lim
ited
Indi
aC
ellu
lar M
obile
& B
B a
nd T
elep
hone
Ser
vice
sSu
bsid
iary
2006
-07
68.8
9%
1
53.1
0 N
il
2007
-08
68.8
9%
3
30.6
7 N
il
2008
-09
70%
545
.51
Nil
2009
-10
70%
624
.34
Nil
Tota
l pro
fit
1
,653
.62
2B
harti
Acq
ua n
et L
td (
Mer
ged
with
B
AL
w.e.
f. 01
.1.0
9)In
dia
Subm
arin
e ca
ble
land
ing
stat
ion
Subs
idia
ry
2006
-07
51%
1.20
N
il
2007
-08
100%
3.00
N
il
2008
-09
100%
-
Nil
2009
-10
-
- N
il
Tota
l pro
fit
4.20
3Sa
tcom
Bro
adba
nd E
qpt.
Ltd
Indi
aEn
terp
rise
Serv
ice
Cor
pora
te a
nd V
SAT
eqp
t tra
ding
Subs
idia
ry
2006
-07
100%
2.74
N
il
2007
-08
-
- N
il
2008
-09
-
- N
il
2009
-10
-
- N
il
Tota
l pro
fit
2.74
4B
harti
Com
tel
Ltd/
Bha
rti A
irtel
Ser
-vi
ces L
tdIn
dia
Adm
inis
trativ
e su
ppor
t to
Bha
rti A
irtel
and
VSA
T
eqpt
trad
ing
Subs
idia
ry
2006
-07
100%
(11
.86)
Nil
2007
-08
100%
-
Nil
2008
-09
100%
-
Nil
2009
-10
100%
-
Nil
Tota
l pro
fit
(11
.86)
5B
harti
Bro
adba
nd L
tdIn
dia
Ente
rpris
e Se
rvic
es C
orpo
rate
Subs
idia
ry
2006
-07
100%
(2
.88)
Nil
2007
-08
-
- N
il
2008
-09
-
- N
il
2009
-10
-
- N
il
Tota
l pro
fit
(2
.88)
6B
harti
Inf
rate
l Lt
dIn
dia
Pass
ive
infr
astru
ctur
e fo
r mob
ile se
rvic
esSu
bsid
iary
2006
-07
100%
(0
.01)
Nil
2007
-08
92.8
9%
41.
86
Nil
2008
-09
92.5
1%
2
96.3
4 N
il
2009
-10
86.0
9%
2
05.5
0 N
il
Report No. 4 of 2016
- 173 -
Airtel
Sl. N
o.N
ame
of th
e co
mpa
nyC
ount
ry o
f in
corp
.Pr
inci
pal s
ervi
ceR
elat
ion
ship
Sh
are
hold
ing
Profi
t aft
er ta
xPr
opos
ed
divi
dend
Tota
l pro
fit
543
.69
7B
harti
Tel
emed
ia L
tdIn
dia
DTH
Ser
vice
sSu
bsid
iary
2006
-07
100%
(0
.10)
Nil
2007
-08
40%
(23
.81)
Nil
2008
-09
40%
(223
.70)
Nil
2009
-10
95%
(467
.24)
Nil
Tota
l pro
fit
(714
.84)
8B
harti
Airt
el (U
K) L
tdU
KIn
tern
atio
nal c
allin
g se
rvic
es a
nd w
hole
sale
switc
hing
da
ta p
rodu
cts
Subs
idia
ry
2006
-07
100%
(1
.65)
Nil
2007
-08
100%
(1
.91)
Nil
2008
-09
100%
(1
.72)
Nil
2009
-10
100%
5.88
N
il
Tota
l pro
fit
0.60
9B
harti
Airt
el (C
anad
a) L
tdC
anad
aIn
tern
atio
nal c
allin
g se
rvic
es a
nd w
hole
sale
sw
itchi
ng
data
pro
duct
sSu
bsid
iary
2006
-07
100%
(0
.19)
Nil
2007
-08
100
(0
.12)
Nil
2008
-09
100
(2
.19)
Nil
2009
-10
100
(1
.28)
Nil
Tota
l pro
fit
(3
.78)
10B
harti
Airt
el (U
SA) L
tdU
SAIn
tern
atio
nal c
allin
g se
rvic
es a
nd w
hole
sale
sw
itchi
ng
data
pro
duct
sSu
bsid
iary
2006
-07
100%
(22
.70)
Nil
2007
-08
100
(31
.96)
Nil
2008
-09
100
(22
.80)
Nil
2009
-10
100
0.78
N
il
Tota
l pro
fit
(76
.67)
11B
harti
Airt
el (H
ongk
ong)
Ltd
Hon
g K
ong
Inte
rnat
iona
l cal
ling
serv
ices
and
who
lesa
le s
witc
hing
da
ta p
rodu
cts
Subs
idia
ry
2006
-07
100%
(0
.73)
Nil
2007
-08
100
(0
.80)
Nil
2008
-09
100
(1
.38)
Nil
2009
-10
100
(1
.01)
Nil
Tota
l pro
fit
(3
.91)
12N
etw
ork
I2i L
td (F
rom
200
7-08
)M
aurit
ius
Subm
arin
e ca
ble
syst
emSu
bsid
iary
2006
-07
- N
il
2007
-08
100
2
9.09
N
il
2008
-09
100
(58
.54)
Nil
2009
-10
100
3
2.37
N
il
Tota
l pro
fit
2.92
Report No. 4 of 2016
- 174 -
Airtel
Sl. N
o.N
ame
of th
e co
mpa
nyC
ount
ry o
f in
corp
.Pr
inci
pal s
ervi
ceR
elat
ion
ship
Sh
are
hold
ing
Profi
t aft
er ta
xPr
opos
ed
divi
dend
13B
harti
Airt
el S
ervi
ces L
td (F
rom
200
7-08
)In
dia
Man
pow
er su
ppor
t to
Bha
rti A
irtel
and
VSA
T eq
pt
tradi
ngSu
bsid
iary
2006
-07
- N
il
2007
-08
100
1
1.02
N
il
2008
-09
100
(3
.61)
Nil
2009
-10
100
1
5.17
N
il
Tota
l pro
fit
2
2.59
14B
harti
Airt
el (S
inga
pore
) Pte
Ltd
(Fro
m
2007
-08)
Sing
apor
eIn
tern
atio
nal c
allin
g se
rvic
es a
nd w
hole
sale
sw
itchi
ng
data
pro
duct
sSu
bsid
iary
2006
-07
- N
il
2007
-08
100
(1
.17)
Nil
2008
-09
100
(0
.25)
Nil
2009
-10
-
9.
64
Nil
Tota
l pro
fit
8.22
15B
harti
Airt
el L
anka
(Pvt
) Ltd
(Fro
m
2007
-08)
Sri L
anka
Mob
ile
Subs
idia
ry
2006
-07
-
- N
il
serv
ices
2007
-08
100
(10
.37)
Nil
20
08-0
910
0
(1
61.0
6)N
il
20
09-1
010
0
(3
08.5
7)N
il
Tota
l pro
fit
(480
.00)
16B
harti
Airt
el H
oldi
ngs (
Sing
apor
e) P
vt
Ltd
(Fro
m 2
007-
08)
Sing
apor
eIn
vest
men
tsSu
bsid
iary
2006
-07
-
- N
il
2007
-08
100
(0
.03)
Nil
2008
-09
100
5.06
N
il
2009
-10
100
(56
.99)
Nil
Tota
l pro
fit
(51
.96)
17B
harti
Inf
rate
l Ven
ture
Ltd
(Fro
m 2
007-
08)
Indi
aPa
ssiv
e in
fras
truct
ure
serv
ices
Subs
idia
ry
2006
-07
-
- N
il
2007
-08
100%
(0
.03)
Nil
2008
-09
100%
(0
.03)
Nil
2009
-10
100%
(0
.03)
Nil
Tota
l pro
fit
(0
.10)
18B
harti
Inf
rate
l (La
nka)
Pvt
. Ltd
(Fro
m
2007
-08)
Sri L
anka
Mob
ile se
rvic
esSu
bsid
iary
2006
-07
-
- N
il
2007
-08
100
-
Nil
2008
-09
100
-
Nil
2009
-10
100%
(308
.57)
Nil
Tota
l pro
fit
(308
.57)
Report No. 4 of 2016
- 175 -
Airtel
Sl. N
o.N
ame
of th
e co
mpa
nyC
ount
ry o
f in
corp
.Pr
inci
pal s
ervi
ceR
elat
ion
ship
Sh
are
hold
ing
Profi
t aft
er ta
xPr
opos
ed
divi
dend
19W
arad
Tel
ecom
Inte
rnat
iona
l Ltd
(Fro
m
2009
-10)
Ban
glad
esh
Mob
ile se
rvic
esSu
bsid
iary
2006
-07
-
- N
il
2007
-08
-
- N
il
2008
-09
-
- N
il
2009
-10
70%
(23
.14)
Nil
Tota
l pro
fit
(23
.14)
20B
harti
Inte
rnat
iona
l (Si
ngap
ore)
Pvt
Ltd
(F
rom
200
9-10
)Si
ngap
ore
Inve
stm
ents
Subs
idia
ry
2006
-07
-
- N
il
2007
-08
-
- N
il
2008
-09
-
- N
il
2009
-10
100
(51
.10)
Nil
Tota
l pro
fit
(51
.10)
21B
harti
Airt
el In
tern
atio
nal (
Net
herla
nds)
B
.V. (
From
200
9-10
)N
ethe
rland
Su
bsid
iary
2006
-07
-
- N
il
2007
-08
-
- N
il
2008
-09
-
- N
il
2009
-10
100
-
Nil
Tota
l pro
fit
-
22In
dus T
ower
s (Fr
om 2
007-
08)
Join
t ven
ture
2006
-07
0
- N
il
2007
-08
42%
-
Nil
2008
-09
42%
-
Nil
2009
-10
42%
-
Nil
Tota
l pro
fit
-
Report No. 4 of 2016
- 176 -
Airtel
ANNEXURE 3.16 [Para 3.3.4]Particulars of investment of BAL in its subsidiary/JV/Associates
(` in crore)
Investments by BAL 2006-07 2007-08 2008-09 2009-10
In subsidiaries 572.87 9365.20 9706.94 11137.80
In Joint Venture and others 7.37 14.23 15.70 15.71
Total investments 580.24 9379.43 9722.64 11153.51
Source: - Annual Reports of BAL for the respective years
ANNEXURE 3.17 [Para 3.3.4]Summary of Bharti Airtel Ltd’s statements under Section 212(8) of the Companies Act, 1956 relating to
Subsidiary companies contained in the respective Annual Reports
(` in crores)
YearTotal No. of subsidiaries
No. of profit making
subsidiaries
Capital invested in profit making subsidiaries
Profit after Tax / (Loss)
Proposed Dividend
2006-07 11 3 269.06 157.04 Nil
2007-08 14 5 280.32 415.64 Nil
2008-09 14 4 962.10 905.44 Nil
2009-10 17 7 943.75 893.68 Nil
Total 2455.23 2371.80
Source: - Annual Reports of BAL for the respective years
Report No. 4 of 2016
- 177 -
AirtelA
NN
EX
UR
E 3
.18
[Par
a 3.
3.8)
}Im
pact
on
paym
ent o
f Rev
enue
Sha
re (L
F an
d SU
C) o
n M
isce
llane
ous i
ncom
e no
t con
side
red
by B
AL
(Am
ount
in `
)
Serv
ices
/LSA
FY 2
006-
07FY
200
7-08
FY 2
008-
09FY
200
9-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im-
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im-
pact
Am
ount
of
GR
/AG
RL
F Im
-pa
ctSU
C Im
pact
AP
--
-23
2520
1818
6016
110
5796
727
0399
527
0400
1230
3247
6878
947
6879
2169
80A
ssam
--
-17
6762
210
6057
6098
394
7440
5684
632
687
1009
577
6057
534
830
Bih
ar-
--
8231
954
4939
1737
4554
1594
184
9565
172
535
2736
516
1641
9112
4511
Del
hi-
--
2465
8217
2465
822
1070
167
3256
270
3256
2714
1648
9521
673
9521
6741
4193
Guj
arat
--
-84
3377
384
3377
3078
3319
7432
8819
7432
972
0630
4890
924
4890
9217
8519
Har
yana
--
-22
2684
617
8148
7682
617
7055
014
1644
6108
411
5037
992
030
3968
8H
P-
--
2930
562
1465
2810
1104
2639
7715
839
9107
5970
9735
826
2060
0J &
K-
--
3622
896
2173
7412
5352
7066
0142
396
2437
882
9807
4978
828
628
Kar
nata
ka-
--
2894
3196
2315
456
1345
859
8601
707
8601
7139
9979
8797
072
8797
0740
9064
Ker
ala
--
-14
5928
2811
6742
651
8045
6214
7649
718
2206
231
5323
225
2259
1119
40K
olka
ta-
--
8473
254
8473
2536
4350
6758
6067
586
2906
224
5353
324
5353
1055
02M
ahar
asht
ra-
--
1307
7708
1307
771
4773
3611
4899
2711
4899
346
5342
5593
362
5593
3626
0091
MP
--
-70
4407
156
3526
2571
0919
5853
315
6683
7148
644
6090
435
6872
1628
23M
umba
i-
--
1410
8689
1410
869
6419
4519
7359
4319
7359
489
7985
1175
0285
1175
029
5346
38O
dish
a-
--
3552
460
2131
4815
9861
1046
535
6279
247
094
1876
146
1125
6984
427
Punj
ab11
7616
4770
5699
5233
9311
6587
9969
9528
5188
1721
2493
916
9995
9456
040
1819
532
1456
1788
10TN
--
-36
3995
5936
3995
618
0177
827
9147
927
9148
1353
8782
2369
082
2369
3988
49U
PE-
--
8053
917
6443
1328
1887
2584
388
2067
5195
622
4477
859
3582
2920
1504
UPW
--
-52
5342
842
0274
1864
9779
6488
6371
928
275
6093
7748
750
2163
3W
B-
--
2664
547
2131
6471
943
8106
8464
855
2837
424
0390
019
2312
8413
6TO
TAL
UA
SL (B
AL
)11
7616
4770
5699
5233
9322
8946
343
1975
4140
9800
213
8422
4263
8026
737
3500
329
8332
2317
7644
789
3611
366
NL
D (i
/c IP
1)-
--
4139
0695
2483
442
-32
0881
719
2529
-34
2050
420
5230
-IL
D (i
/c B
ILG
O)
--
-42
5134
2425
5080
5-
2495
8196
814
9749
18-
1733
1596
210
3989
58-
ISP
(i/c
BB
L)
1340
7568
8044
54-
6081
986
3649
19-
4837
5929
026
-27
2318
1633
9-
VSA
T (i/
c Sa
tcom
)10
3063
8961
8383
-95
4889
157
2933
-80
6848
4-
1090
6165
44-
GR
AN
D T
OTA
L35
4756
0421
2853
652
3393
3284
8133
825
7262
3998
0021
333
7506
875
2322
3694
3500
329
2604
4016
218
2718
6036
1136
6
(` in
cro
re)
Serv
ices
/Com
pany
Tota
l am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
Tota
l UA
SL
40.8
3
3.
62
1.
74
NL
D (i
/c IP
1)
4.8
0
0.
29
-
IL
D (i
/c B
ILG
O)
46
.54
2.79
-
ISP
(i/c
BB
L)
2
.02
0.12
-
VSA
T (i/
c Sa
tcom
)
2.0
0
0.
12
-
G
RA
ND
TO
TAL
96
.19
6.94
1.
74
Report No. 4 of 2016
- 178 -
Airtel
AN
NE
XU
RE
3.1
9 [P
ara
3.3.
9]Im
pact
on
paym
ent o
f Rev
enue
Sha
re (L
F an
d SU
C) o
n pr
ofit o
n Sa
le o
f Ass
ets n
ot c
onsi
dere
d by
BA
L(A
mou
nt in
`)
Serv
ices
/LSA
FY 2
007-
08FY
200
8-09
FY 2
009-
10A
mou
nt o
f GR
/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f GR
/A
GR
LF
Impa
ctSU
C Im
pact
AP
3778
2130
226
1719
198
390
9839
4477
1761
2417
612
8014
Ass
am10
905
654
376
1380
882
847
669
3519
4161
123
926
Bih
ar54
506
3270
2480
5502
433
0125
0411
1813
6709
5087
Del
hi38
6366
3863
716
768
1074
769
1074
7746
752
1743
6717
437
7585
Guj
arat
2620
626
2195
735
370
3537
1291
7795
077
9528
45H
arya
na11
442
915
395
1427
111
4249
221
699
1736
749
HP
9581
479
331
1025
061
535
417
960
1078
620
J & K
1533
192
053
039
994
2400
1380
2723
516
3494
0K
arna
taka
5422
750
4338
2025
2158
2230
8556
2230
856
1037
348
9381
363
9381
3643
6233
Ker
ala
2288
618
3181
228
718
2297
1019
4883
939
0717
34K
olka
ta52
6888
4252
6888
422
6562
016
3034
5516
3034
670
1049
6068
170
6068
1726
0931
Mah
aras
htra
4485
044
8516
3754
893
5489
2223
9030
790
3141
99M
P27
7207
9122
1766
310
1180
996
9911
477
5929
3540
1824
9261
1994
190
98M
umba
i48
855
4886
2223
5208
052
0823
7030
1912
3019
113
737
Odi
sha
2131
518
1278
9195
918
2466
114
8011
1044
946
2697
2023
Punj
ab46
263
2776
2059
5346
642
7723
7983
654
6692
3723
TN16
2353
1623
580
3693
430
9343
4531
1652
8316
528
8016
UPE
3197
125
5811
1945
165
3613
1671
8812
370
5039
66U
PW17
944
1436
637
2132
217
0675
740
504
3240
1438
WB
3111
2703
2489
016
8400
4322
2686
0717
8148
977
9401
7547
2760
378
2641
5TO
TAL
UA
SL (B
AL
)12
0343
883
1064
9202
4521
099
7229
5341
6581
171
2945
602
1861
7756
1800
221
8212
79N
LD
(i/c
IP1)
(162
3135
)-
-(9
9347
9)-
-40
6045
2436
3-
ILD
(i/c
BIL
GO
)72
066
4324
-78
630
4718
-13
3684
8021
-IS
P (i/
c B
BL
)24
8914
9-
4145
249
-70
8742
5-
VSA
T (i/
c Sa
tcom
)13
9684
-14
9189
-24
0314
4-
GR
AN
D T
OTA
L12
0419
834
1065
3759
4521
099
7237
9607
6586
227
2945
602
1916
6975
1833
174
8212
79
Not
e: N
egat
ive
figur
es n
ot c
onsi
dere
d fo
r cal
cula
tion
of G
R/A
GR
.(`
in c
rore
)
Serv
ices
/Com
pany
Tota
l am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
Tota
l UA
SL
21
.13
1.
90
0.83
NL
D (i
/c IP
1)0.
04
0.00
-
ILD
(i/c
BIL
GO
)
0.0
3
0.01
-
ISP
(i/c
BB
L)
0
.00
0.
00
-
VSA
T (i/
c Sa
tcom
)
0.0
0
0.00
-
GR
AN
D T
OTA
L
21.2
0
1.91
0.
83
Report No. 4 of 2016
- 179 -
AirtelA
NN
EX
UR
E 3
.20
[(Pa
ra 3
.4.1
]Im
pact
on
paym
ent o
f LF
and
SUC
due
to d
educ
tion
of B
ad D
ebts
Wri
tten
Off
from
GR
to a
rriv
e at
AG
R fo
r co
mpu
tatio
n of
rev
enue
shar
e(A
mou
nt in
`)
Serv
ices
/LSA
FY 2
007-
08FY
200
8-09
FY 2
009-
10
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f GR
/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ct
AP
3480
7986
2784
639
1583
763
2703
776
2703
7812
3022
6810
762
6810
7630
9890
Ass
am27
1126
8216
2676
193
5388
9385
793
5631
4832
3810
9354
651
5612
7932
2735
Bih
ar39
6598
923
7959
1804
5252
8029
031
6817
2402
5397
6755
358
6053
4444
24D
elhi
7583
5032
7583
503
3291
240
1270
3579
1270
358
5526
0615
6704
2315
6704
268
1663
Guj
arat
1638
9698
416
3896
9859
8224
0-
--
8722
8130
8722
813
3183
827
Har
yana
1059
8051
984
7844
236
5632
869
2166
3255
3733
123
8797
411
9137
9995
3104
4110
26H
P18
0240
590
120
6218
317
6547
0510
5928
260
9087
3568
1721
409
1231
0J &
K43
6165
6926
1699
415
0913
366
6144
039
9686
2298
2016
2438
9746
5604
Kar
nata
ka29
9439
4823
9551
613
9239
4-
--
2428
345
2428
3511
2918
Ker
ala
8160
5075
6528
406
2896
980
2845
1963
2276
157
1010
045
5228
0599
4182
448
1855
961
Kol
kata
2340
3819
2340
382
1006
364
7476
783
7476
7832
1502
1152
075
1152
0849
539
Mah
aras
htra
3195
7646
831
9576
4711
6645
4192
5100
6892
5100
737
4665
873
3366
773
3367
3410
16M
P24
3960
087
1951
6807
8904
543
8851
4264
7081
141
3230
771
7944
4482
6355
559
2899
724
Mum
bai
2871
5483
128
7154
8313
0655
4518
6185
6618
6185
784
7145
2226
3821
2226
382
1013
004
Odi
sha
1471
4819
8828
8966
2167
8107
132
4864
2836
4821
1249
0824
7494
4956
2087
Punj
ab36
5974
0421
9584
416
2858
422
6062
2618
0849
810
0597
795
5470
076
4376
4251
84TN
1897
5261
718
9752
6293
9275
512
0058
480
1200
5848
5822
836
3753
2877
3753
288
1820
345
UPE
7027
914
5622
3324
5977
7989
7328
6391
786
2956
201
1612
4781
1289
982
7256
15U
PW11
2079
233
8966
339
3978
813
3448
4924
2758
794
1224
215
2212
9171
1770
334
7855
86W
B84
6006
167
6805
2284
2274
2747
659
4198
2599
6273
4842
158
7874
2571
95TO
TAL
BA
L18
1129
4443
1635
2172
972
2678
1263
1759
425
5468
0392
2525
6705
4113
4833
635
8736
2416
2196
53N
E-
--
2235
4432
1341
266
5923
92-
--
Raj
asth
an-
--
1724
7813
798
6640
3383
4527
068
1539
5TO
TAL
BH
L-
--
2252
6910
1355
064
5990
3233
8345
2706
815
395
TOTA
L U
ASL
1811
2944
4316
3521
729
7226
7812
6542
8633
556
0354
5625
8557
3741
1686
681
3590
0692
1623
5048
(` in
cro
re)
Serv
ices
/Com
pany
Tota
l am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
BA
L
28
5.44
25.
41
11.3
8
BH
L
2.2
8
0.
14
0.0
6
Tota
l UA
SL
28
7.72
25.
55
11.4
4
Report No. 4 of 2016
- 180 -
Airtel
ANNEXURE 3.21 [Para 3.4.2]Impact on payment of LF & SUC due to deduction of lease line charges (2006-07)
(Amount in `)
Services/LSA Amount of GR/AGR LF Impact SUC Impact
AP 5681254 454500 257361
Assam - - -
Bihar 134698433 8081906 5832442
Delhi 91775162 9177516 3992220
Gujarat 139189284 13918928 5080409
Haryana 119834958 9586797 4170257
HP 13121316 656066 452685
J&K 12644856 758691 417280
Karnataka 432674658 34613973 20119372
Kerala 127128652 10170292 4513067
Kolkata 63469174 6346917 2729174
Maharashtra 499135568 49913557 18218448
MP 313098261 25047861 11428087
Mumbai 85615307 8561531 3895496
Odisha - - -
Punjab 57064747 3423885 2539381
TN (including Chennai) 533323080 53332308 20266277
UPE 238080782 19046463 8332827
UPW 121832683 9746615 4325060
WB 22902939 1832235 572573
TOTAL BAL 3011271114 264670041 117142416
NE - - -
Rajasthan 259605842 15576351 9164086
TOTAL BHL 259605842 15576351 9164086
TOTAL UASL 3270876956 280246392 126306502
(` in crore)
Services/Company Total amount of GR/AGR LF Impact SUC Impact
BAL 301.13 26.47 11.71
BHL 25.96 1.56 0.92
Total UASL 327.09 28.03 12.63
Report No. 4 of 2016
- 181 -
AirtelA
NN
EX
UR
E 3
.22
[Par
a 3.
4.3]
Impa
ct o
n pa
ymen
t of S
UC
due
to n
on c
onsi
dera
tion
of r
even
ue fr
om sa
le/le
ase
of b
andw
idth
(Am
ount
in `
)
Serv
ices
/LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of G
R/
AG
RSU
C Im
pact
Am
ount
of G
R/
AG
RSU
C Im
pact
Am
ount
of G
R/
AG
RSU
C Im
pact
Am
ount
of G
R/
AG
RSU
C Im
pact
AP
2992
3939
1355
554
2912
0400
1324
978
7698
0625
3502
618
4795
1780
2181
806
Del
hi11
3660
298
4944
223
1989
6606
486
3512
746
2475
179
2011
7670
2140
8548
793
1271
9
Guj
arat
--
1979
589
7225
578
0004
928
4702
3242
0174
1183
336
Har
yana
1110
8038
6610
4717
3613
2683
8592
5967
5424
523
3021
Kar
nata
ka20
7065
450
9628
543
3496
4845
916
2586
5350
7045
098
2357
7597
1351
5017
362
8448
3
Ker
ala
1190
6375
4226
7613
1881
1546
8178
1814
7125
6442
2320
2028
8571
7202
Kol
kata
8140
710
3500
5119
6431
6584
4656
4789
5614
2059
511
2003
8780
8616
68
MP
1734
2484
863
3000
782
1415
9929
9816
819
4190
153
7087
941
4467
9689
1630
809
Mah
aras
htra
4822
117
1760
0732
3673
4811
8140
868
5975
1327
7819
965
4378
4730
4286
0
Mum
bai
--
8252
1377
3754
723
1676
9282
676
3002
412
2221
994
5561
101
Punj
ab21
9127
9751
6653
288
2960
7113
7101
5861
0102
1473
9745
6559
19
TN38
3228
561
1456
2685
1690
6583
683
6875
930
9726
174
1502
1719
1437
7231
669
7295
7
UPE
--
2077
2372
7024
1380
889
311
2172
3467
9775
56
UPW
--
--
1312
695
4660
118
0491
1164
0743
TOTA
L B
AL
9325
0250
537
7833
6398
5607
680
4421
3859
1878
2554
0283
4594
7790
7227
693
4025
6180
Raj
asth
an42
8891
1514
011
0603
639
264
7377
623
2840
3820
8805
3495
0064
TOTA
L B
HL
4288
9115
140
1106
036
3926
473
7762
328
4038
2088
0534
9500
64
TOTA
L U
ASL
9329
3139
637
7985
0398
6713
716
4425
3123
1885
6330
2583
7435
1592
8108
227
4120
6244
(` in
cro
re)
Serv
ices
/Com
pany
Tota
l am
ount
of G
R/A
GR
SUC
Impa
ct
BA
L
47
0.36
20.5
7
BH
L
2.9
8
0.1
3
Tota
l UA
SL
47
3.34
20.7
0
Report No. 4 of 2016
- 182 -
Airtel
ANNEXURE 3.23 [Para 3.5]Impact on payment of LF and SUC on gain from transfer of assets by BAL during 2007-08
(Amount in `)
Services/LSA Amount of GR/AGR LF Impact SUC Impact
AP 2450296243 245029624 111488479
Assam 354079600 21244776 12215746
Bihar 1248925110 74935507 56826093
Delhi 3317758185 331775819 144322481
Gujarat 850880422 85088042 31057135
Haryana 371500711 29720057 12816775
HP 311076018 18664561 10732123
J&K 497794076 29867645 17173896
Karnataka 3320068629 332006863 154383191
Kerala 743080768 59446461 26379367
Kolkata 772734448 77273445 33227581
Maharashtra 1456239694 145623969 67715146
MP 990684944 79254796 36160000
Mumbai 1586268306 158626831 72175208
Odisha 562117623 33727057 25295293
Punjab 1440197276 115215782 64088779
TN 2565232252 256523225 124413764
UPE 1003703147 80296252 45166642
UPW 582614107 46609129 20682801
WB 538448440 43075875 18845695
TOTAL UASL 24963699999 2264005716 1085166195
(` in crore)
Services/Company Total amount of GR/AGR LF Impact SUC Impact
UASL 2,496.37 226.40 108.52
Report No. 4 of 2016
- 183 -
Airtel
AN
NE
XU
RE
3.2
4 [P
ara
3.6]
Stat
emen
t sho
win
g in
tere
st o
n L
F an
d SU
C u
pto
Mar
ch 2
015
(Am
ount
in `
)
Sl N
o.
Para
N
o.
No.
of M
onth
s(up
to M
arch
15)
9684
7260
TOTA
LR
ate@
(PL
R+2
)%14
.25
14.2
514
.25
13.7
5
Issu
es20
06-0
720
07-0
820
08-0
920
09-1
0In
tere
st o
n L
FIn
tere
st o
n SU
CIn
tere
st o
n L
FIn
tere
st o
n SU
CIn
tere
st o
n L
FIn
tere
st o
n SU
CIn
tere
st o
n L
FIn
tere
st o
n SU
C
13.
2.1
Com
mis
sion
/Mar
gin
1193
9840
060
5418
8324
4892
030
1276
5799
826
7280
236
1363
7391
248
7801
571
2434
2229
316
8736
8322
2
3.2.
1B
FAT
1235
7370
859
7846
0221
2512
790
1177
0470
532
7357
610
1530
8354
111
6490
250
5654
3739
1167
0509
453
Free
of C
ost
5875
0098
2549
1437
7804
718
3303
519
1832
009
8553
8022
0530
910
9602
110
1338
491
4Pr
omo
2568
5419
1195
5298
7864
269
4519
154
3076
7581
1458
1439
1867
9414
9356
666
1234
0923
95
Ful
l Tal
k Ti
me
9171
998
4533
690
1067
2617
4689
981
9651
2455
4946
2099
558
9935
4233
6814
576
Adj
ustm
ents
offe
red
6959
9784
3542
9628
8870
4312
4820
3428
1385
8454
266
1620
7257
3091
5527
1349
2553
1127
846
73.
2.2
Dis
coun
ts
1214
0979
951
7386
8973
4659
5436
6623
3217
5018
9083
4451
563
0929
9128
7027
8140
0918
951
8w
aive
rs (R
EV)
7701
3230
4653
8690
5675
3829
3457
0739
7062
6518
3413
0464
6289
8006
429
3490
075
1242
1036
089
wai
vers
(EX
P)62
4839
4529
1168
2639
3109
5318
9105
5232
4786
3914
6872
3325
5214
5711
5525
0823
4062
112
103.
2.3
IOT
Dis
coun
t58
6049
3027
4886
8460
6837
6029
5693
8811
4926
511
5160
1446
6674
792
3157
657
3527
0716
811
3.2.
4Si
te sh
arin
g re
venu
e 48
8389
7821
7622
0321
7139
148
9840
2078
1109
5957
4828
424
3282
9949
1844
8291
4533
4502
712
3.2.
5Fo
rex(
BA
L)12
9757
4755
9306
425
8581
6923
9896
791
0318
2036
2331
5976
0278
0331
2665
2828
1385
256
13Fo
rex(
BH
L)11
2636
6626
868
5343
438
6250
463
871
3046
835
3473
120
0604
816
5299
6014
3.3.
1In
tere
st In
com
e(B
AL)
3452
0081
1400
7244
8994
4710
3891
7465
1673
2576
667
7601
3784
6064
2934
7073
7853
1789
209
15In
tere
st In
com
e(B
HL)
00
6410
9437
9314
1320
258
6353
7430
4302
417
2869
677
4776
016
3.3.
3In
com
e on
inve
stm
ent(B
AL)
5774
7556
2363
3694
7867
5924
3407
6919
2648
3241
410
7520
967
1500
5890
861
7119
1077
8258
292
173.
3.5
BIL
GO
Rev
enue
(ILD
)10
0711
650
1342
5462
091
1560
20
9060
324
041
6725
5418
3.3.
6Sa
tcom
Bro
adba
nd(V
SAT)
2634
2331
036
6610
360
1810
0588
021
5702
110
1026
7416
619
3.3.
7IP
-1 R
even
ue(N
LD)
5942
6791
054
9508
060
5244
9703
028
2674
410
1950
9474
020
3.3.
8M
isc.
Inco
me(
BA
L)44
8235
711
0218
243
6216
1916
6173
2131
1095
5346
8890
417
9243
0635
4267
312
3088
915
213.
3.9
Profi
t on
sale
of a
sset
s(B
AL)
00
1806
4600
7666
013
8822
653
3945
813
1798
304
8056
5741
1030
4022
3.4.
1D
educ
tion
of B
ad D
ebt w
ritte
n of
f(B
AL)
00
2772
6876
812
2537
887
7324
7716
3383
2895
3519
1262
1591
1135
5579
8966
323
Ded
uctio
n of
Bad
Deb
t writ
ten
off(
BH
L)0
00
018
1519
180
2440
2655
315
102
2659
286
243.
4.2
Ded
uctio
n of
Lea
se li
ne(B
AL)
5573
5288
524
6683
241
00
00
00
8040
3612
625
Ded
uctio
n of
Lea
se li
ne(B
HL)
3280
1310
1929
8103
00
00
00
5209
9414
263.
4.3
Sale
/leas
e of
Ban
dwid
th(B
AL)
079
5657
350
7496
9377
011
1799
054
039
4904
5630
5824
623
27Sa
le/le
ase
of B
andw
idth
(BH
L)0
3188
20
6657
60
3804
860
9319
9314
1093
828
3.5
Tran
sfer
of A
sset
s0
038
3886
6423
1840
0165
870
00
056
7888
3010
TO
TAL
1570
3631
4776
4363
045
5504
6364
2326
6570
2803
1732
6517
5085
2833
066
1872
7938
0688
6016
075
1584
9360
117
Say
` 1,
584.
94 c
rore
Report No. 4 of 2016
- 184 -
Vodafone
AN
NE
XU
RE
4.0
1 [P
ara
No.
4.2.
1]Im
pact
on
paym
ent o
f LF
and
SUC
due
to n
on-c
onsi
dera
tion
of C
omm
issi
on/d
isco
unt t
o de
aler
s(A
mou
nt in
`)
Serv
ices
/ L
SA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
AP
--
-24
8449
703
2484
4970
8819
964
3253
0911
132
5309
1111
5484
7331
0755
115
3107
5512
1103
1807
Ass
am-
--
--
-46
7715
628
0629
1099
1344
6395
3726
7837
210
4902
9
Bih
ar-
--
--
-15
9598
1395
7589
3750
5611
7699
772
7061
986
2765
945
Che
nnai
1685
1410
1685
141
7161
8515
6518
311
1565
1831
6652
028
1587
3568
315
8735
6867
4626
715
9714
525
1597
1453
6787
867
Del
hi60
0000
060
0000
2640
00
19
7228
587
1972
2859
8678
058
Guj
arat
8470
2724
6776
218
3853
974
4888
3143
739
1065
1522
2418
3065
8856
335
6588
5634
2997
7963
1152
3717
511
5237
1752
4329
1
Har
yana
2105
6934
1263
416
7264
6421
1647
358
1269
8841
7301
834
4559
5955
3647
676
1573
060
7837
0732
6269
659
2703
790
J&K
--
--
--
--
-44
3098
2658
610
413
Kar
nata
ka27
7717
7027
7717
712
6361
624
1788
224
1788
1100
1433
8662
256
3386
6226
1540
9133
3225
6485
632
2564
8614
6767
01
Ker
ala
8854
0271
5312
416
3054
639
1465
7837
787
9470
350
5695
436
5387
876
2923
1030
1260
5882
4190
1574
633
5212
6014
4560
43
Kol
kata
2390
3083
2390
308
1015
881
1728
3125
617
2831
2673
4532
824
6679
246
2466
7925
1048
3868
2231
6470
422
3164
7094
8450
0
Mah
aras
htra
7263
7077
5810
966
2578
616
1945
8034
215
5664
2769
0760
239
3033
124
3930
3312
1395
2676
4392
6069
843
9260
7015
5937
55
MP
--
--
--
2239
150
1791
3252
620
1377
8545
811
0228
3732
3795
8
Mum
bai
2012
2580
420
1225
8090
5516
131
6853
495
3168
5350
1425
8407
4609
1900
446
0919
0020
7413
5538
0717
179
3807
1718
1713
2273
NE
--
--
--
1950
235
1170
1445
831
2366
104
1419
6655
603
Odi
sha
--
--
--
1031
2293
6187
3824
2339
4396
7692
2638
062
1033
241
Punj
ab-
--
2864
1941
222
9135
5398
8147
022
3670
248
1789
3620
7716
624
2484
7489
619
8779
9285
7238
4
Raj
asth
an42
9414
9434
3532
014
8148
233
5174
529
2011
0472
1156
3521
4582
7043
436
6616
3515
8103
3047
4778
210
3798
2257
1637
9848
TN82
2465
4165
7972
337
4221
8-
--
4904
9069
949
0490
7022
3173
2756
0509
229
5605
0923
2550
3170
UP
(E)
4186
2512
2511
751
1988
469
1828
2999
010
9697
9986
8442
520
7636
529
1661
0922
9862
735
1952
2387
715
6179
1092
7313
4
WB
3437
2194
2749
776
1185
841
2813
0916
722
5047
3397
0516
641
0487
253
3283
8980
1416
1810
4682
0457
037
4563
6616
1530
58
Tota
l UA
SL74
4111
814
6201
4792
3092
6546
3024
4412
5824
2372
109
1185
2854
448
1887
2400
4463
0551
119
3733
261
4940
1217
6044
5210
458
1898
2186
8
(` in
cro
re)
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
1
,352
.75
119
.59
53.3
0
Report No. 4 of 2016
- 185 -
VodafoneA
NN
EX
UR
E-4
.02
[Par
a N
o.4.
2.3]
Impa
ct o
n L
F an
d SU
C d
ue to
net
ting
off o
f IO
T di
scou
nts f
rom
roa
min
g re
venu
e (A
mou
nt in
`)
Serv
ices
/LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
AP
1986
0000
1986
000
7050
3062
1419
9862
1420
022
0604
127
5385
3427
5385
397
7618
1596
0000
1596
000
5665
80
Che
nnai
2541
0000
2541
000
1079
925
5774
0000
5774
000
2453
950
2743
0000
2743
000
1165
775
1700
0000
1700
000
7225
00
Del
hi12
8880
000
1288
8000
5670
720
2492
3000
024
9230
0010
9661
2018
7760
000
1877
6000
8261
440
8721
7635
8721
764
3837
576
Guj
arat
1135
0000
9080
0051
6425
3852
0000
3081
600
1752
660
1656
0000
1656
000
7534
8020
8800
0020
8800
095
0040
Har
yana
1640
000
9840
056
580
4430
000
2658
0015
2835
5235
1541
881
1806
116
2695
013
0156
5613
0
Kar
nata
ka44
1900
0044
1900
020
1064
584
2100
0084
2100
038
3155
585
2000
0085
2000
038
7660
030
1300
0030
1300
013
7091
5
Ker
ala
--
-41
3500
0024
8100
014
2657
532
0600
0025
6480
011
0607
031
4697
6425
1758
110
8570
7
Kol
kata
1188
0000
1188
000
5049
0018
6900
0018
6900
079
4325
1244
0000
1244
000
5287
0077
5000
077
5000
3293
75
Mah
aras
htra
5285
0000
4228
000
1876
175
8173
4625
6538
770
2901
579
4600
6406
4600
641
1633
227
3812
9097
3812
910
1353
583
Mum
bai
1084
6822
910
8468
2348
8107
024
9280
000
2492
8000
1121
7600
1483
1000
014
8310
0066
7395
090
0250
0090
0250
040
5112
5
Punj
ab86
5000
069
2000
2984
2519
7100
0015
7680
067
9995
9880
000
7904
0034
0860
4552
198
3641
7615
7051
Raj
asth
an16
3800
0098
2800
5651
1032
1400
0019
2840
011
0883
021
7200
0017
3760
074
9340
8790
000
7032
0030
3255
TN-
--
2282
4108
1825
929
1038
497
9858
9298
589
4485
811
8639
6611
8639
753
9810
UP
(E)
4030
000
2418
0019
1425
3210
000
1926
0015
2475
7670
000
6136
0036
4325
6971
000
5576
8033
1123
UP
(W)
1683
766
1347
0156
406
8771
935
7017
5529
3860
8060
000
6448
0027
0010
4924
517
3939
6116
4971
WB
1820
000
1456
0062
790
1430
000
1144
0049
335
3140
000
2512
0010
8330
1800
000
1440
0062
100
Tota
l UA
SL43
7091
995
4130
0124
1847
5626
9754
1266
690
8362
5341
0262
3263
5284
348
6186
7364
2687
2645
3790
9012
736
7063
2415
8818
41
(`
in c
rore
)
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
242
.69
23.
07
10.
23
Report No. 4 of 2016
- 186 -
Vodafone
AN
NE
XU
RE
4.0
3 [P
ara
No.
4.2.
4]Im
pact
on
LF
and
SUC
due
to n
on-c
onsi
dera
tion
of S
ervi
ce ta
x on
FT
T
(Am
ount
in `
)
Serv
ices
/ L
SA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SU
C Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SU
C Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SU
C Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SU
C Im
pact
Bih
ar-
--
--
--
--
7607
8518
4564
711
3309
416
Che
nnai
--
--
--
2048
9847
2048
985
8708
1818
7250
3118
7250
379
5814
Del
hi-
--
--
-11
2768
9911
2769
049
6184
--
-
Guj
arat
--
-92
2192
7377
5.36
4196
028
2385
528
2386
1284
85-
--
Har
yana
--
-83
9403
2550
3642
028
9594
179
7501
9263
8001
527
5138
281
6009
0765
2807
336
3124
0
Kar
nata
ka-
--
9332
8558
9332
856
4246
449
2960
7691
329
6076
9113
4715
0019
2444
127
1924
4413
8756
208
Ker
ala
--
--
--
5879
5372
4703
630
2028
440
8306
1815
6644
945
3696
251
MP
--
--
--
--
-16
7171
3613
3737
172
7195
Mum
bai
--
--
--
1908
7303
019
0873
0385
8928
6-
--
Punj
ab26
3712
8521
0970
2.8
9098
0911
1730
8938
3855
9804
747
7843
8033
8264
4588
6130
3670
890
2041
933
Raj
asth
an12
3846
0774
3076
4272
6918
4717
909
1108
3075
6372
768
2796
2217
422
3697
7496
4696
518
5955
234
1487
6419
8275
008
UP
(E)
9948
774
5969
2647
2567
1359
2656
181
5559
464
5651
212
8459
0910
2767
361
0181
1495
8522
1196
682
7105
30
Tota
l UA
SL48
7046
6634
4970
618
0964
549
8947
274
3369
0657
2001
7485
9623
5893
787
4195
2638
9315
0571
5427
420
5993
6006
3194
3594
(`
in c
rore
)
Am
ount
of
GR
/AG
RL
F Im
pact
SU
C
Impa
ct
222
.54
18.
45
9.
27
Report No. 4 of 2016
- 187 -
VodafoneA
NN
EX
UR
E 4
.04
[Par
a N
o.4.
2.5]
Impa
ct o
n L
F an
d SU
C d
ue to
non
-con
side
ratio
n of
Infr
astr
uctu
re sh
arin
g re
venu
e
(A
mou
nt in
`)
Serv
ices
/LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
And
hra
Prad
esh
2044
1695
2044
170
7256
8015
2223
809
1522
2381
5403
945
2657
9584
826
5795
8594
3575
356
5799
556
5800
2008
59
Che
nnai
3327
9418
3327
942
1414
375
5311
1554
5311
155
2257
241
6039
2873
6039
287
2566
697
2468
6916
2468
692
1049
194
Del
hi13
0910
9013
0910
957
6008
8345
9975
8345
998
3672
239
1958
0680
919
5806
8186
1550
029
6963
129
6963
1306
64
Guj
arat
5804
1838
4643
347
2640
904
1345
5067
810
7640
5461
2205
632
9861
379
3298
6138
1500
8693
1296
4813
1296
481
5898
99
Har
yana
--
-11
3415
404
6804
924
3912
831
1672
3326
813
3786
6157
6954
814
7590
0211
8072
050
9186
Kar
nata
ka97
2547
5597
2547
644
2509
114
0935
902
1409
3590
6412
584
1487
9820
614
8798
2167
7031
826
5735
3726
5735
412
0909
6
Ker
ala
4766
2086
2859
725
1644
342
1519
3581
791
1614
952
4178
628
2617
254
2260
9380
9750
295
2489
1977
1991
358
8587
73
Kol
kata
2807
5739
2807
574
1193
219
3992
6702
3992
670
1696
885
5094
1650
5094
165
2165
020
5947
108
5947
1125
2752
Mah
aras
htra
2936
4813
2349
185
1042
451
1747
3966
013
9791
7362
0325
818
4413
654
1844
1365
6546
685
8424
0433
8424
043
2990
535
Mum
bai
5491
4560
5491
456
2471
155
8186
2863
8186
286
3683
829
9165
9841
9165
984
4124
693
2217
6063
2217
606
9979
23
Punj
ab-
--
1354
4811
1083
585
4672
9612
1117
483
9689
399
4178
553
6710
7132
5368
571
2315
196
Raj
asth
an28
5614
4417
1368
798
5370
2856
1444
1713
687
9853
7050
0307
4540
0246
017
2606
125
0722
652
2005
7812
8649
931
TN21
7140
0817
3712
198
7987
6994
6928
5595
754
3182
585
1005
1665
910
0516
6645
7350
813
1212
4413
1212
459
7017
UP
(E)
2411
213
1446
7311
4533
5121
5966
3072
958
2432
758
2615
1978
920
9215
8312
4221
9061
7017
449
3614
2930
83
UP
(W)
--
-21
7738
077
1741
9046
7294
226
2222
5189
617
7801
5274
4543
960
1303
548
1043
2014
37
WB
1888
4864
1510
789
6515
28-
--
1900
5578
515
2044
6365
5692
511
0796
056
8863
684
3822
464
Tota
l UA
SL45
3697
523
3966
4252
1887
2643
1507
1695
9112
4701
411
5896
8888
2723
0131
3924
6404
790
1076
5587
667
8797
768
5827
0576
2466
8009
(` in
cro
re)
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
536
.27
46.
90
2
1.02
Report No. 4 of 2016
- 188 -
Vodafone
AN
NE
XU
RE
-4.0
5 [P
ara
No.
4.2.
6]Im
pact
on
LF
and
SUC
due
to n
on-c
onsi
dera
tion
of g
ain
on fo
reig
n ex
chan
ge fl
uctu
atio
n
(Am
ount
in `
)
Serv
ices
/ LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im-
pact
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Im
pact
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C
Impa
ct
AP
8516
0404
8516
040
3023
194
4640
9216
4640
922
1647
527
--
-40
0007
2040
0007
214
2002
6A
ssam
--
--
--
--
-19
6498
711
7899
4617
7B
ihar
--
--
--
--
-12
7056
2976
2338
2985
82C
henn
ai47
5878
747
5879
2022
48-
--
1321
2513
212
5615
4187
525
4187
5317
7970
Del
hi16
9829
1698
374
72-
--
5992
1611
5992
161
2636
551
--
-G
ujar
at-
--
1366
0885
610
9287
0862
1570
314
2560
309
1425
6031
6486
494
--
-H
arya
na-
--
3205
0661
1923
040
1105
748
--
-81
1009
364
8807
2797
98H
P-
--
--
--
--
2283
253
1369
9553
656
Kar
nata
ka53
2757
253
2757
2424
0514
2893
614
2894
6501
737
1205
139
3712
0514
1688
9834
--
-K
eral
a-
--
7107
523
4264
5124
5210
--
-93
9866
675
1893
3242
54K
olka
ta35
400
3540
1505
--
-12
2217
025
1222
1703
5194
224
--
-M
ahar
asht
ra-
--
--
-16
2410
1716
2410
257
6556
--
-M
P-
--
--
--
--
9491
548
7593
2422
3051
Mum
bai
--
-86
2875
2986
2875
338
8293
934
2000
2134
2000
215
3900
1-
--
NE
--
--
--
--
-32
7401
519
6441
7693
9O
dish
a-
--
1118
456
6710
726
284
--
--
--
Punj
ab10
8018
0786
4145
3726
6233
5203
0326
8162
411
5645
0-
--
--
-R
ajas
than
--
--
--
--
-42
1112
5233
6890
014
5283
8TN
--
-36
4286
029
1429
1657
5037
7219
937
7220
1716
35-
--
UP
(E)
1487
4000
8924
4070
6515
--
--
--
--
-U
P (W
)74
8899
459
9120
2508
8168
6734
6854
9387
723
0056
1-
--
1447
9546
1158
364
4850
65W
B10
7028
0785
6225
3692
47-
--
--
-26
0589
8820
8471
989
9035
Tota
l UA
SL13
9319
600
1275
7128
5176
130
4168
4780
835
2248
0516
8111
8875
0249
446
7502
4945
3349
9910
1740
6622
314
4045
0557
3739
2N
LD
2911
403
1746
84-
3259
513
1955
71-
--
--
--
ILD
1140
8768
45-
--
--
--
6762
5846
4057
551
-G
rand
Tot
al14
2345
090
1293
8657
5176
130
4201
0732
135
4203
7616
8111
8875
0249
446
7502
4945
3349
9910
2416
9206
918
4620
5657
3739
2
(`
in c
rore
)
Serv
ices
/ com
-pa
nyA
mou
nt o
f GR
/A
GR
LF
Impa
ctSU
C Im
pact
Tota
l UA
SL14
8.05
13.7
46.
12
NL
D0.
620.
04-
ILD
6.77
0.41
-
Gra
nd T
otal
155
.44
1
4.19
6.12
Report No. 4 of 2016
- 189 -
VodafoneA
NN
EX
UR
E 4
.06
(Par
a 4.
2.7)
Impa
ct o
n L
F an
d SU
C d
ue to
non
-con
side
ratio
n of
am
ount
of W
aive
rs(A
mou
nt in
`)
Serv
ices
/LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
Ass
am-
--
--
-49
687
2981
1168
--
-
Bih
ar-
--
--
--
--
1301
210
7807
330
578
HP
--
--
--
--
-13
0989
7859
3078
Ker
ala
--
-26
2787
015
7672
9066
241
2911
333
0329
1424
5447
5037
938
0030
1638
88
Mah
aras
htra
2010
875
1608
7071
386
3793
060
3034
4513
4654
6239
626
6239
6322
1507
7380
967
7380
9726
2024
MP
--
--
--
--
-50
6103
4048
811
893
NE
--
--
--
3129
818
7873
6-
--
Punj
ab-
--
2543
806
2035
0487
761
3022
957
2418
3710
4292
3351
302
2681
0411
5620
Raj
asth
an-
--
--
--
--
5380
463
4304
3718
5626
UP(
E)41
1445
924
6868
1954
3759
2677
835
5607
2815
2276
7320
561
3856
3644
7788
3773
170
7019
4197
92
UP(
W)
--
--
--
--
-49
0182
539
2146
1642
11
Tota
l UA
SL61
2533
440
7738
2668
2314
8915
1410
2022
859
4598
2114
5886
1814
844
8346
3436
5409
6930
4225
313
5671
2
(` in
cro
re)
Am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
7.8
7
0
.63
0
.31
Report No. 4 of 2016
- 190 -
Vodafone
AN
NE
XU
RE
4.0
7 (P
ara4
.3.1
)Im
pact
on
LF
and
SUC
due
to n
on-c
onsi
dera
tion
of In
tere
st in
com
e(A
mou
nt in
`)
Serv
ices
/ L
SA
2006
-07
2007
-08
2008
-09
2009
-10
Inte
rest
not
co
nsid
ered
Impa
ct o
n L
FIm
pact
on
SUC
Inte
rest
not
co
nsid
ered
Impa
ct o
n L
FIm
pact
on
SUC
Inte
rest
not
co
nsid
ered
Impa
ct o
n L
FIm
pact
on
SUC
Inte
rest
not
co
nsid
ered
Impa
ct o
n L
FIm
pact
on
SUC
AP
--
-12
010
1201
474
2856
828
2856
8310
1417
7830
3073
678
3030
7427
7975
91A
ssam
--
--
--
--
-91
215
5473
2144
Bih
ar-
--
--
--
--
2999
3617
996
7048
Che
nnai
--
-15
7576
915
7577
7563
722
6927
922
6928
9644
442
6631
864
4266
3186
1813
1854
Del
hi-
--
2099
8486
2099
849
1228
411
3626
2207
3626
221
1595
537
2339
5950
4123
3959
504
1029
4218
2G
ujar
at-
--
--
-91
7858
904
9178
5890
4176
2580
3288
5627
732
8856
2814
9629
61H
arya
na-
--
--
-26
4866
721
1893
9137
946
9045
779
3752
3662
1618
2079
HP
--
--
--
2114
013
1268
4149
679
1013
8777
6083
2723
8261
J&K
--
--
--
3227
619
3775
812
5563
7534
2951
Kar
nata
ka-
--
2143
5718
2143
572
1061
068
2543
0233
2543
023
1157
076
8300
5653
383
0056
5337
7675
72K
eral
a-
--
5720
5434
323
-29
8797
323
9038
1030
8520
7764
0009
1662
1120
171
6785
80K
olka
ta-
--
7079
532
7079
5333
9818
1757
0387
1757
039
7467
4180
7207
626
8072
0763
3430
6324
Mah
aras
htra
4462
5635
700
1584
288
1203
470
4963
3436
6913
5661
2513
5661
248
1597
2341
0730
9023
4107
309
8310
8095
MP
--
--
--
--
-11
6659
9333
2741
Mum
bai
--
-66
8951
663
6689
5166
3010
2825
2042
5903
4520
4259
035
9191
6566
4781
8953
8647
8189
539
2151
8529
2N
E-
--
--
--
--
6321
837
9314
86O
dish
a-
--
--
-14
6414
787
849
3440
712
5340
7520
2945
Punj
ab-
--
6996
655
9726
5916
8959
313
5167
5829
150
7981
011
4063
8481
1752
5345
Raj
asth
an-
--
1304
3078
2648
2622
5058
918
0047
7764
598
3565
997
7868
5280
3393
3027
TN-
--
3168
089
2534
47-
3954
433
3954
4317
9927
1500
7398
7315
0073
987
6828
3664
UP(
E)-
--
6224
444
3734
6774
0708
847
0539
9137
6431
922
3506
516
1984
9872
1295
8799
076
9428
69U
P(W
)-
--
4412
0135
296
1544
238
1268
3050
112
772
7436
4137
059
4913
1024
9119
86W
B-
--
5936
647
4921
9718
7566
715
0053
6471
180
3152
864
6425
2229
2770
8774
Tota
l UA
SL44
6256
3570
015
842
7395
3076
273
4249
8640
5841
1431
2485
6925
3111
6352
014
0765
679
2135
4924
035
1990
9587
7087
1625
772
NL
D-
--
2698
3816
190
-67
9549
340
7730
-16
1238
2788
9674
2967
-IL
D-
--
1195
5071
73-
2483
676
1490
21-
5719
2274
034
3153
64-
Gra
nd T
otal
4462
5635
700
1584
273
9920
150
7344
8349
4058
4114
3134
1360
9431
1720
270
1407
6567
923
5392
2956
221
2201
7102
8716
2577
2
(` in
cro
re)
Serv
ices
/ Com
pany
Am
ount
of
GR
/AG
R L
F Im
pact
SUC
Impa
ct
Tota
l UA
SL 2
,521
.98
23
7.56
10
5.30
NL
D
161
.94
9.7
2 -
ILD
57.
45
3.4
5 -
Gra
nd T
otal
2,7
41.3
7
250.
73
105.
30
Report No. 4 of 2016
- 191 -
VodafoneA
NN
EX
UR
E-4
.08[
Para
No.
4.3.
2]Im
pact
on
LF
and
SUC
due
to n
on-c
onsi
dera
tion
of P
rofit
on
Sale
of F
ixed
Ass
ets
(A
mou
nt in
`)
SER
VIC
ES/
LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
AP
2608
261
9314
9838
1498
453
1967
2098
6721
023
859
7564
9478
7564
948
2685
556
Ass
am-
--
--
--
--
2921
7221
1753
033
6866
05B
ihar
--
--
--
--
-58
1352
3488
113
662
Che
nnai
1114
453
1114
4547
364
2955
410
2955
4112
5605
--
-14
1833
1418
360
28D
elhi
1032
649
1032
6545
437
--
-18
1552
118
1552
7988
319
382
1938
853
Guj
arat
3737
1929
897
1700
469
3034
655
4428
3153
3115
9405
7596
1594
0576
072
5296
2122
5601
0022
5601
010
2648
5H
arya
na-
--
8833
5753
001
3047
6-
--
5092
386
4073
9117
5687
HP
--
--
--
--
-60
7236
414
3J&
K-
--
--
--
--
1-
-K
arna
taka
5029
8650
299
2288
637
855
3785
1722
--
-52
6001
952
6002
2393
31K
eral
a-
--
4727
4528
365
1631
0-
--
7933
410
6346
7327
3703
Kol
kata
1669
167
7150
5716
5057
221
493
3271
4432
714
1390
412
871
1287
547
Mah
aras
htra
1659
913
2858
9-
--
--
--
--
MP
--
--
--
--
--
--
Mum
bai
1620
242
1620
2472
911
1282
2783
1282
278
5770
2554
7296
5473
024
628
1864
080
1864
0883
884
NE
--
--
--
--
--
--
Odi
sha
--
-18
6011
244
1522
5291
3535
781
--
Punj
ab55
326
4426
1909
4933
339
4717
0215
9801
412
7841
5513
182
9849
6638
835
269
Raj
asth
an34
7620
912
0-
--
8225
3999
6580
320
2837
763
6624
6191
5299
695
2285
494
TN-
--
--
--
--
1163
9311
639
5296
UP
(E)
5856
0935
137
2781
666
3782
3982
731
530
7238
757
9134
3819
3650
1549
291
98U
P (W
)-
--
2329
118
6378
0-
--
1078
6709
8629
3736
1355
WB
8562
685
295
--
--
--
6910
5256
5528
420
2384
131
Tota
l UA
SL53
1789
849
9142
2364
9525
4963
1623
2870
211
2733
716
8149
6307
1664
6505
375
5718
0629
5616
255
2516
5690
1027
3225
NL
D-
--
--
-38
150
2289
--
--
VE
CL
Cor
p16
8713
1687
158
21-
--
--
--
--
Gra
nd T
otal
5486
611
5160
1424
2316
2549
6316
2328
702
1127
337
1681
5344
5716
6467
342
7557
1806
2956
1625
525
1656
9010
2732
25
Not
e :-
low
est r
ates
in V
ECL
is ta
ken
as ra
tes o
f VEC
L co
rp
(` in
cro
re)
Serv
ices
/ Com
pany
Am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
Tota
l UA
SL
200.
79
19.
45
8.7
2
NL
D
0
.00
0
.00
-
V
EC
L C
orp
0.0
2
0.0
0
0
.00
Gra
nd T
otal
200.
8119
.45
8.72
Report No. 4 of 2016
- 192 -
Vodafone
AN
NE
XU
RE
4.0
9 [P
ara
No.
4.4]
Im
pact
on
LF
and
SUC
due
to d
educ
tion
of B
ad d
ebts
from
GR
(A
mou
nt in
`)
Serv
ices
/ LSA
2007
-08
2008
-09
2009
-10
Am
ount
of L
F/SU
CL
F Im
pact
SUC
Impa
ct
Am
ount
of L
F/SU
CL
F Im
pact
SUC
Impa
ct
Am
ount
of L
F/SU
CL
F Im
pact
SUC
Impa
ct
AP
5852
3756
5852
376
2077
593
1030
6241
510
3062
4236
5871
644
2829
3144
2829
315
7204
4
Che
nnai
5349
1549
5349
155
2273
391
4583
2767
4583
277
1947
893
2865
9206
2865
921
1218
016
Del
hi12
9003
996
1290
0400
5676
176
3742
1257
137
4212
5716
4653
5316
2266
124
1622
6612
7139
709
Guj
arat
2925
8431
2340
674
1331
259
1001
1846
910
0118
4745
5539
040
7880
5340
7880
518
5585
6
Har
yana
1498
3471
8990
0851
6930
1139
1169
9112
9439
2995
3248
727
2598
9811
2081
Kar
nata
ka16
9266
065
1692
6607
7701
606
1151
2078
111
5120
7852
3799
634
2599
5034
2599
515
5882
8
Ker
ala
5209
4462
3125
668
1797
259
4426
7630
3541
410
1527
233
1813
6780
1450
942
6257
19
Kol
kata
6017
8535
6017
854
2557
588
1021
5105
210
2151
0543
4142
036
3357
8936
3357
915
4427
1
Mah
aras
htra
1232
7353
798
6188
343
7621
112
7315
371
1273
1537
4519
696
2481
1104
2481
110
8807
94
Mum
bai
1334
8288
413
3482
8860
0673
028
4764
500
2847
6450
1281
4403
1084
4520
810
8445
2148
8003
4
Odi
sha
--
--
--
1326
3879
5831
17
Punj
ab36
8787
3729
5029
912
7231
679
4269
2063
5415
427
4022
917
7638
0114
2110
461
2851
Raj
asth
an13
9022
9383
4138
4796
2943
4492
7534
7594
214
9900
012
1526
8697
2215
4192
68
TN50
7042
1340
5633
723
0704
239
4714
5439
4714
517
9595
120
7014
2220
7014
294
1915
UP(
E)18
4316
1511
0589
787
5502
4601
3048
3681
044
2185
620
2376
4671
1901
174
1128
822
UP(
W)
1096
6635
8773
3136
7382
2809
3193
2247
455
9411
2218
6586
3014
9269
062
5064
WB
2101
270
1681
0272
494
9024
659
7219
7331
1351
1445
7969
1156
638
4988
00
Tota
l UA
SL95
6541
449
8661
4015
3968
9106
1553
7152
7415
0138
210
6493
4366
6088
6568
958
7175
9825
6171
90
(`
in c
rore
)
Am
ount
of L
F/SU
CL
F Im
pact
SUC
Impa
ct
311.
91
29.5
5 13
.02
Report No. 4 of 2016
- 193 -
VodafoneA
NN
EX
UR
E-4
.10
[Par
a N
o.4.
6]St
atem
ent s
how
ing
inte
rest
on
LF
and
SUC
up
to M
arch
201
5
(A
mou
nt in
`)
No.
of M
onth
s(up
to M
arch
201
5)96
8472
60
R
ate@
(PLR
+2)%
14.2
514
.25
14.2
513
.75
Sl
No.
Pa
ra
No.
Issu
es20
06-0
720
07-0
820
08-0
920
09-1
0TO
TAL
Inte
rest
on
LF
Inte
rest
on
SUC
Inte
rest
on
LF
Inte
rest
on
SUC
Inte
rest
on
LF
Inte
rest
on
SUC
Inte
rest
on
LF
Inte
rest
on
SUC
14.
2.1
CO
MM
ISSI
ON
/ MA
RG
IN13
0593
259
6512
6371
4109
6811
020
0977
959
5978
5342
325
9517
506
4367
4198
918
6211
215
2287
9898
32
24.
2.3
Roa
min
g C
omm
issi
on86
9714
7338
9067
2215
4022
686
6956
4411
8287
5104
3599
7545
3600
8123
1557
9748
5199
2581
2
34.
2.4
Free
Tal
k tim
e72
6453
038
1082
457
1261
5133
9418
0911
7103
781
5215
1122
5879
5947
3133
5986
3615
3015
0
44.
2.5
Infr
astru
ctur
e re
venu
e 83
5265
8839
7427
7521
1444
722
9998
8124
3300
7422
714
4211
605
5716
2196
2419
8792
9903
4902
9
54.
2.6
Fore
x27
2467
4810
9001
0460
0590
7728
5051
8710
0500
484
4487
5170
1811
0884
5628
260
2958
2591
3
64.
2.7
Wai
vers
8586
3056
1886
1729
907
1008
206
2431
094
1118
042
2984
385
1330
905
1202
3057
74.
3.1
Inte
rest
Inco
me
7518
033
361
1245
3961
668
8147
5241
7568
293
1885
6420
320
8165
3638
8550
4634
137
3629
5384
84.
3.2
Fixe
d A
sset
s10
8664
251
0278
3948
567
1911
521
2229
9314
610
1233
038
2468
7007
1007
7815
3664
4801
4
94.
4B
ad D
ebt
-
-
14
6863
425
6729
7170
2011
1927
986
9835
3957
6007
1525
1299
1858
4994
046
TO
TAL
3376
2305
015
9592
322
1170
7022
6057
2009
139
2072
5188
3191
4651
771
2773
7448
8411
5453
8981
9155
3812
38
Say
` 91
5.54
cro
re
Report No. 4 of 2016
- 194 -
RCL/RTL
AN
NE
XU
RE
-5.0
1 [P
ara
No.
5.2.
2(A
)]Im
pact
on
paym
ent o
f LF
and
SUC
due
to n
on-c
onsi
dera
tion
of c
omm
issi
on/d
isco
unt
(Am
ount
in `
)
Serv
ices
/LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
(C
DM
A)
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
(C
DM
A)
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
(CD
MA
)
SUC
Im
pact
(G
SM)
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
(CD
MA
)
SUC
Im
pact
(G
SM)
AP
1767
9823
517
6798
2345
9214
719
6282
303
1962
8230
5419
847
2035
6584
220
3565
8456
9867
725
361
4193
4941
541
9349
4210
6233
8011
0578
7
Bih
ar62
1416
4637
2849
915
1449
590
8928
1654
5356
922
4822
299
2053
3959
5232
025
2200
5-
2294
0177
713
7641
0756
8662
7-
Che
nnai
5874
6163
5874
616
1252
895
6339
9508
6339
951
4237
92-
--
--
--
-
Del
hi20
9372
553
2093
7255
4750
150
2059
3347
320
5933
4746
1460
321
7400
744
2174
0074
4680
989
5699
459
6963
571
5969
6357
1001
9073
3224
257
Guj
arat
1267
6190
312
6761
9031
5530
613
1560
190
1315
6019
3540
360
1269
3744
812
6937
4533
0891
228
491
2909
5601
029
0956
0158
9720
518
9479
0
Har
yana
3308
0302
2646
424
8313
1841
2707
4933
0166
011
4737
443
0250
2034
4200
212
5608
518
232
1041
1754
983
2940
422
2214
478
8810
HP
5813
364
3488
0213
8671
1248
5763
7491
4634
7786
1154
3137
6925
8830
7443
-21
8494
5113
1096
760
5157
-
J&K
7022
9142
137
4240
4900
225
2940
1311
7897
7129
2742
776
1832
777
018
2180
3310
9308
281
2749
6253
Kar
nata
ka12
6675
446
1266
7545
3026
100
1494
4560
614
9445
6138
3187
315
7968
538
1579
6854
3881
727
3016
335
5712
929
3557
1293
6861
418
1746
519
Ker
ala
1328
9883
810
6319
0735
1438
315
2089
589
1216
7167
4758
059
1467
0730
811
7365
8545
4304
013
598
2444
8381
319
5587
0569
8503
740
9227
Kol
kata
8182
7171
8182
717
1752
889
9369
5073
9369
507
1945
762
9643
7834
9643
783
1912
094
-16
9077
997
1690
7800
3871
434
-
Mah
aras
htra
1609
5510
716
0955
1141
2365
616
7799
129
1677
9913
5034
158
1577
3001
915
7730
0244
8253
930
411
3900
4678
639
0046
7984
6301
027
0283
6
MP
7920
6130
6336
490
1997
926
1009
5261
680
7620
927
9010
110
8302
294
8664
184
3084
582
-23
0349
405
1842
7952
6485
861
-
Mum
bai
2309
7049
423
0970
4952
1137
424
9526
578
2495
2658
5967
511
2610
4604
326
1046
0458
6404
236
929
6332
7470
163
3274
7011
7541
9924
5895
4
Odi
sha
2454
0951
1472
457
6200
2730
9208
0718
5524
886
9994
2881
0844
1728
651
8312
35-
5890
8970
3534
538
1580
342
-
Punj
ab56
7324
8745
3859
914
0804
455
7660
7444
6128
615
0188
352
3376
9041
8701
514
0276
825
509
1296
2074
810
3696
6024
3144
911
4761
8
Raj
asth
an82
7559
7466
2047
821
7183
584
9947
2467
9957
824
4453
083
8051
9967
0441
624
1900
332
383
2071
2017
616
5696
1443
4268
717
3739
6
TN10
7831
631
1078
3163
3119
648
1341
5788
913
4157
8956
1892
319
2658
716
1926
5872
5348
682
1969
438
0020
109
3800
2011
9113
076
1121
629
UP(
E)10
9113
350
8729
068
3108
240
1238
4005
399
0720
439
2589
314
1689
685
1133
5175
4057
662
3825
036
4828
004
2918
6240
8089
038
2557
180
UP(
W)
8394
4255
6715
540
2347
843
9623
1465
7698
517
3253
446
1035
1228
082
8098
232
7231
134
066
2701
1739
721
6093
9261
4953
922
9997
0
WB
3166
3985
2533
119
8007
4343
5861
6834
8689
312
4832
547
6391
7138
1113
414
6543
8-
9741
2744
7793
019
2686
554
-
TOTA
L U
ASL
(R
CL
)19
8253
2273
1823
3739
149
4419
3122
2973
0800
2034
3046
761
0503
3922
8103
6076
2079
5234
560
3575
6239
0850
5211
8295
8547
5086
833
1138
7535
723
6912
27
(` in
cro
re)
Serv
ices
/Com
pany
Tota
l am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
UA
SL (R
CL
)1,
170.
5110
6.88
30.8
8
Report No. 4 of 2016
- 195 -
RCL/RTL
AN
NE
XU
RE
-5.0
2 [P
ara
No.
5.2.
2 (B
)Im
pact
on
paym
ent o
f LF
and
SUC
due
to n
on-c
onsi
dera
tion
of S
MS
cont
ent a
nd R
wor
ld(A
mou
nt in
`)
Serv
ices
/LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
(CD
MA
)A
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
(C
DM
A)
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
(CD
MA
)SU
C Im
pact
(G
SM)
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
(CD
MA
)SU
C Im
pact
(G
SM)
AP
9840
9848
9840
985
2556
092
1982
8412
219
8284
1254
7512
335
2817
483
3528
1748
9876
868
4395
622
2817
128
2228
1713
5644
627
5875
49
Bih
ar34
5894
2920
7536
684
3002
9181
9803
5509
188
2271
151
1719
4131
210
3164
7943
7110
5-
1218
9034
673
1342
130
2153
2-
Che
nnai
3269
9427
3269
943
6973
9064
0460
9964
0461
042
8114
--
--
--
--
Del
hi11
6541
442
1165
4144
2644
040
2080
3372
120
8033
7246
6166
637
6795
943
3767
9594
8113
026
9878
031
7190
637
3171
9064
5323
535
1713
177
Guj
arat
7055
8508
7055
851
1756
314
1329
0193
013
2901
9335
7646
722
0006
217
2200
0622
5734
960
4937
915
4596
573
1545
9657
3133
421
1006
778
Har
yana
1841
3235
1473
059
4627
3041
6916
5633
3533
211
5907
674
5703
6559
6562
921
7702
931
599
5532
1821
4425
746
1180
714
4191
26
HP
3235
848
1941
5177
188
1261
3101
7567
8635
1333
2000
6404
1200
384
5328
55-
1160
9488
6965
6932
1544
-
J&K
3909
1123
455
2360
4950
200
2970
1211
9099
1235
635
7413
831
764
1335
9679
970
5807
9843
1826
3679
Kar
nata
ka70
5103
8470
5103
816
8439
515
0969
753
1509
6975
3870
953
2737
8887
027
3788
8767
2775
552
278
1890
0451
618
9004
5236
4574
692
7996
Ker
ala
7397
4463
5917
957
1956
184
1536
4070
112
2912
5648
0658
525
4271
063
2034
1685
7873
934
2356
712
9904
035
1039
2323
3711
430
2174
39
Kol
kata
4554
6832
4554
683
9756
9794
6506
3894
6506
419
6560
716
7144
711
1671
4471
3314
015
-89
8379
0789
8379
120
5704
8-
Mah
aras
htra
8959
1209
8959
121
2295
319
1695
1045
816
9510
4650
8549
927
3375
473
2733
7547
7769
074
5270
720
7247
468
2072
4747
4496
736
1436
125
MP
4408
7902
3527
032
1112
090
1019
8219
981
5857
628
1855
618
7708
029
1501
6642
5346
154
-12
2393
858
9791
509
3446
197
-
Mum
bai
1285
6333
812
8563
3429
0076
725
2071
418
2520
7142
6028
372
4524
4136
745
2441
3710
1634
7564
004
3364
8419
433
6484
1962
4547
613
0654
1
Odi
sha
1366
0042
8196
0234
5121
3123
6159
1874
170
8788
6749
9345
5329
9607
314
4068
4-
3130
0693
1878
042
8396
99-
Punj
ab31
5785
7025
2628
678
3749
5633
4814
4506
785
1517
200
9071
0955
7256
876
2431
259
4421
268
8726
9155
0981
512
9192
660
9776
Raj
asth
an46
0638
2536
8510
612
0889
285
8615
5868
6892
524
6946
114
5250
004
1162
0000
4192
583
5612
511
0051
239
8804
099
2307
443
9231
48
TN60
0214
9660
0215
017
3646
613
5526
121
1355
2612
5676
229
3339
1340
533
3913
4092
7026
134
133
2019
1989
420
1919
8948
4214
259
5967
UP(
E)60
7349
2948
5879
417
3011
612
5103
057
1000
8245
3965
932
2455
7459
019
6459
6770
3268
466
295
1938
4772
015
5078
1842
9803
013
5873
2
UP(
W)
4672
5248
3738
020
1306
862
9721
2898
7777
032
3286
627
1794
0604
414
3524
8356
7152
459
042
1435
2418
411
4819
3532
6749
612
2206
6
WB
1762
4882
1409
991
4457
1144
0306
8935
2245
512
6105
682
5675
4866
0540
425
3987
7-
5175
9289
4140
743
1427
474
-
TOTA
L U
ASL
(RC
L)
1103
5217
6610
1493
066
2752
0484
2252
4710
9520
5505
188
6167
2972
3953
4599
7236
0420
109
1046
1088
667
7415
2769
2536
5125
2432
648
6050
6535
1258
8097
(` in
cro
re)
Serv
ices
/Com
pany
Tota
l am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
UA
SL (R
CL
)
1,00
7.87
91
.99
26
.76
Report No. 4 of 2016
- 196 -
RCL/RTL
AN
NE
XU
RE
-5.0
3 [P
ara
No.
5.2.
2 (C
)]Im
pact
on
paym
ent o
f LF
and
SUC
due
to n
on-c
onsi
dera
tion
of r
even
ue fr
om C
RB
T(A
mou
nt in
`)
Serv
ices
/LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
-pa
ct
SUC
Im
pact
(C
DM
A)
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
(C
DM
A)
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
(C
DM
A)
SUC
Im
pact
(G
SM)
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
(C
DM
A)
SUC
Im
pact
(G
SM)
AP
2561
8822
2561
882
6654
2211
0043
569
1100
4357
3038
579
1617
7273
716
1772
7445
2871
020
155
1656
1588
916
5615
8941
9554
843
6714
Bih
ar90
0459
154
0275
2194
5750
9580
8330
5748
512
6044
278
8379
7747
3027
920
0422
5-
9059
8861
5435
932
2245
850
-
Che
nnai
8512
571
8512
5718
1550
3554
4254
3554
425
2375
94-
--
--
--
-
Del
hi30
3389
8030
3389
868
8317
1154
5439
311
5454
3925
8712
817
2767
263
1727
6726
3719
958
4529
223
5761
990
2357
6199
3956
886
1273
373
Guj
arat
1836
8343
1836
834
4572
1773
7578
1073
7578
119
8486
510
0876
543
1008
7654
2629
575
2264
111
4908
800
1149
0880
2329
015
7483
20
Har
yana
4793
478
3834
7812
0461
2313
8003
1851
040
6432
6334
1917
6427
3534
199
8204
1448
941
1196
9632
8957
687
7603
3115
29
HP
8423
8150
543
2009
470
0000
942
0001
1949
8391
7327
255
0396
2443
23-
8629
120
5177
4723
8998
-
J&K
1017
6561
0661
427
4725
816
4836
6609
756
6559
3399
414
564
612
7194
945
4316
9732
1019
5988
Kar
nata
ka18
3558
1518
3558
143
8495
8378
5076
8378
508
2148
299
1255
3679
212
5536
7930
8478
923
970
1404
8359
414
0483
5927
0981
668
9762
Ker
ala
1925
7611
1540
609
5092
4985
2673
9768
2139
226
6755
511
6587
550
9327
004
3610
331
1080
696
5552
8977
2442
327
5863
816
1618
Kol
kata
1185
7108
1185
711
2540
0152
5291
3852
5291
410
9087
176
6386
5576
6386
515
1953
2
6677
4870
6677
487
1528
966
-
Mah
aras
htra
2332
3085
2332
308
5975
3594
0747
8294
0747
828
2234
712
5347
242
1253
4724
3562
251
2416
715
4043
246
1540
4325
3342
341
1067
445
MP
1147
7308
9181
8528
9508
5659
8002
4527
840
1564
240
8606
7281
6885
383
2451
301
-90
9731
1272
7784
925
6149
5-
Mum
bai
3346
8614
3346
861
7551
5013
9894
400
1398
9440
3345
621
2074
5196
020
7451
9646
6012
429
347
2501
0253
725
0102
5446
4214
897
1128
Odi
sha
3556
089
2133
6589
845
1733
5419
1040
125
4877
5322
8958
3113
7375
066
0578
-23
2652
3213
9591
462
4133
-
Punj
ab82
2078
065
7662
2040
3231
2646
5125
0117
284
2015
4159
2495
3327
400
1114
773
2027
251
1918
0940
9534
596
0265
4532
35
Raj
asth
an11
9916
9595
9336
3147
0847
6513
8138
1211
013
7049
966
5995
6453
2796
519
2237
025
734
8179
9070
6543
926
1715
080
6861
59
TN15
6252
6515
6252
745
2050
7521
4182
7521
418
3150
189
1531
0490
015
3104
9042
5057
015
651
1500
8335
815
0083
3635
9907
644
2971
UP(
E)15
8109
9212
6487
945
0397
6942
9598
5554
368
2201
010
1126
0007
190
0800
632
2460
330
397
1440
8345
911
5266
7731
9464
710
0992
1
UP(
W)
1216
3882
9731
1134
0212
5395
1139
4316
091
1824
010
8226
0682
6580
855
2600
489
2707
210
6678
896
8534
312
2428
670
9083
39
WB
4588
247
3670
6011
6031
2443
6118
1954
889
6998
6037
8586
0630
2868
911
6457
6-
3847
1732
3077
739
1061
015
-
TOTA
L U
ASL
(R
CL
)28
7277
422
2642
1469
7164
348
1250
0746
6211
4051
110
3422
7218
1812
7277
4516
5258
669
4796
5847
3106
0620
5833
5505
1876
2856
344
9733
9993
5650
2
(`
in c
rore
)
Serv
ices
/Com
pany
Tota
l am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
UA
SL (R
CL
)
54
0.84
49.3
4
14.4
0
Report No. 4 of 2016
- 197 -
RCL/RTL
AN
NE
XU
RE
5.0
4 [P
ara
No.
5.2.
2 (D
)]Im
pact
on
paym
ent o
f LF
and
SUC
due
to n
on-c
onsi
dera
tion
of sa
le o
f SIM
car
ds(A
mou
nt in
`)
Serv
ices
/LSA
2008
-09
2009
-10
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ct
(CD
MA
)SU
C Im
pact
(G
SM)
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ct
(CD
MA
)SU
C Im
pact
(G
SM)
AP
3185
9952
3185
995
3199
1838
1354
5428
4565
5428
457
4453
1360
0394
Bih
ar15
5265
6193
1594
1415
83-
2969
5941
1781
756
2383
73-
Del
hi34
0252
4434
0252
426
2786
8569
9977
2766
2677
2766
341
9981
1750
629
Guj
arat
1986
6894
1986
689
1857
5942
8406
3766
4105
3766
411
2472
0010
2878
8
Har
yana
6733
817
5387
0570
515
2741
4913
4779
6310
7823
793
148
4282
89
HP
1806
609
1083
9717
260
-28
2840
016
9704
2536
7-
J&K
1115
8066
9510
2911
583
2358
315
1414
9934
126
9443
Kar
nata
ka24
7235
4924
7235
521
7916
4535
5446
0468
5546
0468
528
7618
9482
83
Ker
ala
2296
1062
1836
885
2550
4220
4465
3164
8303
2531
864
2928
0022
2192
Kol
kata
1509
3420
1509
342
1073
43-
2188
7059
2188
706
1622
83-
Mah
aras
htra
2468
6219
2468
622
2516
4545
7280
5049
1355
5049
135
3547
5414
6752
1
MP
1695
0319
1356
026
1731
65-
2981
8611
2385
489
2718
75-
Mum
bai
4085
6140
4085
614
3292
0155
5290
8197
7083
8197
708
4927
1513
3510
4
Odi
sha
4509
166
2705
5046
665
-76
2573
645
7544
6624
5-
Punj
ab81
9133
665
5307
7875
038
3576
1677
9339
1342
347
1019
2262
3106
Raj
asth
an13
1162
9510
4930
413
5800
4869
3226
8116
0021
4492
818
2038
9433
30
TN30
1528
8630
1528
930
0270
2961
3349
1934
0749
1934
138
2004
6089
95
UP(
E)22
1757
5717
7406
122
7793
5751
6047
2267
9737
7814
433
9078
1388
436
UP(
W)
1620
0637
1296
051
1837
0451
2241
3496
6557
2797
325
2577
7712
4878
2
WB
7455
974
5964
7882
268
-12
6100
2910
0880
211
2615
-
TOTA
L U
ASL
(R
CL
)35
7003
416
3254
6481
3388
414
5877
122
6746
6864
661
4997
4547
7344
812
8632
94
(` in
cro
re)
Serv
ices
/Com
pany
Tota
l am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
UA
SL (R
CL
)
10
3.17
9.4
0
2.6
9
Report No. 4 of 2016
- 198 -
RCL/RTL
AN
NE
XU
RE
-5.0
5 [P
ara
5.2.
2 (E
)]Im
pact
on
paym
ent o
f LF
and
SUC
due
to n
on-c
onsi
dera
tion
of sa
le o
f Han
dset
s(A
mou
nt in
`)
Serv
ices
/LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
(C
DM
A)
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
(C
DM
A)
Am
ount
of
GR
/AG
RL
F Im
-pa
ct
SUC
Im
pact
(C
DM
A)
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
(C
DM
A)
AP
1660
3126
6316
6031
266
4312
4863
5238
0943
052
3809
4314
4636
9434
6962
1134
6962
197
7847
2272
2835
2272
284
6974
89
Bih
ar58
3572
348
3501
4341
1422
2630
2425
6142
114
5536
8559
9972
516
9087
7710
1452
743
2756
1243
0347
7458
2137
3361
Che
nnai
5516
8536
655
1685
3711
7659
4416
9191
310
1691
9131
1130
954
--
--
--
Del
hi19
6621
8167
1966
2181
744
6086
7154
9565
056
5495
6506
1231
4776
3705
4263
3705
426
8032
2032
3470
2232
3470
265
7813
Guj
arat
1190
4213
4411
9042
134
2963
1488
3510
8854
635
1088
5594
4799
321
6354
9921
6355
056
7782
1576
5720
1576
572
3871
87
Har
yana
3106
5719
924
8525
7678
0690
511
0137
323
8810
986
3061
944
7333
279
5866
6221
5534
5641
706
4513
3614
5897
HP
5459
3312
3275
599
1302
264
3332
0173
1999
210
9281
2019
6743
811
8046
5275
511
8393
371
036
3973
2
J&K
6595
216
3957
1339
817
1307
7001
7846
2031
4625
1215
1372
9131
4598
7161
5923
053
4
Kar
nata
ka11
8960
9429
1189
6094
328
4181
0939
8818
520
3988
1852
1022
5942
2692
4506
2692
451
6660
7319
2746
3419
2746
345
0494
Ker
ala
1248
0533
1699
8442
6533
0035
7940
5874
395
3246
9952
1269
7609
2500
5117
2000
409
7795
4913
2475
8110
5980
645
8610
Kol
kata
7684
3917
176
8439
1716
4613
8925
0039
672
2500
3967
5192
566
1643
7077
1643
708
3281
0091
6164
791
6165
2541
83
Mah
aras
htra
1511
5298
0815
1152
981
3872
5262
4477
9771
244
7797
7113
4344
2226
8838
5326
8838
576
9167
2113
5045
2113
505
5556
48
MP
7438
2496
659
5059
9718
7625
2926
9407
539
2155
2603
7445
811
1845
9282
1476
743
5292
8912
4816
9599
8536
4258
36
Mum
bai
2169
0444
8421
6904
448
4894
0024
6658
9994
466
5899
9415
9252
1944
4932
6444
4932
610
0622
234
3145
7434
3145
777
1734
Odi
sha
2304
6412
913
8278
4858
2267
682
5169
1749
5101
523
2171
249
1058
429
4635
1426
3331
9203
719
1522
1037
59
Punj
ab53
2774
924
4262
1994
1322
2947
1488
2032
111
9056
2640
0800
689
2055
171
3644
2407
0470
2362
056
1890
1596
39
Raj
asth
an77
7161
562
6217
2925
2039
5707
2268
2145
818
1457
1765
2360
314
2839
4311
4271
541
5081
1122
2998
8978
4028
5124
TN10
1264
7118
1012
6471
229
2966
2235
8020
902
3580
2090
1499
4958
3283
7177
3283
718
9177
9020
5917
4120
5917
459
8328
UP(
E)10
2468
3739
8197
4699
2918
9494
3304
8617
526
4388
9410
4768
4724
1499
0319
3199
269
6262
1976
8542
1581
483
5310
94
UP(
W)
7883
2070
463
0656
5622
0485
9725
6808
423
2054
4674
8682
321
1764
2862
1411
429
5615
0214
6365
6111
7092
540
3754
WB
2973
5656
223
7885
2575
1977
911
6316
374
9305
310
3331
345
8119
725
6495
7825
1457
5278
399
4222
7217
6388
TOTA
L U
ASL
(R
CL
)18
6179
6552
617
1233
0893
4643
0929
759
5037
8614
5428
8540
116
2922
194
3887
8482
435
4438
5710
3568
6728
2407
799
2574
3019
7476
604
(` in
cro
re)
Serv
ices
/Com
pany
Tota
l am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
UA
SL (R
CL
)2,
523.
95
231.
64
64.5
1
Report No. 4 of 2016
- 199 -
RCL/RTL
AN
NE
XU
RE
-5.0
6 [P
ara
No.
5.2.
2(F)
]Im
pact
on
paym
ent o
f LF
and
SUC
due
to n
on-c
onsi
dera
tion
of' U
p-fr
ont c
harg
es' i
n re
spec
t of F
ixed
Wir
eles
s Pho
ne/T
erm
inal
(FW
P/T
)(A
mou
nt in
`)
Serv
ices
/LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
(CD
MA
)A
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
(C
DM
A)
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
(CD
MA
)A
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
(C
DM
A)
AP
8054
0981
8054
098
2091
967
5797
0688
5797
069
1600
716
5299
9479
5299
948
1493
690
2633
8958
2633
896
8084
88
Bih
ar28
3088
1816
9852
968
9933
2684
4596
1610
676
6639
9825
8286
5215
4971
966
1047
1440
8518
8645
1143
2778
Che
nnai
2676
1996
2676
200
5707
6018
7246
2818
7246
312
5164
--
--
--
Del
hi95
3803
1295
3803
121
6394
560
8210
9760
8211
013
6289
356
6014
7256
6014
712
2694
237
4947
4237
4947
476
2497
Guj
arat
5774
6775
5774
678
1437
409
3885
5437
3885
544
1045
622
3304
8858
3304
886
8673
0418
2746
8418
2746
844
8804
Har
yana
1506
9834
1205
587
3787
0912
1890
4497
5124
3388
6911
2017
9989
6144
3292
3465
3952
952
3162
1691
15
HP
2648
296
1588
9863
172
3687
588
2212
5510
2716
3005
319
1803
1980
584
1372
344
8234
146
055
J&K
3199
3119
196
1931
1447
249
8683
534
820
1856
1411
137
4804
1144
258
6865
561
9
Kar
nata
ka57
7073
9057
7073
913
7854
944
1377
7744
1377
811
3171
941
1279
7241
1279
710
1744
622
3420
0722
3420
152
2185
Ker
ala
6054
2475
4843
398
1600
988
4491
8660
3593
493
1405
261
3819
6049
3055
684
1190
784
1535
5807
1228
465
5315
93
Kol
kata
3727
6620
3727
662
7985
3427
6722
2427
6722
257
4668
2510
8117
2510
812
5011
8210
6196
3610
6196
429
4634
Mah
aras
htra
7332
3595
7332
359
1878
544
4955
8370
4955
837
1486
805
4106
5872
4106
587
1174
925
2449
8486
2449
849
6440
74
MP
3608
2597
2886
608
9101
6129
8156
9123
8525
582
4038
2819
7094
2255
768
8085
0514
4680
3811
5744
349
3604
Mum
bai
1052
1932
010
5219
3223
7405
773
6960
3473
6960
317
6246
567
9647
6467
9647
615
3703
339
7754
1139
7754
189
4548
Odi
sha
1117
9706
6707
8228
2455
9132
257
5479
3525
6947
7501
061
4500
6421
7876
3700
019
2220
0112
0271
Punj
ab25
8446
5920
6757
364
1439
1647
0143
1317
611
4435
7113
6264
0410
9011
236
7682
8141
362
6513
0918
5044
Raj
asth
an37
6997
3930
1597
998
9386
2510
2633
2008
211
7219
7621
8191
4217
4553
163
4049
1300
9031
1040
722
3304
98
TN49
1230
3249
1230
314
2116
539
6226
5039
6226
516
5951
250
1597
5050
1597
514
0195
223
8687
1923
8687
269
3547
UP(
E)49
7069
2339
7655
414
1596
936
5753
4529
2602
811
5948
736
8896
8429
5117
510
6356
022
9145
1718
3316
161
5613
UP(
W)
3824
1064
3059
285
1069
567
2842
1330
2273
706
9608
8426
9499
8821
5599
985
7711
1696
5829
1357
266
4680
08
WB
1442
4626
1153
970
3647
8112
8728
8810
2983
136
8684
1240
3119
9922
4938
4108
6118
406
4894
7320
4459
TOTA
L U
ASL
(R
CL
)90
3148
686
8306
4360
2252
3424
6585
3633
160
0818
5118
0308
1659
3880
208
5414
1529
1582
0418
3273
5030
329
8397
7486
6643
4
(` in
cro
re)
Serv
ices
/C
ompa
nyTo
tal a
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
UA
SL (R
CL
)24
8.29
22.7
16.
50
Report No. 4 of 2016
- 200 -
RCL/RTL
AN
NE
XU
RE
-5.0
7 [P
ara
No.
5.2.
3]Im
pact
on
paym
ent o
f LF
and
SUC
due
to n
ettin
g of
com
mis
sion
pai
d on
Bro
adba
nd p
re-p
aid
vouc
hers
(Am
ount
in `
)
Serv
ices
/LSA
2008
-09
2009
-10
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ct
(CD
MA
)SU
C Im
pact
(G
SM)
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ct
(CD
MA
)SU
C Im
pact
(G
SM)
AP
1498
2714
983
4018
2531
3655
3136
669
8913
70
Del
hi49
366
4937
1152
820
285
2029
393
90
Guj
arat
2323
9823
240
6233
3944
4976
4449
899
1519
43
Kar
nata
ka11
3559
1135
630
4619
2112
3321
123
4707
923
Ker
ala
1588
3812
707
4575
2861
5900
449
2720
1474
0829
051
Mah
aras
htra
3510
135
1010
116
8999
990
0021
5439
3
MP
2888
723
1178
00
8475
967
8122
89-
Mum
bai
2028
720
2951
44
2885
288
6114
Punj
ab16
9133
1353
145
3628
5682
745
4612
6624
8
Raj
asth
an10
2813
8225
2757
1828
3107
2264
963
0913
35
TN29
7083
2970
879
6852
4499
5844
996
1002
621
22
UP(
E)21
2592
1700
757
0237
8518
1968
146
1898
140
18
UP(
W)
--
--
-425
4-
--
WB
3027
3424
219
8779
-30
6162
2449
382
66-
TOTA
L U
ASL
(RC
L)
1872
617
1677
6251
071
264
9270
416
7726
3321
8765
4150
9
(` in
cro
re)
Serv
ices
/Com
pany
Tota
l am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
UA
SL (R
CL
)
1.
11
0
.09
0
.03
Report No. 4 of 2016
- 201 -
RCL/RTL
AN
NE
XU
RE
-5.0
8 (P
ara
5.2.
4)Im
pact
on
paym
ent o
f LF
and
SUC
due
to N
ettin
g of
Rev
enue
with
Exp
ense
s by
RC
L du
ring
the
peri
od 2
006-
07 to
200
9-10
(Am
ount
in `
)
Serv
ices
/LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
-pa
ct
SUC
Im
pact
(C
DM
A)
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
(C
DM
A)
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
(C
DM
A)
SUC
Im
pact
(G
SM)
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
(C
DM
A)
SUC
Im
pact
(G
SM)
AP
4360
0043
600
1107
413
3328
013
3328
3599
920
4600
020
4600
5487
234
319
4000
019
4000
4322
984
73
Che
nnai
--
-77
6794
7767
918
255
--
--
--
--
Del
hi21
2510
2125
148
6652
2958
5229
612
290
7363
4673
635
1718
812
650
9992
5099
998
9122
72
Guj
arat
--
-21
8400
021
8400
6098
818
0438
818
0439
4839
230
217
5800
017
5800
3917
476
78
Har
yana
--
-18
2000
1456
047
3244
3000
3544
011
881
7420
8000
1664
046
3590
8
HP
--
--
--
2600
0015
600
7020
--
--
-
Kar
nata
ka77
2000
7720
019
223
4000
0040
000
1080
073
2000
7320
019
632
123
5760
0057
600
1283
525
16
Ker
ala
4080
0032
640
1040
412
2000
097
600
3650
910
6146
784
917
3057
618
599
3400
7947
223
776
4686
Kol
kata
8800
088
0020
1570
2000
7020
016
497
6040
0060
400
1419
40
4495
5044
955
1056
4-
Mah
aras
htra
4000
0040
000
1032
011
3713
511
3714
3454
018
4311
618
4312
5309
230
911
7371
311
7371
2809
151
26
MP
--
-67
5857
5406
918
248
7410
6759
285
2000
9-
7812
6462
501
2109
4-
Mum
bai
--
-10
8000
1080
027
5441
2000
4120
010
436
7425
1090
025
1090
5284
212
282
Odi
sha
--
-27
9000
1674
075
3332
0000
1920
086
40-
3080
0018
480
8316
-
Punj
ab-
--
5401
3043
210
1458
413
1700
010
5360
3532
122
168
0000
5440
015
153
2970
Raj
asth
an-
--
1006
4580
5227
1780
0064
021
5-
--
--
TN68
8000
6880
019
058
1309
592
1309
5939
975
2351
366
2351
3763
062
410
2079
137
2079
1446
330
9807
UP(
W)
4400
035
2011
6674
2133
5937
123
377
5476
6843
813
1577
695
3237
4225
899
7748
1527
WB
--
-14
4000
1152
038
8856
000
4480
1624
-16
000
1280
432
-
TOTA
L U
ASL
(R
CL
)30
4851
029
5811
7812
612
3575
2411
5249
734
3685
1528
3418
1421
658
4119
2822
6014
3076
9813
5840
232
4110
5824
5
(` in
cro
re)
Serv
ices
/Com
pany
Tota
l am
ount
of
GR
/AG
RL
F Im
-pa
ctSU
C Im
pact
UA
SL (R
CL
)
4.5
0
0.42
0
.12
Report No. 4 of 2016
- 202 -
RCL/RTL
AN
NE
XU
RE
-5.0
9 [P
ara
No.
5.2
.5]
Impa
ct o
n pa
ymen
t of L
F an
d SU
C d
ue to
Net
ting
of d
isco
unt g
iven
to d
istr
ibut
ors/
dea
lers
/ fra
nchi
sees
from
the
reve
nue
on sa
le o
f pre
paid
pro
duct
s(A
mou
nt in
`)
Serv
ices
/LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C
Impa
ct
Ass
am20
9725
5110
4862
872
1456
1199
2926
859
9646
341
3756
017
6458
945
1058
7537
6087
834
2097
0870
012
5825
2272
3495
0
Bih
ar15
4612
678
7730
634
5952
588
2279
6969
911
3984
8510
0306
6727
6767
543
1660
6053
1203
9388
2633
5315
315
8011
8911
4558
62
HP
2459
6701
1229
835
8190
7060
7216
8930
3608
420
3417
795
4298
0857
2578
831
9689
994
4837
5856
6902
531
6520
6
Kol
katta
7860
4313
7860
431
2578
221
6709
7396
6709
740
2200
795
8271
0464
8271
046
2688
090
2214
5623
422
1456
2371
9732
8
MP
9520
9326
5712
560
3275
201
1207
0124
472
4207
540
4349
215
9749
080
1277
9926
5351
594
2420
4147
619
3633
1881
0838
9
NE
1841
1251
9205
6361
4936
5470
2210
2735
111
1832
524
7226
3620
4335
817
2420
831
4814
8463
2888
908
1612
974
Odi
sha
8110
4376
4055
219
2708
886
1244
9013
662
2450
741
7042
018
1909
841
1091
4590
6093
980
2007
0570
912
0423
4367
2364
1
WB
6951
4327
4170
860
2307
876
7143
6183
4286
171
2421
687
9108
7697
7287
016
3051
438
1235
9708
298
8776
741
4050
2
TOTA
L U
ASL
(R
TL
)54
3025
523
3272
8728
1897
8234
8470
4782
547
6286
3530
8713
2011
3637
6998
7650
7774
4093
0053
1403
4945
7510
0380
695
4963
8852
(` in
cro
re)
Serv
ices
/Com
pany
Tota
l am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
UA
SL (R
TL
)
3
92.9
9
25.
72
14.
04
Report No. 4 of 2016
- 203 -
RCL/RTL
AN
NE
XU
RE
-5.1
0 [P
ara
No.
5.2
.6]
Impa
ct o
n pa
ymen
t of L
F an
d SU
C d
ue to
non
con
side
ratio
n of
Fre
e of
Cha
rge
Rec
harg
e vo
uche
rs d
istr
ibut
ed to
Dis
trib
utor
s in
GR
(Am
ount
in `
)
Serv
ices
/LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im-
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
-pa
ctA
mou
nt o
f G
R/A
GR
LF
Im-
pact
SUC
Im
pact
Ass
am18
2884
4591
4422
6291
2317
0920
8685
4604
5896
7717
0079
3510
2047
658
6774
--
-
Bih
ar41
6580
7520
8290
416
0383
632
2796
9416
1398
514
2030
714
7014
5188
2087
6395
1329
239
1754
1272
HP
7421
4137
107
2471
323
3398
8711
6699
478
1886
1611
4826
9668
9053
9847
--
-
Kol
katta
--
-16
5807
3616
5807
454
3848
5421
6536
5421
654
1762
037
1556
539
1556
5450
588
MP
1209
9607
272
5976
441
6226
516
9995
186
1019
9711
5694
839
1520
6522
812
1652
1850
9418
5-
--
NE
8505
795
4252
9028
4094
7123
273
3561
6423
8630
3984
661
2390
8013
3486
--
-
Odi
sha
2296
6197
1148
310
7670
7118
2298
8591
1494
6107
0128
2757
9116
9654
794
7239
1912
622
1147
5764
073
WB
3655
5678
2193
341
1213
648
2142
5749
1285
545
7263
3327
5484
5522
0387
692
2873
--
-
TOTA
L U
ASL
(RT
L)
2497
1240
314
0611
3886
8475
030
6066
495
1804
6571
1060
6220
3139
1488
424
5958
2810
6259
5534
9840
027
2166
1159
32
(` in
cro
re)
Serv
ices
/Com
pany
Tota
l am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
UA
SL (R
TL
)
8
7.32
5.70
3.00
Report No. 4 of 2016
- 204 -
RCL/RTL
AN
NE
XU
RE
-5.1
1 [P
ara
No.
5.3
.1]
Impa
ct o
n pa
ymen
t of L
F an
d SU
C d
ue to
For
ex g
ains
not
con
side
red
for
GR
RC
L(A
mou
nt in
`)
Serv
ices
/LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
(C
DM
A)
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
(C
DM
A)
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
(C
DM
A)
SUC
Im
pact
(G
SM)
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
(C
DM
A)
SUC
Im
pact
(G
SM)
AP
5874
8057
5874
806
1492
201
1172
4044
911
7240
4531
6549
226
1347
961
2613
4796
7009
117
4377
630
3236
325
3032
3633
6757
045
1324
385
Bih
ar20
6489
6712
3893
848
1121
5429
0756
3257
445
1248
687
1273
6475
276
4188
529
2938
9-
1658
8303
199
5298
243
5294
4-
Che
nnai
1952
0687
1952
069
4470
2437
8688
5937
8688
688
9918
--
--
--
--
Del
hi69
5721
3569
5721
315
9320
212
3005
144
1230
0514
2890
621
2791
0989
727
9109
9065
1513
747
686
4316
7113
843
1671
1483
7206
719
2303
0
Guj
arat
4212
1549
4212
155
1069
887
7858
1592
7858
159
2192
426
1629
6861
416
2968
6143
7067
227
297
2103
9359
521
0393
6046
8822
291
8894
Har
yana
1099
2211
8793
7726
4912
2465
1235
1972
099
6409
3255
2376
6244
1901
314
8142
492
5275
2885
8260
2308
716
7766
332
8823
HP
1931
715
1159
0348
100
7457
812
4474
6920
1361
1481
9654
8891
7940
0131
-15
7995
8694
7975
4867
02-
J&K
2333
6314
002
5064
2926
930
1756
1665
271
9152
9154
917
2272
915
313
1736
6779
0420
2718
0657
536
Kar
nata
ka42
0928
2042
0928
210
4811
189
2646
4489
2646
424
1014
520
2807
872
2028
0787
5439
125
3397
025
7220
059
2572
2006
5731
660
1123
409
Ker
ala
4416
0783
3532
863
1126
100
9084
3910
7267
513
2716
233
1883
5014
415
0680
1254
2555
832
811
1767
8902
214
1431
2242
3121
583
3896
Kol
kata
2719
0245
2719
024
6226
5755
9645
5855
9645
613
1516
712
3811
691
1238
1169
2909
575
-12
2262
220
1222
6222
3278
034
-
Mah
aras
htra
5348
3564
5348
356
1379
876
1002
2730
010
0227
3030
4691
020
2501
650
2025
0165
5833
202
3391
928
2047
261
2820
4726
6750
435
1231
841
MP
2631
9303
2105
544
6553
5160
2995
2748
2396
216
2808
713
9043
876
1112
3510
3754
185
-16
6568
271
1332
5462
5131
086
-
Mum
bai
7674
8887
7674
889
1818
949
1490
4353
414
9043
5338
0061
033
5143
904
3351
4390
8488
910
5995
445
7928
129
4579
2813
9637
166
2240
001
Oris
sa81
5468
148
9281
2030
5218
4691
6011
0815
049
8667
3698
8795
2219
328
9986
97-
4259
7745
2555
865
1312
211
-
Punj
ab18
8515
6515
0812
546
9404
3330
9369
2664
749
8993
5367
1937
3153
7549
918
0207
511
255
9373
0235
7498
419
2088
600
4093
67
Raj
asth
an27
4988
7621
9991
068
4722
5076
7795
4061
424
1370
730
1075
9328
686
0746
328
8555
518
743
1497
7095
111
9816
7633
3736
170
6455
TN35
8312
3335
8312
399
2525
8013
3211
8013
321
2444
063
2473
4485
024
7344
8566
3356
643
087
2747
9685
727
4796
8661
2332
612
9618
9
UPE
3625
7134
2900
571
1004
323
7397
0313
5917
625
2256
095
1819
0827
114
5526
6248
7861
631
688
2638
1127
421
1049
0258
7853
312
4437
1
UPW
2789
3728
2231
498
7391
8457
4795
5945
9836
518
1060
613
2894
218
1063
1537
3828
111
2315
019
5324
957
1562
5997
4674
849
9213
28
WB
1052
1585
8417
2726
1987
2603
4247
2082
740
7029
2561
1615
3948
9292
317
7368
5-
7044
0261
5635
221
2169
891
-
TOTA
L U
ASL
(R
CL
)65
8773
084
6058
8656
1640
7750
1331
8299
0212
1510
085
3619
4300
2928
5076
5926
6979
572
7737
9458
4167
4237
6873
3169
3435
4068
586
9508
1614
5595
26
NL
D11
6745
735
7004
744
-25
9264
025
1555
5842
-71
8644
776
4311
8687
--
1282
2285
2376
9337
11-
-
ILD
1438
0076
586
2804
6-
2196
2750
813
1776
50-
4487
4337
926
9246
03-
-42
2457
709
2534
7463
--
GR
AN
D
TOTA
L91
9319
584
7622
1446
1640
7750
1810
7214
3615
0243
577
3619
4300
4095
8958
1433
7022
861
7737
9458
4167
4254
7341
9401
4458
2185
986
9508
1614
5595
26
Con
td…
….
Report No. 4 of 2016
- 205 -
RCL/RTLR
TL
(Am
ount
in `
)
Serv
ices
/LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
Ass
am22
0140
1100
775
7364
3952
7232
1976
422
2163
713
2370
0879
4220
4566
7789
9848
5153
9909
131
0447
7
Bih
ar42
2006
2110
016
247
9770
1897
4885
095
4298
883
2002
4881
1201
493
8710
8212
0666
858
7240
011
5249
008
HP
5062
125
3116
8620
0357
2810
0178
667
1197
4991
863
2995
1216
7227
3074
0898
1844
454
1029
820
Kol
katta
--
-15
1192
1115
1192
149
5910
3005
801
3005
8097
689
4882
0315
4882
032
1586
660
MP
3409
2420
455
1172
867
5374
0640
5224
422
6250
314
6876
3811
7501
149
2036
1414
5524
311
3164
1947
3875
1
NE
8040
540
2026
8625
2479
7412
6239
984
5807
4896
408
2937
8516
4030
2031
7260
1219
036
6806
28
Odi
sha
1890
2194
5163
1345
9121
2822
9560
615
3805
611
1391
6166
8350
3731
6276
1455
5845
6873
325
5087
6
WB
2069
7412
418
6872
3371
3254
2022
795
1142
879
7154
340
5723
4723
9670
6077
5109
4862
009
2035
966
TOTA
L U
ASL
(R
TL
)15
1009
280
984
5310
436
9662
870
2025
1611
1347
6873
7913
7100
5305
298
2861
573
5889
0609
241
3317
8520
9761
87
(`
in c
rore
)
Serv
ices
/Com
pany
Tota
l am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
UA
SL (R
CL
)
8
68.7
8
79.2
6
23.1
9
UA
SL (R
TL
)
1
03.9
2
6.7
0
3.7
4
NL
D
2
37.6
9
14.2
6
-
ILD
123
.46
7
.41
-
GR
AN
D T
OTA
L
1,3
33.8
6
1
07.6
3
26.9
3
Report No. 4 of 2016
- 206 -
RCL/RTL
AN
NE
XU
RE
-5.1
2 (i)
[Par
a N
o. 5
.3.2
]Im
pact
on
paym
ent o
f LF
and
SUC
due
to In
tere
st in
com
e no
t con
side
red
for
GR
RC
L (A
mou
nt in
`)
Serv
ices
/LSA
2006
-07
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
(CD
MA
)A
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
(C
DM
A)
SUC
Impa
ct
(GSM
)A
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
(C
DM
A)
SUC
Impa
ct
(GSM
)
AP
5212
6744
5212
674
1324
019
3642
4198
936
4241
9997
6864
261
011
3197
2679
831
9726
8071
2450
413
9640
7
Bih
ar18
3216
8610
9930
142
6895
1775
0890
710
6505
3440
8270
5-
1749
0401
310
4942
4140
2279
2-
Che
nnai
1732
0570
1732
057
3966
41-
--
--
--
-
Del
hi61
7308
7461
7308
714
1363
738
8996
890
3889
9689
9080
179
6646
045
5146
100
4551
4610
8827
354
2027
608
Guj
arat
3737
4159
3737
416
9493
0422
7130
191
2271
3019
6091
427
3804
422
1835
133
2218
3513
4943
174
9688
65
Har
yana
9753
313
7802
6523
5055
7698
5012
6158
801
2064
669
1289
579
3828
9563
5063
217
6889
734
6705
HP
1713
997
1028
4042
679
2065
4227
1239
254
5576
64-
1665
8793
9995
2844
9787
-
J&K
2070
6212
424
4493
1275
646
7653
931
677
214
1389
0072
8334
0428
6587
6066
5
Kar
nata
ka37
3486
6837
3486
792
9982
2826
5436
828
2654
3775
8053
647
345
2712
0809
427
1208
0960
4335
711
8450
1
Ker
ala
3918
3557
3134
685
9991
8126
2504
559
2100
0365
7561
628
4572
818
6403
090
1491
2247
4461
316
8792
45
Kol
kata
2412
5716
2412
572
5524
7917
2556
987
1725
5699
4055
089
-12
8911
034
1289
1103
3029
409
-
Mah
aras
htra
4745
5597
4745
560
1224
354
2822
2758
528
2227
5881
2976
347
273
2973
8543
929
7385
4471
1753
412
9883
1
MP
2335
2935
1868
235
5814
8819
3786
161
1550
2893
5232
226
17
5626
518
1405
0121
4741
916
-
Mum
bai
6809
8756
6809
876
1613
941
4670
9177
246
7091
7711
8310
3883
558
4828
3098
848
2830
9910
1612
5123
6181
6
Odi
sha
7235
592
4341
3618
0166
5155
1473
3093
088
1391
890
-44
9142
7826
9485
712
1268
6-
Punj
ab16
7268
6313
3814
941
6499
9364
8247
7491
860
2511
562
1568
698
8274
3479
0619
522
0218
243
1629
Raj
asth
an24
3995
6219
5196
560
7549
1499
5331
311
9962
6540
2161
326
122
1579
1573
412
6332
5935
1885
274
4873
TN31
7928
0531
7928
188
0661
3447
2578
234
4725
7892
4523
560
051
2897
4074
728
9740
7564
5632
213
6667
8
UPE
3217
0704
2573
656
8911
2925
3526
487
2028
2119
6799
352
4416
427
8157
750
2225
2620
6198
217
1312
042
UPW
2474
9912
1979
993
6558
7318
5215
351
1481
7228
5335
258
3226
520
5947
039
1647
5763
4929
075
9714
32
WB
9335
729
7468
5823
2460
8524
1150
6819
292
2471
993
-74
2709
1559
4167
320
0531
5-
TOTA
L U
ASL
(RC
L)
5845
2480
153
7598
9514
5584
8340
8147
6096
3720
9079
410
7844
147
5808
1639
7368
2863
3622
2297
389
5005
2615
3512
96
NL
D10
3587
683
6215
261
-10
0157
8898
6009
4734
--
1351
9581
4781
1174
89-
-
ILD
1275
9342
476
5560
5-
6254
1594
137
5249
56-
-44
5431
630
2672
5898
--
GR
AN
D T
OTA
L81
5705
908
6763
0762
1455
8483
5708
4709
3546
9710
484
1078
4414
758
0816
5771
0726
4047
0066
359
8950
0526
1535
1296
Report No. 4 of 2016
- 207 -
RCL/RTL
Impa
ct o
n pa
ymen
t of L
F an
d SU
C d
ue to
Inte
rest
inco
me
not c
onsi
dere
d fo
r G
RR
TL
(Am
ount
in `
)
Serv
ices
/LSA
2008
-09
2009
-10
Am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
Ass
am15
6987
658
9419
259
5416
074
6977
4441
4186
466
2407
218
Bih
ar23
7490
169
1424
9410
1033
0822
9356
5334
5613
920
4070
092
HP
5920
2269
3552
136
1983
276
2383
6556
1430
193
7985
25
Kol
katta
3564
8057
3564
806
1158
562
3785
5374
3785
537
1230
300
MP
1741
9178
113
9353
4258
3542
510
9684
691
8774
775
3674
437
NE
5807
0201
3484
212
1945
352
1575
4046
9452
4352
7761
Odi
sha
1321
0771
879
2646
344
2560
959
0434
2435
4260
519
7795
5
WB
8484
8713
6787
897
2842
432
4712
5146
3770
012
1578
692
TOTA
L U
ASL
(RT
L)
9385
4656
562
9195
2633
9375
5145
6639
012
3204
8752
1626
4979
Report No. 4 of 2016
- 208 -
RCL/RTL
AN
NE
XU
RE
-5.1
2 (ii
) [Pa
ra 5
.3.2
]Im
pact
on
paym
ent o
f LF
and
SUC
due
to O
ther
inco
me
not c
onsi
dere
d fo
r G
R
RC
L (
Am
ount
in `
)
Serv
ices
/LSA
2006
-07
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
(CD
MA
)A
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
(C
DM
A)
SUC
Impa
ct
(GSM
)A
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
(C
DM
A)
SUC
Impa
ct
(GSM
)
AP
2077
2345
2077
235
5276
1810
8183
8110
8183
829
0139
1812
1694
8070
1694
807
3776
5674
021
Bih
ar73
0113
543
8068
1701
1652
7220
631
6332
1212
61-
9271
307
5562
7821
3240
-
Che
nnai
6902
193
6902
1915
8060
--
--
--
--
Del
hi24
5995
6124
5995
656
3330
1155
3628
1155
363
2696
9119
7424
1263
7324
1263
746
7920
1074
79
Guj
arat
1489
3486
1489
349
3782
9567
4601
267
4601
1809
2211
3011
7590
3111
7590
326
2028
5135
8
Har
yana
3886
665
3109
3393
669
2286
538
1829
2361
323
383
4207
926
3366
3493
766
1837
8
HP
6830
2340
981
1700
761
3453
3680
716
563
-88
3049
5298
323
842
-
J&K
8251
349
5117
9137
888
2273
941
673
6285
4417
715
191
3216
Kar
nata
ka14
8833
2814
8833
337
0595
8395
140
8395
1422
5150
1406
1437
6192
1437
619
3203
4662
788
Ker
ala
1561
4526
1249
162
3981
7077
9666
962
3734
2245
8913
5898
8085
079
0468
2364
8546
607
Kol
kata
9614
023
9614
0222
0161
5125
129
5125
1312
0441
68
3331
368
3331
1605
83-
Mah
aras
htra
1891
0908
1891
091
4879
0183
8246
483
8246
2414
6314
0415
7638
0015
7638
037
7286
6884
8
MP
9306
072
7444
8623
1721
5755
658
4604
5315
5403
-93
0960
674
4768
2513
59-
Mum
bai
2713
7142
2713
714
6431
5013
8731
3013
8731
335
1395
2482
2559
3893
2559
389
5386
2712
5195
Odi
sha
2883
361
1730
0271
796
1531
134
9186
841
341
-23
8081
514
2849
6428
2-
Punj
ab66
6560
353
3248
1659
7427
8145
422
2516
7459
646
652
3864
241
9091
1167
3322
880
Raj
asth
an97
2315
077
7852
2421
0644
5377
535
6302
1194
4677
683
7079
366
9663
1865
2739
484
TN12
6693
3412
6693
335
0941
1023
8728
1023
873
2745
9317
8415
3585
7015
3585
734
2237
7244
5
UPE
1281
9925
1025
594
3551
1275
3001
160
2401
2019
4813
1214
7445
7911
7956
632
8555
6954
9
UPW
9862
763
7890
2126
1363
5501
096
4400
8815
8463
958
1091
6835
8733
4726
1280
5149
4
WB
3720
259
2976
2192
634
2531
754
2025
4073
421
-39
3695
131
4956
1062
98-
TOTA
L U
ASL
(R
CL
)23
2931
314
2142
3151
5801
510
1212
2425
011
0514
9932
0308
817
251
2106
3687
919
2007
0647
4424
281
3741
NL
D41
2793
6924
7676
2-
2974
7976
1784
879
--
7166
4563
4299
874
--
ILD
5084
5582
3050
735
-18
5755
2911
1453
2-
-23
6114
2814
1668
6-
-
GR
AN
D T
OTA
L32
5056
266
2695
0648
5801
510
1695
4775
513
9509
0932
0308
817
251
3059
1287
024
9172
6547
4424
281
3741
Report No. 4 of 2016
- 209 -
RCL/RTLIm
pact
on
paym
ent o
f LF
and
SUC
due
to O
ther
inco
me
not c
onsi
dere
d fo
r G
RR
TL
(A
mou
nt in
`)
Serv
ices
/LSA
2008
-09
2009
-10
Am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
Ass
am55
5057
376
3330
3443
1914
9479
3129
0589
518
7743
5410
7952
53
Bih
ar83
9688
113
5038
1287
3652
6433
4195
9697
525
1758
1918
2524
68
HP
2093
1999
512
5592
0070
1222
010
6895
862
6413
752
3581
011
Kol
katta
1260
3995
312
6039
9540
9629
816
9763
735
1697
6373
5517
321
MP
6158
8556
749
2708
4520
6321
6749
1884
790
3935
0783
1647
8140
NE
2053
1737
112
3190
4268
7813
270
6495
6442
3897
423
6676
0
Odi
sha
4670
8998
728
0253
9915
6475
1526
4782
279
1588
6937
8870
206
WB
2999
9749
323
9997
9910
0499
1621
1334
348
1690
6748
7079
701
TOTA
L U
ASL
(R
TL
)33
1839
5855
2224
6301
111
9992
160
2047
8134
4614
3723
739
7294
0862
(` in
cro
re)
Inte
rest
inco
me
Oth
er in
com
e T
otal
(int
eres
t + o
ther
) inc
ome
Serv
ices
/Com
-pa
nyTo
tal a
mou
nt
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
Serv
ices
/Com
-pa
nyTo
tal a
mou
nt
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
Serv
ices
/Com
-pa
nyTo
tal a
mou
nt
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
UA
SL (R
CL
)
8
63.9
7
78.8
1
22
.78
UA
SL (R
CL
)
5
6.48
5.
17
1.46
U
ASL
(RC
L)
92
0.45
8
3.97
2
4.24
NL
D
2
45.7
1
14.7
4
- N
LD
14.
27
0.85
- N
LD
25
9.98
1
5.60
-
ILD
119
.84
7.19
-
ILD
9.30
0.
56
-
ILD
12
9.14
7.7
5
-
UA
SL (R
TL
)13
9.52
9
.50
5
.02
UA
SL (R
TL
)
536
.62
36.
62
19.
30
UA
SL (R
TL
)
676.
14
46.
12
24.
32
GR
AN
D
TOTA
L
1,
369.
04
110.
24
27
.80
GR
AN
D
TOTA
L
616.
67
43.2
0
20
.76
GR
AN
D
TOTA
L
1,9
85.7
2
1
53.4
4
48.
56
Report No. 4 of 2016
- 210 -
RCL/RTL
ANNEXURE -5.13 [Para No. 5.3.4]Impact on payment of LF and SUC due to non-consideration of income from non trade investment
(Amount in `)
Amount shown in the Schedule O- Financial charges (Net) under the head 'Income from non-trade investments'
GL code Description of item Amount
6345600 Profit/Loss of sale of cumulative investment units 3305651923 (a)
6345800 Profit/Loss of sale of cumulative investment in PMS (Loss) -2216452461 (b)
Total (a-b) 1089199462 Say ` 108.92 crore
The loss of ` 221.65 Crore shown in GL code 6345800 above has been arrived as follow-
GL code Description of item Amount
6345800Reversal of Marked to Market (MTM)* gain for 08-09 in RCIL -MF FP Dr 3433283200
Profit/Loss & interest transferred by RCIL for 08-09 Cr 1216830739
Loss shown in accounts Say ` 221.65 crore 2216452461
* Process of revaluation to reflect its current market value instead of its acquisition price or book value, also called 'Marking to Market'
Services/LSA2008-09
Amount of GR/AGR LF Impact SUC Impact
Assam 182186882 10931213 6285447
Bihar 275611434 16536686 11989098
HP 68705253 4122316 2301626
Kolkatta 41370185 4137019 1344531
MP 202152563 16172205 6772111
NE 67391468 4043488 2257614
Odisha 153313283 9198797 5135995
WB 98468393 7877472 3298691
TOTAL UASL (RTL) 1089199462 73019196 39385114
(` in crore)
Services/Company Total amount of GR/AGR LF Impact SUC Impact
UASL (RTL) 108.92 7.30 3.94
Report No. 4 of 2016
- 211 -
RCL/RTL
ANNEXURE - 5.14 [Para No. 5.3.5]Summary of Reliance Communication Ltd's statements under Section 212 (8) of the Companies Act, 1956
relating to Subsidiary companies contained in the respective Annual Reports
(` in crore)
Investments by RCL 2006-07 2007-08 2008-09 2009-10 TOTAL
In subsidiaries 5358.50 13712.39 31342.32 31875.99 82289.20
In others 75.92 131.74 22.30 22.31 252.27
Total Investments 5434.42 13844.13 31364.62 31898.30 82541.47
Source: Annual report of RCL for the respective years
Statement showing Capital invested in profit making subsidiaries and Profit after Tax
(` in crore)
Year Total No. of Subsidiaries
No. of Profit making sub-
sidiaries
Capital invested in profit making subsidiaries Profit after tax/ (Loss) Proposed dividend
2006-07 13 5 1598.39 708.61 Nil
2007-08 14 6 8611.87 668.65 Nil
2008-09 16 6 29353.14 1118.01 Nil
2009-10 19 8 31748.42 1499.98 Nil
Total 62 25 71311.82 3995.25
Report No. 4 of 2016
- 212 -
RCL/RTL
AN
NE
XU
RE
-5.1
5 [P
ara
No.
5.4
.1]
Impa
ct o
n pa
ymen
t of S
UC
due
to n
on-c
onsi
dera
tion
of in
com
e fr
om sa
le/le
ase
of b
andw
idth
cha
rges
(Am
ount
in `
)
Serv
ices
/LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of G
R/
AG
RSU
C Im
pact
Am
ount
of G
R/
AG
RSU
C Im
pact
Am
ount
of G
R/
AG
RSU
C Im
pact
Am
ount
of G
R/
AG
RSU
C Im
pact
AP
1428
9248
636
2946
924
7431
991
6680
664
2955
5812
179
8006
919
9767
185
5393
714
Bih
ar30
3114
7070
6257
5003
054
1150
7017
3585
2539
9246
1058
0667
024
3355
3
Che
nnai
1106
4167
825
3369
412
5212
511
2942
494
4049
1817
1093
279
--
Del
hi25
2266
322
5776
899
5719
7954
813
4415
1976
6545
192
1801
3812
9842
9562
623
1309
47
Guj
arat
1222
2883
331
0461
228
8664
272
8053
733
2890
4615
978
0424
668
3389
9518
4515
3
Har
yana
6320
063
1523
1470
0807
518
2210
1051
7229
2839
6551
6033
913
9329
HP
2754
932
6859
856
9798
415
3846
4770
735
1288
1039
9769
810
7938
J&K
401
2994
6713
2924
933
231
8894
822
24
Kar
nata
ka22
0466
945
5489
627
3758
6364
810
1483
1971
9465
667
1942
5573
5867
1810
815
8413
89
Ker
ala
6124
4895
1561
745
9616
5062
2875
335
1070
7761
531
0525
145
3914
8913
1635
3
Kol
kata
2675
1831
861
2616
960
9846
008
1433
1381
8027
1003
218
8636
8612
2775
223
2885
218
Mah
aras
htra
1895
8058
848
9117
930
3439
605
9224
564
3633
0624
810
5358
8112
8424
465
3724
309
MP
1087
8239
727
0868
218
5760
708
5015
539
1732
0417
546
7651
319
0314
004
5138
478
Mum
bai
4940
2914
311
7084
9165
7428
991
1676
4439
1391
5763
8735
4851
9814
7258
2879
3755
0863
Odi
sha
2472
8697
6157
4545
0617
8512
1666
843
1727
9411
6566
510
3725
547
2800
590
Punj
ab51
1732
0612
7421
382
1657
6622
1847
694
2006
1525
4341
721
5179
6158
0985
Raj
asth
an11
8058
2229
3965
1222
3293
3300
2916
8533
8745
5041
8125
697
2193
94
TN20
0156
2255
4433
2288
4521
6979
7815
4565
056
4173
256
1633
1973
544
0963
3
UP(
E)60
0645
5416
6378
878
8652
3024
0539
090
3729
7324
4007
028
0414
3175
7119
UP(
W)
1181
3467
3130
5711
0677
9834
8636
1818
3703
5273
2711
0269
0931
9780
WB
3862
1887
9616
8525
7685
6769
5751
1037
0876
730
0755
414
3640
280
3878
288
TOTA
L U
ASL
(R
CL
)22
2726
1364
5413
4622
3757
5414
1097
8421
0755
0401
4446
1421
4109
243
9305
9189
1124
7525
7
(` in
cro
re)
Serv
ices
/Com
pany
Tota
l am
ount
of
GR
/AG
RSU
C Im
pact
UA
SL (R
CL
)
1,
588.
19
4
0.66
Report No. 4 of 2016
- 213 -
RCL/RTL
ANNEXURE -5.16 [Para No. 5.4.2]Impact on payment of SUC due to non-consideration of income from investment
(Amount in `)
Services/LSA2006-07
Amount of GR/AGR SUC Impact (CDMA)
AP 33721609 856529
Bihar 11852586 276165
Chennai 11204949 256593
Delhi 39934671 914504
Gujarat 24177930 614119
Haryana 6309571 152061
HP 1108812 27609
J&K 133951 2907
Karnataka 24161440 601620
Kerala 25348458 646386
Kolkata 15607305 357407
Maharashtra 30699770 792054
MP 15107380 376174
Mumbai 44054154 1044083
Odisha 4680818 116552
Punjab 10820870 269440
Rajasthan 15784460 393033
TN 20567265 569713
UP(E) 20811733 576485
UP(W) 16011106 424294
WB 6039430 150382
TOTAL UASL (RCL) 378138270 9418111
NLD 67012498 -
ILD 82542189 -
GRAND TOTAL 527692957 9418111
(` in crore)
Services/Company Total amount of GR/AGR SUC Impact
UASL (RCL) 37.81 0.94
NLD 6.70 -
ILD 8.25 -
GRAND TOTAL 52.77 0.94
Report No. 4 of 2016
- 214 -
RCL/RTL
ANNEXURE -5.17 [Para No. 5.5.1]Impact on payment of LF and SUC due to non-consideration of profit on transfer of OFU by RCL to RITL
(Amount in `)
Services/LSA2008-09
Amount of GR/AGR LF Impact SUC Impact (CDMA) SUC Impact (GSM)
AP 2733745073 273374507 73316582 457902
Bihar 1332257437 79935446 30641921 -
Delhi 2919538009 291953801 68149462 498803
Gujarat 1704680016 170468002 45717984 285534
Haryana 577795542 46223643 15495956 96781
HP 155016155 9300969 4185436 -
J&K 9574103 574446 237749 1604
Karnataka 2121405573 212140557 56894188 355335
Kerala 1970175233 157614019 56752277 343205
Kolkata 1295091800 129509180 30434657 -
Maharashtra 2118202440 211820244 61016304 354799
MP 1454423103 116353848 39269424 -
Mumbai 3505663461 350566346 88795476 627128
Odisha 386909225 23214554 10446549 -
Punjab 702858103 56228648 18850022 117729
Rajasthan 1125444464 90035557 30183408 196052
TN 2587270102 258727010 69388256 450702
UP(E) 1902792116 152223369 51031172 331466
UP(W) 1390096611 111207729 40042706 242155
WB 639760326 51180826 18521061 -
TOTAL UASL (RCL) 30632698894 2792652703 809370590 4359196
(` in crore)
Services/ Company Total amount of GR/AGR LF Impact SUC Impact
UASL (RCL) 3,063.27 279.27 81.37
Report No. 4 of 2016
- 215 -
RCL/RTL
ANNEXURE -5.18 [Para No. 5.5.2]Impact on payment of LF and SUC due to non-consideration of gain on revaluation of
investment on transfer to passive infrastructure to RTIL(Amount in `)
Services/LSA2007-08
Amount of GR/AGR LF Impact SUC Impact (CDMA)
AP 111551105 11155111 3011880
Bihar 51656181 3099371 1188092
Chennai 36031191 3603119 846733
Delhi 117036055 11703606 2750347
Gujarat 74768252 7476825 2086034
Haryana 23454981 1876398 609830
HP 7095905 425754 191589
J&K 2784894 167094 62103
Karnataka 84932886 8493289 2293188
Kerala 86435514 6914841 2584422
Kolkata 53248758 5324876 1251346
Maharashtra 95363555 9536356 2899052
MP 57373363 4589869 1549081
Mumbai 141810877 14181088 3616177
Odisha 17572905 1054374 474468
Punjab 31692960 2535437 855710
Rajasthan 48304179 3864334 1304213
TN 76244575 7624457 2325460
UP(E) 70380745 5630460 2146613
UP(W) 54690240 4375219 1722743
WB 24770879 1981670 668814
TOTAL UASL (RCL) 1267200000 115613547 34437894
(` in crore)
Services/Company Total amount of GR/AGR LF Impact SUC Impact
UASL (RCL) 126.72 11.56 3.44
Report No. 4 of 2016
- 216 -
RCL/RTL
ANNEXURE-5.19 [Para No.5.5.2]Impact on payment of LF and SUC due to non-consideration of gain on transfer of
passive infrastructure assets of RITL to RCL(Amount in `)
Services/LSA2007-08
Amount of GR/AGR LF Impact SUC Impact (GSM)
Assam 560152181 28007609 19325250
Bihar 849874979 42493749 37394499
HP 174283859 8714193 5838509
Kolkatta 131516786 13151679 4313751
MP 587484520 35249071 19680731
NE 219623387 10981169 7357383
Odisha 399373713 19968686 13379019
WB 293259925 17595595 9941511
TOTAL UASL (RTL) 3215569350 176161751 117230655
(` in crore)
Services/Company Total amount of GR/AGR LF Impact SUC Impact
UASL (RTL) 321.56 17.62 11.72
Report No. 4 of 2016
- 217 -
RCL/RTL
ANNEXURE-5.20 (Para 5.6)Impact on payment of LF and SUC due to non-consideration of refund of service Tax for GR by RCL
(Amount in `)
Services/LSA2009-10
Amount of GR/AGR LF Impact SUC Impact (CDMA) SUC Impact (GSM)
AP 41393933 4139393 1048691 109123
Bihar 22644223 1358653 561358 -
Delhi 58926206 5892621 989037 318182
Gujarat 28720234 2872023 582145 186985
Haryana 10277431 822195 219360 77843
HP 2156757 129405 59738 -
J&K 1798300 107898 802 48972
Karnataka 35112382 3511238 677328 172353
Kerala 24132969 1930638 689531 40384
Kolkata 16689670 1668967 382170 -
Maharashtra 38501473 3850147 835430 266726
MP 22737763 1819021 640255 -
Mumbai 62510473 6251047 1160321 242659
Odisha 5814898 348894 156004 -
Punjab 12794849 1023588 240022 113251
Rajasthan 20444809 1635585 428690 171453
TN 37511741 3751174 899601 110687
UP(E) 36012130 2880970 798513 252352
UP(W) 26663257 2133061 607054 226970
WB 9615601 769248 265204 -
TOTAL UASL (RCL) 514459100 46895767 11241254 2337938
(` in crore)
Services/Com-pany
Total amount of GR/AGR LF Impact SUC Impact
UASL (RCL) 51.45 4.69 1.36
Report No. 4 of 2016
- 218 -
RCL/RTL
AN
NE
XU
RE
5.2
1 (p
ara
No.
5.7
)St
atem
ent s
how
ing
inte
rest
on
LF
& S
UC
upt
o M
arch
201
5(A
mou
nt in
)
Sl
No.
Para
N
o.
No.
of M
onth
s(up
to M
arch
15)
9684
7260
TOTA
LR
ate@
(PL
R+2
)%14
.25
14.2
514
.25
13.7
5
Issu
es20
06-0
720
07-0
820
08-0
920
09-1
0
Inte
rest
on
LF
Inte
rest
on
SUC
Inte
rest
on
LF
Inte
rest
on
SUC
Inte
rest
on
LF
Inte
rest
on
SUC
Inte
rest
on
LF
Inte
rest
on
SUC
15.
2.2
AN
on c
onsi
dera
tion
com
mis
sion
/dis
coun
t pai
d to
RC
IL/
dist
ribut
ors (
` 11
70.5
1 cr
)38
3973
458
1041
1681
934
4938
347
1035
1745
027
8564
835
8137
6198
4660
5007
713
4949
893
1897
4870
77
25.
2.2
BN
on c
onsi
dera
tion
of g
ross
val
ue o
f end
use
rs re
venu
e (`
10
07.8
7 cr
)21
3728
207
5795
3748
3484
5626
010
4573
191
4828
0469
414
1040
093
2476
3105
871
7042
7916
6789
1532
35.
2.2
CN
on in
clus
ion
of C
RB
T re
venu
e (`
540
.84
cr)
5563
9399
1508
6973
1933
8598
558
0359
4822
1374
055
6466
9250
1840
5962
953
2964
7784
5547
717
45.
2.2
DB
ooki
ng o
f rev
enue
on
acco
unt o
f Sal
e of
SIM
car
ds b
y R
CIL
(` 1
03.1
7 cr
)-
--
-43
5979
9412
4117
4960
3299
4217
3012
6813
3640
953
55.
2.2
EB
ooki
ng o
f Rev
enue
of S
ale
of H
ands
ets b
y R
CIL
(`
252
3.95
cr)
3605
8957
0197
7761
311
9205
2088
127
6252
192
4747
9205
1387
3654
2525
3354
7334
390
5874
3706
88
65.
2.2
FB
ooki
ng o
f 'no
n re
fund
able
Up-
fron
t cha
rges
' in
resp
ect
of F
ixed
Wire
less
Pho
ne/T
erm
inal
(FW
P/T)
by
RC
IL
(` 2
48.2
9 cr
)
1749
2029
247
4307
3810
1875
273
3057
3198
7252
5877
2119
2414
2927
2184
8501
588
4862
9156
3
75.
2.3
Non
con
side
ratio
n of
com
mis
sion
net
ted
off (
` 1.
11 c
r)-
--
-22
4727
6876
675
7937
2553
2313
0675
3
85.
2.4
Net
ting
of R
even
ue w
ith E
xpen
ses (
`4.5
0 cr
)62
2931
1645
2219
5418
358
2756
1904
397
5548
3113
3256
337
5083
7491
266
95.
2.5
Net
ting
of d
isco
unt t
o di
strib
utor
s/ d
eale
rs/ f
ranc
hise
es o
n sa
le o
f pre
paid
pro
duct
s (`
392.
99 c
r)68
9214
8139
9651
3380
7595
0052
3456
5910
2486
824
5482
8300
9847
1327
4869
4658
5464
7288
2
105.
2.6
Non
incl
usio
n of
FO
C (F
ree
of C
harg
es) R
echa
rge
vouc
h-er
s dis
tribu
ted
to D
istri
buto
rs
(` 8
7.32
cr)
2961
0513
1828
8697
3059
9912
1798
3993
3294
7610
1423
4113
2669
8911
3727
1440
4555
4
115.
3.1
Non
con
side
ratio
n of
For
ex g
ain
(RC
L &
RTL
) 16
0680
744
3466
3932
2890
9302
084
2228
4445
8569
424
1080
4600
147
7887
362
1201
5667
917
3332
0008
125.
3.2
Non
con
side
ratio
n of
Oth
er a
nd in
tere
st in
com
e (R
CL
&
RTL)
1991
7336
142
8748
98-
-10
3018
1197
3557
5390
865
7997
482
1958
1870
324
8179
9548
135.
3.4
Net
ting
of re
venu
e by
` 1
08.9
2 cr
ore
aris
ing
on a
ccou
nt
of n
on in
clus
ion
of ‘I
ncom
e fr
om N
on-tr
ade
inve
stm
ent’
in G
ross
Rev
enue
of R
TL fo
r the
yea
r 200
8-09
--
--
9781
3661
5275
8759
--
1858
6026
1
145.
4.1
Non
con
side
ratio
n of
reve
nue
from
sale
/leas
e of
ban
d-w
idth
cha
rges
for S
UC
(` 1
588.
19 c
r)-
1139
9887
8-
1659
0187
0-
1904
0665
3-
1103
3583
558
0643
235
Con
td…
..
Report No. 4 of 2016
- 219 -
RCL/RTL
Sl
No.
Para
N
o.
No.
of M
onth
s(up
to M
arch
15)
9684
7260
TOTA
LR
ate@
(PL
R+2
)%14
.25
14.2
514
.25
13.7
5
Issu
es20
06-0
720
07-0
820
08-0
920
09-1
0
Inte
rest
on
LF
Inte
rest
on
SUC
Inte
rest
on
LF
Inte
rest
on
SUC
Inte
rest
on
LF
Inte
rest
on
SUC
Inte
rest
on
LF
Inte
rest
on
SUC
155.
4.2
Non
con
side
ratio
n of
Inco
me
from
in
vest
men
t for
SU
C (`
52.
77 c
r)-
1983
3040
--
--
--
1983
3040
165.
5.1
Non
-incl
usio
n of
Pro
fit o
f `30
63.2
7 cr
ore
aris
ing
as a
resu
lt of
tran
sfer
of
Opt
ic F
iber
Und
erta
king
(OFU
) by
RC
L to
Rel
ianc
e In
frat
el L
td
(RIT
L)
--
--
3740
9284
3410
9004
0623
--
4830
9690
58
175.
5.2
Non
-incl
usio
n of
gai
n of
` 1
26.7
2 cr
ore
on re
valu
atio
n of
inve
stm
ent
as a
resu
lt of
tran
sfer
of p
assi
ve
infr
astru
ctur
e to
RTI
L by
RC
L
--
1960
3526
758
3931
72-
--
-25
4428
439
185.
5.2
Non
-con
side
ratio
n of
gai
n fo
r `
321.
56 c
rore
from
the
trans
fer o
f pa
ssiv
e in
fras
truct
ure
asse
ts o
f RTL
fo
r com
puta
tion
of re
venu
e sh
are
--
2987
0129
219
8777
248
--
--
4974
7853
9
19
5
.6
Ref
und
of S
ervi
ce T
ax-
--
--
-46
0037
5013
3208
9959
3246
49
TO
TAL
4893
1660
8614
7213
8690
2806
3199
2011
5115
9520
6611
4029
3622
0125
5313
2295
3136
5278
2158
802
2221
2914
919
Say
` 2,
221.
29 c
rore
Report No. 4 of 2016
- 220 -
Idea
AN
NE
XU
RE
-6.0
1 [p
ara
6.2.
1(A
)]Im
pact
on
LF
and
SUC
due
to n
on-c
onsi
dera
tion
of d
isco
unt/
mar
gins
(Am
ount
in `
)D
isco
unt
Serv
ices
/ LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
Am
ount
of
GR
/AG
RL
F Im
-pa
ctSU
C Im
-pa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
AP
-
-
-
8739
9849
6991
988
3801
893
3752
5521
737
5255
2216
3236
0224
9884
759
2498
8476
1086
9987
Del
hi32
8257
598
3282
5760
1395
0948
3153
4526
931
5345
2713
4021
74-
-
-
-
-
-
Guj
arat
-
-
-
- -
- 41
6914
7241
6914
713
9666
4
-
-
-
HP
-
-
-
4082
498
2449
5095
939
2175
2565
1305
154
5111
8590
2964
454
1779
2121
97
Kar
nata
ka
-
-
-
-
- -
- -
- 33
2462
8833
2462
910
8050
4
Ker
ala
-
-
-
1943
7792
411
6626
7584
5544
053
4522
097
4276
1768
2325
1711
6066
9597
448
5356
7826
3912
75
Mah
aras
htra
-
-
-
2188
1651
317
5053
2195
1851
861
8981
289
6189
8129
2692
5686
6095
7404
060
9574
0426
5164
71
MP
-
-
-
9442
9639
5665
778
4107
689
2394
0136
919
1521
1010
4139
6052
1038
364
4168
3069
2266
5169
Mum
bai
-
-
-
-
- -
1849
069
1849
0741
604
-
-
-
Odi
sha
-
-
-
-
- -
- -
- 18
7027
6511
2216
643
9515
Raj
asth
an
-
-
- 11
5072
223
9205
778
3854
919
1788
4950
514
3079
6059
9145
810
5323
005
8425
840
3528
321
UP(
W)
7967
9827
4780
790
3466
072
1202
5871
272
1552
352
3125
448
3341
169
3866
7294
2102
5341
4484
1531
435
8732
2519
5060
66
Tota
l UA
SL40
7937
425
3760
6549
1741
7020
1149
7826
2790
0265
4048
4678
2724
9564
3752
2199
7199
010
5881
212
2601
9101
5422
5452
266
1112
0950
4
Con
td…
..
Report No. 4 of 2016
- 221 -
Idea
AN
NE
XU
RE
-6.0
1 [p
ara
6.2.
1(A
)]…
..con
tdM
argi
n/C
omm
issi
on
(Am
ount
in `
)
Serv
ices
/ LSA
2007
-08
2008
-09
2009
-10
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f GR
/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ct
AP
-
-
-
-
-
-
3523
077
3523
0815
3254
Ker
ala
1857
8175
1114
691
8081
51
-
-
-
64
6062
8951
6850
328
1037
4
MP
-
-
-
1330
0835
710
6406
6957
8586
411
1999
946
8959
996
4871
998
Tota
l UA
SL18
5781
7511
1469
180
8151
1330
0835
710
6406
6957
8586
418
0129
312
1448
0807
7835
625
(` in
cro
re)
Tota
l am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
698
.70
59.9
3
2
9.74
Report No. 4 of 2016
- 222 -
Idea
AN
NE
XU
RE
-6.0
2 [P
ara
6.2.
1 (B
)]Im
pact
on
LF
and
SUC
due
to n
on-c
onsi
dera
tion
of F
ree A
ir T
ime
(FAT
)/Un-
used
Air
time/
Free
talk
tim
e (A
mou
nt in
`)
Serv
ices
/ LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
AP
--
-31
4487
025
1590
1368
02-
--
--
-
Del
hi-
--
--
-12
0973
1012
0973
151
4136
--
-
Guj
arat
8629
6437
6903
715
2890
931
--
--
--
--
-
Har
yana
4184
9647
225
1097
8814
0196
32-
--
--
--
--
Ker
ala
--
-23
0689
613
8414
1003
50-
--
--
-
Mah
aras
htra
--
-81
9055
2865
5244
235
6289
0-
--
4829
3335
148
2933
3521
0076
01
Mum
bai
--
--
--
--
-67
5801
8367
5801
815
2055
4
Raj
asth
an22
9441
2918
3553
076
8628
5087
2339
4069
787
1704
223
--
--
--
TN-
--
--
--
--
1383
814
1383
8132
520
UP(
E)15
2028
1012
1622
550
9294
6371
1153
5096
892
2134
324
--
--
--
UP(
W)
7736
5738
4641
944
3365
410
2050
8610
012
3051
6689
2124
520
9537
342
1676
2987
9114
874
2227
6761
017
8214
0996
9039
1
Tota
l UA
SL62
0305
586
3970
7202
2155
3895
4070
2688
628
4142
9116
5598
3422
1634
652
1797
2718
9629
010
7746
6495
873
0111
4332
2510
66
(` in
cro
re)
Tota
l am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
2
02.3
6
15
.91
8
.00
Report No. 4 of 2016
- 223 -
Idea
AN
NE
XU
RE
-6.0
3 [P
ara
6.2.
1(B
)]Im
pact
on
LF
and
SUC
due
to n
on-c
onsi
dera
tion
of F
ree
SMS/
Free
SIM (A
mou
nt in
`)
Serv
ices
/LSA
2006
-07
2008
-09
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
AP
-
-
-
3614
1099
3614
110
1572
138
MP
1008
2230
6049
3437
9092
-
-
-
To
tal U
ASL
1008
2230
6049
3437
9092
3614
1099
3614
110
1572
138
(` in
cro
re)
Tota
l am
ount
of
GR
/AG
RL
F Im
-pa
ctSU
C Im
pact
4
.62
0.
42
0.2
0
AN
NE
XU
RE
- 6.
04 [P
ara
6.2.
1(B
)]Im
pact
on
LF
and
SUC
due
to n
on-c
onsi
dera
tion
of B
onus
/Bon
us A
irtim
e an
d Pr
omot
iona
l Tal
k Ti
me
(Am
ount
in `
)
Serv
ices
/LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
AP
2457
4448
519
6595
5910
6898
8554
5082
8743
6066
323
7111
0-
--
--
-D
elhi
--
-12
8589
6612
8589
754
6506
2032
8492
220
3284
9286
3960
942
3542
3342
3542
318
0005
5G
ujar
at10
4296
829
8343
746
3493
944
1161
5068
992
9205
538
9104
813
8695
857
1386
9586
4646
311
8045
9750
8045
975
2695
402
Har
yana
--
--
--
--
-11
5693
3392
5547
3875
73K
eral
a-
--
3861
223
1716
80-
--
--
-M
ahar
asht
ra-
--
--
-64
3581
651
6435
8165
2799
5802
3953
6423
939
5364
2417
1983
44M
P-
--
--
-13
9195
078
1113
5606
6054
986
7675
6296
6140
504
3338
899
Mum
bai
--
--
--
3353
7949
3353
795
7546
0454
4548
9454
4548
912
2523
5Pu
njab
--
--
--
--
-20
9642
1677
191
19R
ajas
than
--
-56
5514
4345
2411
518
9447
328
4291
419
2274
3314
9523
763
5134
5541
141
0764
3317
2007
56TN
--
--
--
--
-33
397
3340
785
UP
(W)
4781
4028
688
2079
916
9267
410
1560
7363
1-
--
2317
4487
318
5395
9010
0809
02To
tal U
ASL
3505
1945
428
0319
9314
2046
2824
1800
671
1956
6607
8778
448
1442
5868
7613
5788
958
5761
5075
1406
4020
6812
3965
496
5393
7070
(` in
cro
re)
Tota
l am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im-
pact
3
44.1
3
30
.74
1
3.45
Report No. 4 of 2016
- 224 -
Idea
AN
NE
XU
RE
-6.0
5 [P
ara
6.2.
1(B
)]Im
pact
on
LF
and
SUC
on
nett
ing
of r
efun
d of
Adm
in F
ee e
tc.
(Am
ount
in `
)
Serv
ices
/ LSA
2006
-07
2007
-08
2008
-09
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f GR
/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ct
AP
--
-86
6057
269
2846
3767
35-
--
Del
hi-
--
--
-27
8961
927
8962
1185
59G
ujar
at-
--
--
-13
9064
513
9065
4658
7K
eral
a53
2137
6631
9282
623
1479
9-
--
--
-M
ahar
asht
ra
-
-
-
4836
400
3869
1221
0383
--
-To
tal U
ASL
5321
3766
3192
826
2314
799
1349
6972
1079
758
5871
1841
8026
441
8027
1651
46
(` in
cro
re)
Tota
l am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
7.
09
0
.47
0.
31
AN
NE
XU
RE
6.0
6 [P
ara
6.2.
1 (B
)]Im
pact
on
LF
and
SUC
due
to n
on-c
onsi
dera
tion
of P
CO
-Fre
e Pr
omot
iona
l Air
Tim
e/re
char
ge fe
e/ac
tivat
ion
char
ges
(Am
ount
in `
)
Serv
ices
/LSA
2008
-09
2009
-10
Am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
AP
-
-
-
3288
8442
232
8884
4214
3064
72K
arna
taka
-
-
-
2185
000
2185
0071
013
Ker
ala
1253
9557
710
0316
4654
5470
816
2023
297
1296
1864
7048
013
Mah
aras
htra
-
-
-
1660
3597
1660
360
7222
56M
P
-
-
-
31
0646
424
8517
1351
31M
umba
i81
7482
4481
7482
418
3933
525
5891
444
2558
9144
5757
557
Raj
asth
an
-
-
-
49
5971
7839
6777
416
6150
5TN
-
-
-
3942
3445
3942
345
9264
51U
P(W
)
-
-
-
14
4296
4111
5437
162
7689
Tota
l UA
SL20
7143
821
1820
6470
7294
043
8721
4448
882
6313
1731
2560
87
(` in
cro
re)
Tota
l am
ount
of
GR
/AGR
LF
Impa
ctSU
C Im
pact
1
07.9
3
10.
08
3.8
6
Report No. 4 of 2016
- 225 -
Idea
AN
NE
XU
RE
-6.0
7 [P
ara
6.2.
2]Im
pact
on
LF
and
SUC
due
to n
on-c
onsi
dera
tion
of P
ostp
aid
Prom
otio
nal D
isco
unt
(Am
ount
in `
)
Serv
ices
/LSA
2006
-07
2007
-08
200
8-09
200
9-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
AP
5215
1472
4172
118
2268
589
4293
1440
3434
515
1867
518
6517
6871
6517
687
2835
194
1018
5562
310
1855
6244
3072
0
Ass
am
-
-
-
-
-
-
-
-
-
8734
852
4120
53
Bih
ar (A
BTL
)
-
-
-
-
-
-
1187
6971
2627
9113
2750
979
651
3119
6
Del
hi56
9495
8856
9495
924
2035
747
8438
3247
8438
320
3336
368
9893
6268
9893
629
3204
811
1527
808
1115
2781
4739
932
Guj
arat
5375
9300
4300
744
1800
937
3852
1626
3081
730
1290
474
5305
7330
5305
733
1777
421
8828
7664
8828
766
2957
637
Har
yana
1319
3984
7916
3944
1998
9885
223
5931
1333
1155
1390
7164
1112
573
4658
9025
5181
5920
4145
385
4858
HP
7991
147
9518
7851
479
3089
1210
1017
6961
0623
9226
8358
1610
163
06
J&K
-
-
-
-
-
-
-
-
-
13
1337
178
802
3086
4
Kar
nata
ka
-
-
-
-
-
-
-
-
-
2116
494
2116
4968
786
Ker
ala
3492
5327
2095
520
1519
252
2740
2046
1644
123
1191
989
4113
0977
3290
478
1789
197
7545
9673
6036
774
3282
496
Kol
kata
-
-
-
-
-
-
-
-
-
32
5687
3256
973
28
Mah
aras
htra
1049
9305
883
9944
545
6719
890
6328
3872
5062
739
4252
814
1126
725
1411
2673
6139
013
2381
4976
223
8149
7610
3595
15
MP
2485
6200
1491
372
9345
9322
1155
9913
2693
696
2029
3346
0091
2676
807
1455
514
5511
2572
4409
006
2397
397
Mum
bai
-
-
-
-
-
-
56
8305
356
8305
1278
6921
0261
0821
0261
147
3087
NE
-
-
-
-
-
-
-
-
-
23
025
1382
541
Odi
sha
-
-
-
-
-
-
-
-
-
29
1212
1747
368
43
Punj
ab
-
-
-
-
-
-
-
-
-
1096
7009
8773
6147
7065
Raj
asth
an19
9433
415
9547
6681
044
3519
235
4815
1485
7952
5964
242
0771
1761
9894
5532
875
6426
3167
53
TN
-
-
-
-
-
-
-
-
-
2330
509
2330
5154
767
UPE
5722
4545
780
1917
019
9383
115
9506
6679
340
5027
632
4022
1356
8490
7571
672
6057
3040
36
UPW
4188
5882
2513
153
1822
036
3575
0874
2145
052
1555
163
4738
7871
3791
030
2061
372
8694
6909
6955
753
3782
191
WB
-
-
-
-
-
-
-
-
-
81
070
6486
1905
Tota
l UA
SL38
5361
301
2966
9072
1586
2818
3215
6398
024
7778
8913
3908
0147
9449
900
4503
2247
1990
0583
8415
4691
478
5699
3134
5862
76
(` in
cro
re)
Tota
l am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
2
02.7
9
17
.80
8
.37
Report No. 4 of 2016
- 226 -
Idea
AN
NE
XU
RE
-6.0
8 [P
ara
6.2.
3] Im
pact
on
LF
and
SUC
due
to n
on-c
onsi
dera
tion
of ir
regu
lar
nett
ing
off o
f Roa
min
g D
isco
unt
(Am
ount
in `
)
Serv
ices
/LSA
2007
-08
2008
-09
2009
-10
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f GR
/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ct
AP
7866
0662
928
3421
781
5204
8152
035
461
1640
4283
1640
428
7135
86
Del
hi72
4565
672
4566
3079
4046
4413
0046
4413
019
7375
571
6205
4471
6205
430
4387
3
Guj
arat
-
-
-
49
8836
4988
416
711
5810
840
5810
8419
4663
Har
yana
1191
473
7148
839
914
-
-
-
7086
6556
693
2374
0
HP
5607
3733
644
1317
7
-
-
-
-
-
-
Ker
ala
4501
7427
010
1958
349
1842
3934
721
395
-
-
-
Mah
aras
htra
1929
6615
437
8394
7787
4177
874
3387
563
8827
4363
8827
427
7889
9
MP
4384
6726
308
1907
315
8454
4012
6763
568
9277
-
-
-
Mum
bai
-
-
-
45
4424
4544
210
225
-
-
-
Punj
ab
-
-
-
-
-
-
3019
6298
2415
704
1313
539
Raj
asth
an15
7376
1259
052
72
-
-
-
-
-
-
UPE
7564
460
5225
3418
9414
1515
363
4517
7615
6314
2092
559
5012
UPW
4321
7925
931
1880
0
-
-
-
39
6888
431
7511
1726
46
Tota
l UA
SL11
5312
7810
0595
446
8904
6551
5201
6220
985
2787
044
2103
5382
019
9826
7388
3595
8
(` in
cro
re)
Tota
l am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
28
.74
2.7
2
1.
21
Report No. 4 of 2016
- 227 -
Idea
AN
NE
XU
RE
-6.0
9 [P
ara
6.2.
4]
Impa
ct o
n L
F an
d SU
C d
ue to
non
-con
side
ratio
n of
Infr
astr
uctu
re sh
arin
g re
venu
e
(Am
ount
in `
)
Serv
ices
/ LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
AP
2232
6758
1786
141
9712
1480
0158
0164
0126
434
8068
776
4265
9676
4266
033
2455
710
3714
0710
3714
145
1156
Del
hi45
8881
3645
8881
419
5024
651
7166
1351
7166
121
9795
612
9567
213
1295
6721
5506
607
6199
0761
991
2634
6
Guj
arat
4326
1023
3460
882
1449
244
7392
4035
5913
923
2476
455
1337
4581
413
3745
8144
8048
523
3851
623
3852
7834
0
Har
yana
2079
3281
1247
597
6965
7560
6626
3736
3975
820
3219
870
6953
3756
5562
723
6829
424
2782
819
4226
8133
2
HP
1029
157
6174
924
185
5062
105
3037
2611
8959
2461
2785
1476
767
5784
0036
9743
1522
1845
986
8896
Ker
ala
4401
9678
2641
181
1914
856
8965
9302
5379
558
3900
180
2306
3893
118
4511
1410
0327
9310
1383
5281
1068
4410
18
Mah
aras
htra
7477
7191
5982
175
3252
808
1911
1720
715
2893
7783
1359
935
5896
278
3558
9628
1548
1488
5046
6898
850
4668
9921
9531
01
MP
1179
5142
7077
0944
3497
4760
8182
2856
491
2070
956
1240
7320
199
2585
653
9718
422
8107
572
1824
8606
9922
679
Mum
bai
-
-
-
-
-
-
1557
7451
1557
745
3504
93-
- -
Raj
asth
an15
3810
212
3048
5152
615
0566
5612
0453
250
4398
5778
0139
4622
411
1935
635
2225
9694
1780
776
7457
00
UPE
-
-
-
7336
525
5869
2224
5774
4779
6990
3823
759
1601
199
1350
699
1080
5645
248
UPW
4484
2591
2690
555
1950
653
6928
9603
4157
376
3014
098
1478
8333
411
8306
6764
3292
578
0344
062
4275
3394
50
Tota
l UA
SL31
0271
059
2328
9851
1270
4804
6914
4866
650
9045
8828
3552
6014
1469
4069
1269
0753
657
4900
6082
7060
718
7578
5349
3495
3266
(` in
cro
re)
Tota
l am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
3
24.3
5
2
7.69
13.3
5
Report No. 4 of 2016
- 228 -
Idea
AN
NE
XU
RE
-6.1
0 [P
ara
6.2.
5] Im
pact
on
LF
and
SUC
due
to n
on-c
onsi
dera
tion
of S
witc
h Sh
arin
g R
even
ue p
aid
by N
LD
(A
mou
nt in
`)
Serv
ices
/ LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
AP
4020
242
3216
1917
4881
3144
9529
2515
962
1368
055
6861
9813
6861
981
2984
962
6451
5226
6451
523
2806
412
Ass
am
-
-
-
-
-
-
-
-
-
47
8738
2872
411
250
Bih
ar (A
BTL
)
-
-
-
-
-
-
-
-
-
26
4727
215
8836
6221
1
Del
hi15
5173
3115
5173
365
9487
9470
1422
9470
142
4024
810
1931
4570
319
3145
7082
0869
226
4378
149
2643
7815
1123
6071
Guj
arat
8207
164
6565
7327
4940
5536
8608
4429
489
1854
848
1059
0735
710
5907
3635
4789
614
1896
686
1418
9669
4753
539
Har
yana
3725
132
2235
0812
4792
2643
9151
1586
349
8857
1258
9697
5047
1758
019
7548
771
8078
4057
4462
724
0556
3
HP
2471
6214
830
5808
2996
535
1797
9270
419
1014
7171
6088
3023
8459
2019
6683
1211
801
4746
22
J&K
-
-
-
-
-
-
-
-
-
4530
9227
186
1064
8
Kar
nata
ka (S
pice
)
-
-
-
-
-
-
-
-
-
20
9788
020
9788
6818
1
Ker
ala
-
-
-
-
-
-
44
6224
6835
6979
719
4107
739
5270
3031
6216
217
1942
6
Kol
kata
-
-
-
-
-
-
-
-
-
2222
372
2222
3750
003
Mah
aras
htra
1119
5130
8956
1048
6988
7188
9750
5751
180
3127
204
1278
3712
912
7837
1355
6091
513
2007
813
1320
0781
5742
340
MP
6325
191
3795
1123
7827
4035
7554
2421
453
1755
554
8318
7474
6654
998
3618
655
9772
6297
7818
104
4251
094
Mum
bai
-
-
-
-
-
-
35
6327
4135
6327
480
1737
1255
3251
112
5532
5128
2448
1
NE
-
-
-
-
-
-
-
-
-
1053
1963
1924
75
Odi
sha
-
-
-
-
-
-
-
-
-
6242
034
3745
2214
6688
Punj
ab (S
pice
)
-
-
-
-
-
-
-
-
-
29
8598
823
8879
1298
90
Raj
asth
an15
5790
812
4633
5219
017
8327
1814
2661
759
7396
3464
3970
2771
518
1160
573
5419
7401
4335
792
1815
613
TN
-
-
-
-
-
-
-
-
-
88
0642
088
0642
2069
51
UPE
8978
7471
830
3007
917
0336
5913
6269
357
0628
3894
9691
3115
975
1304
815
5354
0640
4283
251
1793
611
UPW
6106
878
3664
1326
5649
3862
6806
2317
608
1680
266
7599
9441
6079
955
3305
976
1002
1269
580
1701
643
5925
2
WB
-
-
-
-
-
-
-
-
-
1004
306
8034
423
601
Tota
l UA
SL57
8000
1246
0626
023
1264
139
6695
732
3146
1285
1593
4892
8776
6270
880
6329
2734
6492
4411
9258
2392
1096
3326
944
8939
22
(`
in c
rore
)
Tota
l am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
252.
4722
.63
9.78
Report No. 4 of 2016
- 229 -
IdeaA
NN
EX
UR
E -
6.11
[Par
a 6.
2.7]
Impa
ct o
n L
F an
d SU
C d
ue to
non
-con
side
ratio
n of
gai
n on
fore
ign
exch
ange
fluc
tuat
ion
(Am
ount
in `
)
Serv
ices
/ L
SA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im-
pact
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
-pa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
-pa
ct
AP
9142
9073
143
3977
212
4986
199
989
5436
9
-
-
-
3313
5884
3313
588
1441
411
Ass
am
-
-
-
-
-
-
-
-
-
17
7582
1065
541
73
Bih
ar
-
-
-
-
-
-
-
-
-
49
4013
8529
6408
311
6093
3
Del
hi
-
-
-
61
0044
0761
0044
125
9268
758
8513
958
8514
2501
1848
4578
0948
4578
120
5945
7
Guj
rat
-
-
-
1317
9570
1054
366
4415
16
-
-
-
4649
718
4649
7215
5766
Har
yana
8836
530
296
-
-
-
35
9206
528
7365
1203
3411
5071
1392
0569
3854
88
HP
-
-
-
-
-
-
-
-
-
1610
2896
6237
84
J&K
-
-
-
-
-
-
-
-
-
1273
489
7640
929
927
Kar
nata
ka
-
-
-
-
-
-
-
-
-
12
3221
3112
3221
340
0469
Ker
ala
3072
718
4413
3732
3713
2319
4227
910
8443
9
-
-
-
-
-
-
Mah
aras
htra
-
-
-
4228
9410
3383
153
1839
589
-
-
-
35
1543
6135
1543
615
2921
5
MP
-
-
-
4279
0503
2567
430
1861
387
-
-
-
25
5634
120
4507
1112
01
Mum
bai
-
-
-
-
-
-
91
874
9187
2067
4122
589
4122
5992
758
NE
-
-
-
-
-
-
-
-
-
1136
6568
2026
71
Odi
sha
-
-
-
-
-
-
-
-
-
8360
143
5016
0919
6463
Raj
asth
an
-
-
-
31
2000
6224
9600
510
4520
2
-
-
-
9122
6072
981
3056
1
TN
-
-
-
-
-
-
11
5018
4411
5018
427
0293
UPE
-
-
-
4020
9002
3216
720
1347
002
2681
816
2145
4589
841
1535
7728
1228
618
5144
84
UPW
5544
7933
269
2412
0
18
5720
0014
8576
080
7882
Tota
l UA
SL15
0833
210
8786
6552
526
4294
138
2086
0383
1026
6191
1225
0894
1099
611
4623
6025
7737
070
2241
6106
9196
936
(` in
cro
re)
Tota
l am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
53
.58
4
.45
2
.00
Report No. 4 of 2016
- 230 -
Idea
AN
NE
XU
RE
-6.1
2 [P
ara
6.3.
1]
Impa
ct o
n L
F an
d SU
C d
ue to
non
-con
side
ratio
n of
Inte
rest
Inco
me
(A
mou
nt in
`)
Serv
ices
/LSA
2007
-08
2008
-09
2009
-10
Tota
l Int
eres
tL
FSU
CTo
tal I
nter
est
LF
SUC
Tota
l Int
eres
tL
FSU
C
AP
1161
0578
792
8846
350
5060
231
9752
249
3197
5225
1390
9223
2182
7037
521
8278
8794
9513
1A
ssam
-
-
--
--
4274
2425
646
1004
5B
ihar
(AB
TL)
-
--
1048
7000
062
9220
024
6444
541
0968
638
2465
8221
9657
803
Del
hi91
6142
4091
6142
438
9360
519
7560
931
1975
6093
8396
340
1344
9947
813
4504
6657
1644
8G
ujar
at84
8936
5167
9149
228
4393
721
2951
038
2129
5104
7133
860
1602
3961
016
0245
8453
6823
6H
arya
na33
6104
1920
1662
511
2594
990
3046
9672
2437
630
2520
766
4276
6353
1442
022
2541
3H
P18
5557
611
1335
4360
679
8524
247
9115
1876
5376
5690
145
9432
1799
44J&
K-
--
--
-45
4228
2725
510
675
Kar
nata
ka (S
pice
)-
--
--
-65
0282
365
0308
2113
50K
eral
a85
2074
5951
1244
837
0652
426
0979
773
2087
8382
1135
2620
2037
5801
016
3012
7588
6381
8K
olka
ta-
--
--
-21
2954
021
2962
4791
7M
ahar
asht
ra17
4678
091
1145
4921
7598
497
4483
8256
435
5781
2319
5046
4234
0905
476
2343
3058
1482
9965
MP
9380
1199
5628
072
4080
352
2469
1594
719
7532
7610
7408
4419
5045
572
1560
4252
8484
812
Mum
bai
--
-21
5311
1721
5311
248
4450
5440
1753
5440
387
1224
087
NE
--
--
--
7577
545
4717
81O
dish
a-
--
--
-57
5592
734
5369
1352
70Pu
njab
(Spi
ce)
--
--
--
1117
4475
8939
9048
6107
Raj
asth
an20
5881
8816
4705
568
9704
6078
2073
4862
566
2036
199
4844
9616
3876
120
1623
125
TN-
--
--
-79
9455
679
9487
1878
79U
PE21
0717
8216
8574
370
5905
8395
8929
6716
714
2812
624
8366
9362
6693
809
2803
033
UPW
8409
7764
5045
866
3658
253
2249
1619
117
9932
9597
8385
417
9718
454
1437
8036
7818
057
WB
--
--
--
1898
789
1519
0944
623
Tota
l UA
SL80
7524
156
5794
3444
3339
6934
2280
8907
5019
4957
581
9183
1961
2140
4244
4517
0573
420
7942
5519
NL
D41
9887
7225
1932
6-
1543
3558
792
6013
3-
1756
0252
810
5365
62-
ILD
--
--
--
2037
468
1222
53-
Gra
nd T
otal
8495
1292
860
4627
7033
3969
3424
3522
6337
2042
1771
491
8319
6123
1806
4441
1812
3223
579
4255
19
(` in
cro
re)
Serv
ices
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ct
UA
SL
5
22.8
9
4
2.35
20.
47
NLD
37
.19
2
.23
-
ILD
0
.20
0
.01
-
Tota
l
5
60.2
8
4
4.59
20.
47
Report No. 4 of 2016
- 231 -
IdeaA
NN
EX
UR
E-6
.13
[Par
a 6.
3.2]
Impa
ct o
n L
F an
d SU
C d
ue to
non
-con
side
ratio
n of
Pro
fit o
n sa
le o
f Inv
estm
ent
(A
mou
nt in
`)
Ser
vice
s/ L
SA 2
007-
08
200
8-09
2
009-
10
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f GR
/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ct
Tota
l43
1792
260
87
8708
917
And
hra
Prad
esh
5895
7696
4716
616
2564
660
3058
7065
030
5870
6513
3053
7398
4552
3098
4552
342
8280
3A
ssam
--
--
--
1903
8011
423
4474
Bih
ar (A
BTL
)-
--
4503
3700
027
0202
2010
5829
2019
7768
8211
8661
346
4757
Del
hi46
5858
1446
5858
119
7989
718
8957
567
1889
5757
8030
697
6010
6550
6010
655
2554
528
Guj
arat
4315
9034
3452
723
1445
828
2036
7313
920
3673
1468
2305
072
2562
0672
2562
124
2058
3H
arya
na17
0957
2710
2574
457
2707
8522
4900
6817
992
2855
034
2996
3530
2397
082
1003
778
Him
acha
l Pra
desh
9438
2756
630
2218
076
3857
445
8314
1795
0634
5379
920
7228
8116
4Ja
mm
u &
Kas
hmir
--
--
--
1969
7511
818
4629
Kar
nata
ka (S
pice
)-
--
--
-29
3322
929
3323
9533
0K
eral
a43
3358
1026
0014
918
8510
824
9632
797
1997
0624
1085
9027
9190
6743
7352
539
3997
943
Kol
kata
--
--
--
9581
7895
818
2155
9M
adhy
a Pr
ades
h47
6329
1128
5797
520
7203
223
6074
750
1888
5980
1026
9252
8791
4970
7033
198
3824
301
Mah
aras
htra
8880
0959
7104
077
3862
842
4287
2835
842
8728
3618
6496
8415
3661
141
1536
6114
6684
260
Mum
bai
--
-20
5858
1920
5858
246
3181
2449
8700
2449
870
5512
21N
orth
Eas
t-
--
--
-34
180
2051
803
Odi
sha
--
--
--
2596
326
1557
8061
014
Punj
ab (S
pice
)-
--
--
-46
0115
036
8092
2001
50R
ajas
than
1046
5536
8372
4335
0595
5812
1075
4649
686
1947
056
2183
4830
1746
786
7314
67Ta
mil
Nad
u-
--
--
-35
9797
735
9798
8455
2U
P Ea
st10
7180
2885
7442
3590
5480
3010
8564
2408
726
9008
637
7245
8330
1796
712
6377
4U
P W
est
4273
9595
2564
376
1859
172
2150
3467
917
2027
7493
5400
981
0627
8764
8502
335
2623
1W
est B
enga
l-
--
--
-85
6487
6851
920
127
Tota
l UA
SL41
0434
937
3073
1554
1697
4074
2530
1803
9321
6211
231
9600
8874
7985
8083
471
6908
4031
8794
48N
LD
2135
7323
1281
439
-14
7635
323
8858
119
-79
2090
4247
5254
3-
ILD
--
--
--
9190
4155
142
-G
rand
Tot
al43
1792
260
3201
2993
1697
4074
2677
8157
1622
5069
350
9600
8874
8787
0891
776
4985
2531
8794
48(`
in c
rore
)
Serv
ices
/ Com
pany
Tota
l am
ount
of
GR
/AG
RL
FSU
C
Tota
l UA
SL
373.
92
3
1.86
1
4.49
N
LD
2
4.82
1.
49
-
ILD
0.0
9
0.
01
-
Gra
nd T
otal
39
8.83
33.
36
14.
49
Report No. 4 of 2016
- 232 -
Idea
AN
NE
XU
RE
- 6.
14 [P
ara
6.3.
3] Im
pact
on
LF
and
SUC
due
to n
on-c
onsi
dera
tion
of M
isc.
Inco
me
(Am
ount
in `
)
Ser
vice
s/ L
SA20
07-0
820
08-0
9
Am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
And
hra
Prad
esh
6898
8755
191
3001
056
0396
656
0397
2437
73
Del
hi12
4661
412
4661
5298
134
2345
434
2345
1454
97
Guj
arat
1082
5291
8660
2336
2647
9154
854
9154
8530
6688
Har
yana
2266
746
1360
0575
936
2436
681
1949
3481
629
Him
acha
l Pra
desh
1634
3098
0638
4135
0404
2102
482
35
Ker
ala
5818
319
3490
9925
3097
6932
579
5546
0630
1567
Mad
hya
Prad
esh
5548
3033
290
2413
554
7345
243
7876
2380
95
Mah
aras
htra
4485
443
3588
3519
5117
9108
022
9108
0239
6199
Mum
bai
--
-57
3120
5731
212
895
Raj
asth
an11
1979
689
584
3751
331
2892
325
0314
1048
19
UP
East
1012
564
8100
533
921
2072
793
1658
2369
439
UP
Wes
t86
9635
5217
837
829
4890
972
3912
7821
2757
Tota
l UA
SL29
0525
5421
5567
711
0702
753
1492
2048
0219
721
2159
2
NL
D29
801
1788
-10
6503
563
902
-
Gra
nd T
otal
2908
2355
2157
465
1107
027
5421
4255
4866
099
2121
592
(
` in
cro
re)
Serv
ices
/ Com
pany
Am
ount
of G
R/
AG
R L
F Im
pact
SUC
Impa
ct
Tota
l UA
SL
8.
22
0.69
0.
32
NLD
0.11
0.
01
-
Gra
nd T
otal
8.33
0.
70
0.32
Report No. 4 of 2016
- 233 -
IdeaA
NN
EX
UR
E -
6.15
[Par
a 6.
3.4]
Impa
ct o
n L
F an
d SU
C d
ue to
non
-con
side
ratio
n of
Pro
fit o
n Sa
le o
f Ass
ets
(Am
ount
in `
)
Serv
ices
/ LSA
2006
-07
200
7-08
2
008-
09
200
9-10
A
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
-pa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
-pa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
-pa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
-pa
ctA
ndhr
a Pr
ades
h12
2160
197
728
5314
026
3693
2109
511
471
1206
7295
612
0672
9652
4927
468
5070
6850
729
801
Ass
am-
--
--
--
--
145
93
Bih
ar-
--
--
-11
7800
070
680
2768
3(4
2492
0)-
-D
elhi
2134
9321
349
9073
1174
525
1174
5249
917
1060
359
1060
3645
065
2335
830
2335
8399
273
Guj
arat
2293
818
3576
832
1985
2575
910
786
3001
945
3001
9410
0565
8250
9482
509
2764
1H
arya
na52
658
3159
1764
1267
076
042
417
1918
313
7535
5759
357
2847
4582
819
190
Him
acha
l Pra
desh
2907
174
6869
942
1640
823
2449
959
2633
158
62Ja
mm
u &
Kas
hmir
--
--
--
--
-15
09
4K
arna
taka
(Spi
ce)
--
--
--
--
-22
3722
473
Ker
ala
1934
8211
609
8416
1762
116
1057
2776
652
5686
897
4549
5224
7380
4500
7736
006
1957
8K
olka
ta-
--
--
--
--
731
7316
Mad
hya
Prad
esh
5367
1832
203
2018
111
8530
171
118
5156
110
4543
683
635
4547
618
4703
414
7763
8034
6M
ahar
asht
ra85
3523
6828
237
128
6581
052
6528
6320
2619
320
2619
8813
971
6471
631
2M
umba
i-
--
--
--
--
6868
068
6815
45N
orth
Eas
t-
--
--
--
--
262
1O
dish
a-
--
--
--
--
1980
119
47Pu
njab
(Spi
ce)
--
--
--
--
-17
3508
1388
175
48R
ajas
than
3223
625
7910
80(4
2244
)-
-(1
6373
8)-
-55
6649
4453
218
648
Tam
il N
adu
--
--
--
--
-23
2743
2327
454
69U
P Ea
st33
014
2641
1106
7943
635
266
8652
692
290
1487
6411
901
4984
UP
Wes
t16
1164
696
699
7010
725
9167
415
5500
1127
38(4
1683
1)-
-45
1180
936
0945
1962
64W
est B
enga
l-
--
--
--
--
653
5215
Tota
l UA
SL47
7421
533
8259
2028
3273
8641
650
3355
3166
9513
6442
662
1342
6088
5862
425
1242
3825
1076
958
5108
18N
LD
6578
539
470
1582
895
00
1590
795
40
6039
536
240
Tota
l48
4000
034
2206
2028
3274
0224
450
4304
3166
9513
6458
569
1342
7043
5862
425
1248
4920
1080
582
5108
18
Not
e: N
egat
ive
figur
es n
ot c
onsi
dere
d fo
r cal
cula
tion
of G
R/A
GR
.
(` in
cro
re)
Serv
ices
/ Com
pany
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ct
Tota
l UA
SL
16
.10
1
.54
0
.69
NL
D
0
.02
0
.00
-
Tota
l
16
.12
1
.54
0
.69
Report No. 4 of 2016
- 234 -
Idea
ANNEXURE-6.16 [Para 6.4.1]Impact on LF and SUC due to writing off of Bad Debts from GR
(Amount in `)
2009-10
Services/ LSAAmount of GR/AGR LF Impact SUC Impact
AP 382398930 38239893 16634353
Delhi 171652171 17165217 7295217
Gujarat 417361535 41736154 13981611
Haryana 20911877 1672950 700548
Kerala 21490876 1719270 934853
Maharashtra 584077440 58407744 25407369
MP 67889501 5431160 2953193
UPW 56031875 4482550 2437387
Total UASL 1721814205 168854938 70344531
(` in crore)
Amount of GR/AGR LF Impact SUC Impact
172.18 16.89 7.03
Report No. 4 of 2016
- 235 -
IdeaA
NN
EX
UR
E-6
.17
[Par
a 6.
6] S
tate
men
t sho
win
g in
tere
st o
n L
F an
d SU
C u
pto
Mar
ch 2
015
(Am
ount
in `
)N
o. o
f Mon
ths(
upto
Mar
ch 1
5)96
8472
60
TOTA
LR
ate@
(PLR
+2)%
14.2
514
.25
14.2
513
.75
Sl
No.
Pa
ra N
o.Is
sues
2006
-07
2007
-08
2008
-09
2009
-10
Inte
rest
on
LF
Inte
rest
on
SUC
Inte
rest
on
LF
Inte
rest
on
SUC
Inte
rest
on
LF
Inte
rest
on
SUC
Inte
rest
on
LF
Inte
rest
on
SUC
16.
2.1(
A)
Mar
gin/
Dis
coun
t not
con
side
red
7919
3393
3667
7466
1545
3980
983
5527
4630
8919
705
1495
8485
023
5369
240
1167
8074
011
6461
7949
26.
2.1(
B)
Free
AirT
ime
not c
onsi
dere
d83
6170
3545
3890
6448
1795
0228
0789
9024
0755
5112
8986
4671
6223
7931
6376
0934
5498
776
36.
2.1(
B)
Free
Sim
/Fre
e SM
S no
t con
side
red
1273
894
7983
07
-
-
48
4132
021
0597
4
-
-
9019
496
46.
2.1(
B)
Free
Tal
k Ti
me
not c
onsi
dere
d59
0309
0829
9126
8133
1772
9714
8848
0918
1897
582
7717
8902
1216
0751
552
9111
1857
0600
811
56.
2.1(
B)
Expe
nses
/Adm
n. F
ee a
djus
tmen
ts a
gain
st
reve
nue
6723
582
4874
597
1830
846
9955
2355
9972
2212
220
015
2057
42
66.
2.1(
B)
PCO
Ince
ntiv
es
-
-
-
-
2438
8677
9770
815
8105
9564
3066
1559
1458
8061
5
76.
2.2
Prom
otio
nal d
isco
unts
-Pos
t Pai
d 62
4783
2833
4045
6642
0135
9322
7055
5160
3234
4026
6580
4277
0754
3033
9287
2235
8587
672
86.
2.3
Dis
coun
t Net
ting
Off
00
1705
705
7950
8083
3339
037
3341
719
6025
7886
6788
942
8380
58
96.
2.4
Infr
a sh
arin
g re
venu
e no
t con
side
red
4904
4710
2675
4291
8631
4233
4807
9408
1700
0037
777
0114
3874
3438
1434
2884
1256
5836
683
106.
2.5
NLD
Sw
itch
shar
ing
reve
nue
not c
onsi
dere
d97
0004
948
7005
153
3460
1127
0193
3010
8012
720
4641
4772
1075
4790
644
0399
8340
0950
822
116.
2.6
IRU
Rev
enue
not
con
side
red
-
-
-
-
-
-
6646
78
-
66
4678
126.
2.7
Fore
x G
ains
not
con
side
red
2290
8613
7983
3537
1034
1740
7437
1472
997
6193
6121
9897
2490
2199
986
2496
21
136.
3.1
Inte
rest
inco
me
(IC
L) n
ot c
onsi
dere
d
-
-
1025
2116
156
6281
1326
5133
283
1197
1323
217
7780
505
7791
2997
7996
8929
0
Inte
rest
inco
me
(AB
TL) n
ot c
onsi
dere
d
-
-
-
-
8428
785
3301
274
-
-
11
7300
59
146.
3.2
Inve
stm
ent (
ICL)
not
con
side
red
-
-
54
2814
9028
7813
7826
5298
876
1144
3327
075
0434
2631
2730
6056
9111
500
Inve
stm
ent (
AB
TL) n
ot c
onsi
dere
d
-
-
-
-
3619
5231
1417
6465
-
-
50
3716
96
156.
3.3
Mis
c. In
com
e (I
CL)
not
con
side
red
-
-
36
5518
318
7708
464
3283
528
4200
2
-
-
1480
7105
166.
3.4
Profi
t on
sale
of F
ixed
Ass
ets (
ICL)
7206
3142
7132
8551
0253
6991
1789
1958
7816
059
1060
069
5011
0229
8090
44
Profi
t on
sale
of F
ixed
Ass
ets (
AB
TL)
-
-
-
-
94
680
3708
3
-
-
1317
63
176.
4.1
Bad
deb
ts w
ritte
n of
f tak
en a
s ded
uctio
ns
-
-
-
-
-
-
16
5643
102
6900
6489
2346
4959
1
186.
5.1
Tran
sfer
Infr
a Ass
ets
-
-
-
-
-
-
-
-
0
TO
TAL
3520
1161
618
3246
139
6177
9096
633
1342
437
1492
3013
7966
8516
825
1230
4099
2954
0631
678
5
,416
,250
,971
Say `
541.
63 c
rore
Report No. 4 of 2016
- 236 -
Tata
AN
NE
XU
RE
-7.0
1 [P
ara
No.
7.2.
1]Im
pact
on
Lic
ence
fee
and
SUC
due
to n
on-c
onsi
dera
tion
of c
omm
issi
on p
aid
by T
TSL
(A
mou
nt in
`)
20
06-0
720
07-0
820
08-0
920
09-1
0
Serv
ices
/ L
SAA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
AP
1985
7040
019
8570
4058
5782
718
8151
173
1881
5117
5550
460
1894
0340
618
9403
4155
8740
024
6653
418
2466
5342
7276
276
Ass
am-
--
--
-90
0362
5402
222
509
5809
176
3485
5114
5229
Bih
ar37
8630
0022
7178
010
2230
151
8496
6031
1098
013
9994
161
2214
3636
7328
616
5297
986
9163
4052
1498
023
4674
1
Che
nnai
4940
2200
4940
220
1235
055
4177
2666
4177
267
1044
317
--
--
--
Del
hi19
8450
200
1984
5020
5556
606
2004
1216
020
0412
1656
1154
021
8696
781
2186
9678
6123
510
2427
8212
724
2782
1367
9790
0
Guj
arat
1000
0640
010
0006
4027
0017
380
6354
4880
6354
521
7715
769
1313
2569
1313
318
6654
676
3897
1176
3897
120
6252
2
Har
yana
3690
1400
2952
112
9225
3540
8897
2832
7117
810
2224
344
7855
9135
8284
711
1964
061
5269
3449
2215
515
3817
3
HP
6250
400
3750
2416
8761
7513
065
4507
8420
2853
6866
586
4119
9518
5398
7759
825
4655
9020
9515
J&K
--
--
--
7172
6743
036
1793
270
5662
042
3397
1764
16
Kar
nata
ka13
1378
600
1313
7860
3547
222
1216
8271
412
1682
7132
8543
311
0103
776
1101
0378
2972
802
1723
4597
117
2345
9746
5334
1
Ker
ala
5252
7400
4202
192
1523
295
5948
7777
4759
022
1725
146
5763
8826
4611
106
1671
526
6595
7530
5276
602
1912
768
Kol
kata
6130
2000
6130
200
1716
456
5882
2414
5882
241
1647
028
5829
7301
5829
730
1632
324
6865
3837
6865
384
1922
307
MP
3077
1200
2461
696
8308
2235
7311
7328
5849
496
4742
3472
6051
2778
084
9376
0364
2339
5451
3871
617
3431
7
NE
--
--
--
2338
4014
030
5846
3325
480
1995
2983
137
Oris
sa19
4724
0011
6834
452
5755
2365
7377
1419
443
6387
4924
7973
1614
8783
966
9528
4369
0173
2621
410
1179
635
Punj
ab58
1768
0046
5414
414
5442
057
6850
5346
1480
414
4212
654
3434
5443
4747
613
5858
666
3996
8053
1197
416
5999
2
Raj
asth
an46
1568
0036
9254
412
4623
459
7350
1947
7880
216
1284
663
6446
8350
9157
517
1840
666
6530
9853
3224
817
9963
4
TN59
9798
0059
9798
014
9949
555
9285
0655
9285
113
9821
387
5302
1787
5302
221
8825
512
2824
829
1228
2483
3070
621
UPE
4423
3600
3538
688
1105
840
4699
6486
3759
719
1174
912
4470
5926
3576
474
1117
648
5390
6691
4312
535
1347
667
UPW
4771
9400
3817
552
1288
424
6005
2175
4804
174
1621
409
6256
2521
5005
002
1689
188
7867
5046
6294
004
2124
226
WB
2283
8000
1827
040
6623
0226
5974
0521
2779
277
1325
2679
3333
2143
467
7770
0735
2395
5928
1916
510
2194
7
Tota
l UA
SL12
0200
0000
1108
7007
632
8635
2112
1760
0000
1106
9570
033
2904
3812
1710
0000
1101
3652
033
3146
3415
7680
0000
1416
4584
643
0623
65
(` in
cro
re)
Tota
l am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
521.
3547
.33
14.2
5
Report No. 4 of 2016
- 237 -
Tata
AN
NE
XU
RE
– 7
.02
[Par
a N
o. 7
.2.2
]Im
pact
on
Lic
ence
fee
and
SUC
due
to n
on-c
onsi
dera
tion
of d
isco
unts
net
ted
off i
n re
spec
t of T
TSL
(A
mou
nt in
`)
Serv
ices
/ L
SA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
AP
1892
3249
2218
9232
492
5582
3585
2055
6115
4220
5561
154
6064
0541
2247
3719
6422
4737
196
6629
7473
2515
9208
9725
1592
090
7421
9666
Ass
am-
--
--
-10
4146
6062
4880
2603
6611
8481
352
7108
881
2962
034
Bih
ar22
9070
327
1374
4220
6184
899
1969
3026
211
8158
1653
1711
727
3790
518
1642
7431
7392
344
5015
1666
130
0910
0013
5409
50
Che
nnai
4208
8656
042
0886
5610
5221
6433
2443
292
3324
4329
8311
082
4029
1386
440
2913
8610
0728
47-
--
Del
hi20
7842
8434
2078
4284
358
1959
9628
9770
5041
2897
7050
481
1357
4132
4230
3702
3242
3037
090
7845
0428
7532
3770
2875
3237
780
5090
66
Guj
arat
1040
6704
0510
4067
040
2809
8101
7544
4011
775
4440
1220
3698
8378
9110
623
7891
1062
2130
5987
9220
8982
592
2089
8324
8964
25
Har
yana
6711
8823
953
6950
5916
7797
0655
5574
022
4444
5922
1388
9351
6764
6144
154
1169
1516
9115
3661
9028
391
4952
2271
1547
5710
HP
6404
0433
3842
426
1729
092
8053
1110
4831
867
2174
340
1006
9200
460
4152
027
1868
410
1279
666
6076
780
2734
551
J&K
--
--
--
6100
914
3660
5515
2523
1210
4674
672
6280
530
2616
9
Kar
nata
ka79
5554
105
7955
5410
2147
9961
6694
4984
466
9449
8418
0751
4682
9431
146
8294
3115
2239
4641
1237
6805
1912
3768
052
3341
7374
Ker
ala
2579
3207
720
6345
6674
8003
020
7246
070
1657
9686
6010
136
2234
0100
317
8720
8064
7862
933
3755
837
2670
0467
9678
919
Kol
kata
4783
5811
547
8358
1213
3940
2739
5723
329
3957
2333
1108
0253
5055
8199
350
5581
9914
1562
9670
0750
230
7007
5023
1962
1006
MP
3413
5353
427
3082
8392
1654
522
9230
626
1833
8450
6189
227
2223
3879
217
7871
0360
0314
724
5651
568
1965
2125
6632
592
NE
--
--
--
1917
754
1150
6547
944
6137
4099
3682
446
1534
352
Oris
sa10
5137
214
6308
233
2838
705
8673
6704
5204
202
2341
891
1234
4040
774
0642
433
3289
121
5694
078
1294
1645
5823
740
Punj
ab75
3595
836
6028
7667
1883
9896
7098
9421
056
7915
3717
7473
5581
9985
715
6559
8857
2049
9643
6569
4529
952
5556
2416
4236
32
Raj
asth
an45
9741
797
3677
9344
1241
3029
5126
3540
541
0108
3213
8411
5667
9891
275
5438
8488
1835
6115
6614
6808
152
9174
4617
8596
38
TN29
6363
382
2963
6338
7409
085
2720
7155
127
2071
5568
0178
927
1706
573
2717
0657
6792
664
1012
5896
3010
1258
963
2531
4741
UPE
3881
4446
831
0515
5797
0361
228
2628
807
2261
0305
7065
720
2840
9476
222
7275
8171
0236
937
9940
212
3039
5217
9498
505
UPW
5291
6869
542
3334
9614
2875
5542
8688
139
3429
5051
1157
4580
5637
9057
545
1032
4615
2223
4657
0251
549
4562
0124
1539
6792
WB
1192
7563
495
4205
134
5899
389
7797
7071
8238
226
0361
312
5968
118
1007
7449
3653
075
2115
0113
416
9200
9161
3353
3
Tota
l UA
SL10
9212
3417
810
0578
5493
2978
5498
010
7573
1984
210
0085
0520
2951
6892
112
4007
0780
311
4749
5083
3399
3602
414
0622
8954
512
8788
2409
3846
9939
6
(` in
cro
re)
Tota
l am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
4,8
14.1
6
444.
20
131
.77
Report No. 4 of 2016
- 238 -
Tata
AN
NE
XU
RE
– 7
.03
[Par
a N
o. 7
.2.2
] Im
pact
on
Lic
ence
fee
and
SUC
due
to n
on-c
onsi
dera
tion
of to
tal d
isco
unts
net
ted
off i
n re
spec
t of T
TM
L
(
Am
ount
in `
)
Serv
ices
/ L
SA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
Mah
aras
htra
(in
clud
ing
Mum
bai)
2770
6621
4527
7066
215
9087
7718
3248
3104
2332
4831
042
1065
4458
240
2536
4112
4025
3641
113
2031
943
4717
4961
3747
1749
614
1547
3387
3
Tota
l UA
SL27
7066
2145
2770
6621
590
8777
1832
4831
0423
3248
3104
210
6544
582
4025
3641
1240
2536
411
1320
3194
347
1749
6137
4717
4961
415
4733
873
(` in
cro
re)
Tota
l am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
1,
476.
18
147
.62
48
.42
Report No. 4 of 2016
- 239 -
TataA
NN
EX
UR
E -7
.04
[Par
a N
o.7.
2.3]
Impa
ct o
n L
icen
ce fe
e an
d SU
C d
ue to
non
-con
side
ratio
n of
adj
ustm
ents
net
ted
off i
n re
spec
t of T
TSL
(A
mou
nt in
`)
Serv
ices
/ L
SA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
FSU
CA
mou
nt o
f G
R/A
GR
LF
SUC
Am
ount
of
GR
/AG
RL
FSU
CA
mou
nt o
f G
R/A
GR
LF
SUC
AP
1923
1359
1923
136
5673
2559
8976
6659
8976
717
6698
113
5784
1213
5784
140
0563
2807
2119
2807
212
8281
28
Ass
am-
--
--
-27
3660
1642
068
4244
9144
326
9487
1122
86
Bih
ar45
4816
127
2890
1228
0045
0077
027
0046
1215
2188
2459
652
9476
2382
6423
2892
0713
9735
262
8809
Che
nnai
2827
904
2827
9070
698
2810
315
2810
3170
258
1977
517
1977
5249
438
Del
hi48
2587
4748
2587
513
5124
515
0643
9015
0643
942
1803
1633
3423
1633
342
4573
3680
1648
6280
1648
622
4461
6
Guj
arat
1696
8023
1696
802
4581
3771
7590
271
7590
1937
4915
2569
5115
2569
541
1938
1047
0270
1047
027
2826
97
Har
yana
7602
742
6082
1919
0069
1176
5758
9412
6129
4144
1013
8148
8110
5225
3454
2597
3653
2077
892
6493
41
HP
2341
093
1404
6663
210
2357
539
1414
5263
654
2386
801
1432
0864
444
4084
378
2450
6311
0278
J&K
--
--
--
1490
0289
4037
2563
1441
137
8865
1578
60
Kar
nata
ka20
0704
6920
0704
754
1903
5711
958
5711
9615
4223
7632
283
7632
2820
6072
1791
1238
1791
124
4836
03
Ker
ala
1153
8190
9230
5533
4608
1732
5388
1386
031
5024
3614
6545
7611
7236
642
4983
3154
2314
2523
385
9147
27
Kol
kata
2626
0139
2626
014
7352
8449
8688
9349
8688
913
9632
951
8194
9651
8195
014
5094
634
0068
4334
0068
495
2192
MP
2096
5202
1677
216
5660
6017
3525
0813
8820
146
8518
2046
7624
1637
410
5526
2624
2802
4919
4242
065
5567
NE
--
--
--
1853
511
1246
318
2763
310
9658
4569
1
Oris
sa15
9396
295
638
4303
756
4328
333
8597
1523
6974
5494
544
7297
2012
8419
3748
7311
6249
252
3122
Punj
ab20
6394
1316
5115
351
5985
3010
2053
2408
164
7525
5133
0259
9526
4208
082
5650
4457
6354
3566
108
1114
409
Raj
asth
an70
9932
356
7946
1916
8216
7167
7213
3734
245
1353
2640
6163
2112
493
7129
6652
4679
1441
9743
314
1663
4
TN24
5099
024
5099
6127
524
5636
424
5636
6140
943
7752
243
7752
1094
3816
4907
6916
4907
741
2269
UPE
9488
074
7590
4623
7202
1243
5665
9948
5331
0892
1336
0036
1068
803
3340
0128
0784
0222
4627
270
1960
UPW
5501
693
4401
3514
8546
1094
0924
8752
7429
5405
1160
3116
9282
4931
3284
2915
2758
2332
221
7871
24
WB
2134
703
1707
7661
906
5713
963
4571
1716
5705
1124
6026
8996
8232
6135
1912
6607
1530
129
5546
72
Tota
l U
ASL
2295
2018
520
9133
0362
6097
027
7840
111
2483
6887
7643
299
2709
8482
723
5161
4773
4385
050
1696
297
4269
0387
1357
5985
(` in
cro
re)
Am
ount
of G
R/
AG
RL
FSU
C
128
.00
11.
20
3
.48
Report No. 4 of 2016
- 240 -
Tata
AN
NE
XU
RE
-7.0
5 [P
ara
No.
7.2.
3]Im
pact
on
Lic
ence
fee
and
SUC
due
to n
on-c
onsi
dera
tion
of a
djus
tmen
ts sh
own
in tr
ial b
alan
ce n
ette
d of
f fro
m th
e re
venu
e by
TT
ML
(Am
ount
in `
)
Serv
ices
/ L
SA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
FSU
CA
mou
nt o
f GR
/A
GR
LF
SUC
Am
ount
of
GR
/AG
RL
FSU
CA
mou
nt o
f G
R/A
GR
LF
SUC
Mah
aras
htra
(in
clud
ing
Mum
bai)
4428
7329
644
2873
3014
5262
4438
6404
624
3864
0462
1267
4072
2669
7462
426
6974
6287
5676
838
1043
420
3810
4342
1249
8224
Tota
l UA
SL44
2873
296
4428
7330
1452
6244
3864
0462
438
6404
6212
6740
7226
6974
624
2669
7462
8756
768
3810
4342
038
1043
4212
4982
24
(` in
cro
re)
Tota
l am
ount
of
GR
/AG
RL
FSU
C
147.
73
14.
77
4.85
Report No. 4 of 2016
- 241 -
Tata
ANNEXURE -7.06 [Para No.7.2.4]Impact on Licence fee and SUC due to non-consideration of miscellaneous income
netted off from the revenue by TTSL (Amount in `)
Services/ LSA2008-09 2009-10
Amount of GR/AGR LF Impact SUC Impact Amount of GR/
AGR LF Impact SUC Impact
AP 765 77 23 103900290 10390029 3065059
Assam 704672 42280 17617 536730 32204 13418
Bihar 11053997 663240 298458 53931706 3235902 1456156
Delhi 127 13 4 - - -
Gujarat - - - 17307330 1730733 467298
Haryana 14667375 1173390 366684 69643359 5571468 1741084
HP - - - 6359811 381589 171715
Karnataka 9048822 904882 244318 138627194 13862719 3742934
Kerala - - - 43530205 3482416 1262376
Kolkata 788 79 22 37722762 3772276 1056237
MP 14285144 1142812 385699 124420110 9953609 3359343
NE 673752 40425 16844 - - -
Orissa - - - 49455315 2967319 1335294
Punjab 21560126 1724810 539003 58172847 4653828 1454321
Rajasthan 37350884 2988071 1008474 80677016 6454162 2178279
TN - - - 72869644 7286964 1821741
UPE 17188715 1375097 429718 30273280 2421862 756832
UPW 5040019 403202 136081 1021855 81748 27590
WB - - - 28157205 2252576 816559
Total UASL 131575187 10458378 3442945 916606660 78531404 24726236
(` in crore)
Total amount of GR/AGR
LF Impact
SUC Impact
104.82 8.90 2.82
Report No. 4 of 2016
- 242 -
Tata
ANNEXURE -7.07 [Para No.7.2.4]Impact on Licence fee and SUC due to non-consideration of other revenue heads shown in trial
balance netted off from the revenue(Amount in `)
2009-10
Services/ LSA Amount of GR/ AGR LF SUC
Maharashtra (including Mumbai) 84986842 8498684 2787568
Total UASL 84986842 8498684 2787568
(` in crore)
Total amount of GR/AGR
LFImpact
SUCImpact
8.50
0.85 0.28
Report No. 4 of 2016
- 243 -
Tata
ANNEXURE -7.08 [Para No.7.2.5]Impact on Licence fee and SUC due to non-consideration of revenue towards
OPEX receipt for infra sharing by TTSL(Amount in `)
Services/ LSA
2008-09 2009-10
Amount of GR/AGR LF Impact SUC Impact Amount of GR/
AGR LF Impact SUC Impact
AP 15025641 1502564 443256 33014092 3301409 973916
Bihar 2158804 129528 58288 2578639 154718 69623
Delhi 30202518 3020252 845671 26755357 2675536 749150
Gujarat 7345586 734559 198331 14029487 1402949 378796
Haryana 5969 478 149 - - -
HP 1233347 74001 33300 - - -
J&K 7806 468 195 366275 21977 9157
Karnataka 29263822 2926382 790123 31481393 3148139 849998
Kerala 2915 233 85 - - -
Kolkata 12093 1209 339 - - -
MP - - - 11454799 916384 309280
Orissa 4113840 246830 111074 4756591 285395 128428
Punjab 3352283 268183 83807 498292 39863 12457
Rajasthan 146330 11706 3951 - - -
TN 3735225 373523 93381 13363178 1336318 334079
Total UASL 96606179 9289916 2661949 138298103 13282688 3814884
(` in crore)
Total amount of GR/AGR LF Impact SUC Impact
23.49 2.26 0.65
Report No. 4 of 2016
- 244 -
Tata
AN
NE
XU
RE
-7.0
9 [P
ara
No.
7.2.
6]Im
pact
on
Lic
ence
fee
& S
UC
on
net f
orex
gai
n re
alis
ed w
hich
was
not
con
side
red
for
gros
s rev
enue
by
TT
SL d
urin
g 20
06-0
7 to
200
9-10
(A
mou
nt in
`)
Serv
ices
/ LSA
2006
-07
2007
-08
2009
-10
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f GR
/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ct
AP
8357
0883
570.
8224
653
1028
0018
410
2800
1830
3260
530
4587
030
3045
8703
8985
317
Ass
am-
--
--
-71
7362
743
0418
1793
41
Bih
ar15
9351
9561
.07
4302
2832
9107
1699
746
7648
8610
7331
129
6439
868
2897
940
Che
nnai
2079
1520
791.
5351
9822
8233
3822
8233
457
0583
--
-
Del
hi83
5202
8352
0.23
2338
610
9499
221
1094
9922
3065
978
2998
0645
529
9806
4583
9458
1
Guj
arat
4208
8942
088.
9411
364
4405
6801
4405
680
1189
534
9433
2020
9433
202
2546
965
Har
yana
1553
0412
424.
3338
8322
3409
2717
8727
455
8523
7597
8294
6078
264
1899
457
HP
2630
615
78.3
471
041
0491
424
6295
1108
3395
8244
257
4947
2587
26
J&K
--
--
--
8714
069
5228
4421
7852
Kar
nata
ka55
2923
5529
2.32
1492
966
4838
0266
4838
017
9506
321
2826
353
2128
2635
5746
312
Ker
ala
2210
6817
685.
4564
1132
5023
4526
0018
894
2568
8144
9542
6515
963
2362
037
Kol
kata
2579
9725
799.
7172
2432
1388
1132
1388
189
9887
8477
9154
8477
915
2373
816
MP
1295
0410
360.
3534
9719
5224
4615
6179
652
7106
7932
1136
6345
691
2141
671
NE
--
--
--
4106
564
2463
9410
2664
Oris
sa81
952
4917
.12
2213
1292
5685
7755
4134
8993
5395
2060
3237
124
1456
706
Punj
ab24
4844
1958
7.54
6121
3151
7391
2521
391
7879
3581
9955
4565
5964
420
4988
9
Raj
asth
an19
4257
1554
0.53
5245
3263
7431
2610
994
8812
1182
3084
8565
8467
922
2232
9
TN25
2432
2524
3.24
6311
3055
7666
3055
767
7639
4215
1673
754
1516
7375
3791
844
UPE
1861
6314
893.
0146
5425
6774
7720
5419
864
1937
6656
8219
5325
458
1664
205
UPW
2008
3316
066.
6454
2232
8107
1626
2485
788
5889
9715
4132
7772
331
2623
162
WB
9611
776
89.3
227
8714
5320
2811
6256
242
1429
4351
6577
3481
326
1261
981
Tota
l UA
SL50
5876
646
6610
1383
1066
5260
290
6048
0826
1818
8901
1947
1565
8817
4915
425
5317
6793
(` in
cro
re)
Tota
l am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
261.
75
2
3.59
7
.15
Report No. 4 of 2016
- 245 -
Tata
AN
NE
XU
RE
-7.1
0 [P
ara
No.
7.2.
6]Im
pact
on
Lic
ence
fee
on n
et F
orex
gai
n re
alis
ed w
hich
was
not
con
side
red
for
gros
s rev
enue
by
TT
ML
(Am
ount
in `
)
Ser
vice
s/ L
SA20
06-0
720
07-0
820
08-0
920
09-1
0
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im-
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Im-
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
Mah
aras
htra
(in
clud
ing
Mum
bai)
8719
0314
8719
031
2859
842
2202
9534
722
0295
3572
2568
711
5479
212
1154
7921
3787
718
1696
1601
416
9616
0155
6340
5
Tota
l USA
L87
1903
1487
1903
128
5984
222
0295
347
2202
9535
7225
687
1154
7921
211
5479
2137
8771
816
9616
014
1696
1601
5563
405
(` in
cro
re)
Tota
l am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
59.
26
5
.93
1.94
Report No. 4 of 2016
- 246 -
Tata
AN
NE
XU
RE
-7.1
1 [P
ara
No.
7.3.
1]Im
pact
on
Lic
ence
fee
and
SUC
due
to n
on-c
onsi
dera
tion
of in
tere
st in
com
e fo
r gr
oss r
even
ue b
y T
TSL
(A
mou
nt in
`)
Serv
ices
/ L
SA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im-
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
-pa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
AP
6618
4924
6618
492
1952
455
2502
1148
2502
115
7381
2452
6841
4552
6841
415
5418
274
8624
351
7486
2435
2208
4418
Ass
am-
--
--
-25
0443
1502
762
6117
6315
8410
5789
544
0790
Bih
ar12
6200
0775
7200
3407
4068
9519
041
3711
1861
7017
0292
5610
2175
545
9790
2638
0209
515
8281
2671
2265
7
Che
nnai
1646
6104
1646
610
4116
5355
5510
855
5511
1388
78-
--
--
0
Del
hi66
1448
6066
1448
618
5205
626
6516
6626
6516
774
6247
6083
2343
6083
234
1703
306
7368
7449
273
6874
4920
6324
86
Guj
arat
3333
2843
3333
284
8999
8710
7232
4710
7232
528
9528
1922
9458
1922
946
5191
9523
1852
443
2318
5244
6260
016
Har
yana
1229
9499
9839
6030
7487
5437
691
4350
1513
5942
1245
7488
9965
9931
1437
1867
4203
314
9393
6346
6855
1
HP
2083
303
1249
9856
249
9991
1959
947
2697
619
0999
811
4600
5157
023
5520
5214
1312
363
5905
J&K
--
--
--
1995
1411
971
4988
2141
7736
1285
064
5354
43
Kar
nata
ka43
7894
2043
7894
211
8231
416
1818
8816
1818
943
6911
3062
6288
3062
629
8269
1052
3091
842
5230
9184
1412
3480
Ker
ala
1750
7755
1400
620
5077
2579
1093
963
2875
2294
1716
0327
2312
8261
846
4949
2001
8945
316
0151
5658
0549
4
Kol
kata
2043
2392
2043
239
5721
0778
2245
678
2246
2190
2916
2158
8316
2158
845
4045
2083
7308
620
8373
0958
3444
6
MP
1025
6259
8205
0127
6919
4751
684
3801
3512
8295
9659
342
7727
4726
0802
1949
5818
315
5966
5552
6387
1
NE
--
--
--
6504
539
0316
2610
0932
5260
5595
2523
31
Oris
sa64
9028
938
9417
1752
3831
4605
918
8764
8494
468
9758
141
3855
1862
3513
2605
207
7956
312
3580
341
Punj
ab19
3907
4015
5125
948
4769
7671
205
6136
9619
1780
1511
6087
1209
287
3779
0220
1531
436
1612
2515
5038
286
Raj
asth
an15
3843
8912
3075
141
5379
7943
818
6355
0521
4483
1770
3302
1416
264
4779
8920
2300
592
1618
4047
5462
116
TN19
9916
9319
9916
949
9792
7437
612
7437
6118
5940
2434
7264
2434
726
6086
8237
2788
907
3727
8891
9319
723
UPE
1474
3373
1179
470
3685
8462
4979
449
9983
1562
4512
4353
2899
4826
3108
8316
3613
631
1308
9090
4090
341
UPW
1590
5215
1272
417
4294
4179
8599
563
8880
2156
2217
4022
9013
9218
346
9862
2387
8872
619
1030
9864
4729
6
WB
7612
068
6089
6522
0750
3537
037
2829
6310
2574
7452
790
5962
2321
6131
1069
5652
385
5652
231
0173
9
Tota
l UA
SL
4006
3513
336
9537
8310
9536
4516
1921
655
1472
0787
4427
105
3385
4656
730
6353
9692
6674
547
8578
7625
4299
1307
413
0699
729
(` in
cro
re)
Tota
l am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
568.
69
51.2
2 15
.53
Report No. 4 of 2016
- 247 -
Tata
AN
NE
XU
RE
-7.1
2 [P
ara
No.
7.3.
2]Im
pact
on
Lic
ence
fee
and
SUC
due
to n
on-c
onsi
dera
tion
of r
even
ue o
n pr
ofit o
n sa
le o
f inv
estm
ents
for
gros
s rev
enue
by
TT
SL
(Am
ount
in `
)
vi
ces/
LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
AP
1513
1763
1513
176
4463
8749
5172
4951
714
608
1185
4700
9011
8547
009
3497
1368
2051
7075
7620
5170
758
6052
5374
Ass
am-
--
--
-56
3533
733
8120
1408
8348
3217
7228
9930
612
0804
4
Bih
ar28
8529
417
3118
7790
313
6457
8187
3684
3831
8308
522
9909
8510
3459
4372
2985
776
4337
9147
1952
0616
Che
nnai
3764
621
3764
6294
116
1099
3610
994
2748
--
--
--
Del
hi15
1226
0315
1226
042
3433
5274
4052
744
1476
813
6881
6422
1368
8164
238
3268
6020
1950
5479
2019
5054
856
5461
53
Guj
arat
7620
839
7620
8420
5763
2122
1421
221
5730
4326
9083
643
2690
8411
6826
5363
5423
379
6354
2338
1715
6431
Har
yana
2812
016
2249
6170
300
1076
1386
0926
9028
0311
639
2242
4931
7007
791
5117
9212
040
9433
7012
7948
03
HP
4763
0228
578
1286
019
773
1186
534
4297
7748
2578
665
1160
399
6454
7624
3872
857
1742
786
J&K
--
--
--
4489
350
2693
6111
2234
5869
8238
3521
894
1467
456
Kar
nata
ka10
0115
1210
0115
127
0311
3202
4232
024
8647
6891
3614
568
9136
1418
6066
7614
3360
4845
1433
6048
438
7073
31
Ker
ala
4002
773
3202
2211
6080
1565
5812
525
4540
3607
5964
028
8607
7110
4620
3054
8646
616
4389
1729
1591
0752
Kol
kata
4671
428
4671
4313
0800
1548
0715
481
4335
3648
8101
336
4881
0110
2166
6857
1074
985
5710
7499
1599
0100
MP
2344
874
1875
9063
312
9403
675
2325
3921
7349
287
1738
7943
5868
431
5343
0960
542
7447
6814
4263
59
NE
--
--
--
1463
597
8781
636
590
2766
1939
1659
716
6915
48
Oris
sa14
8386
589
032
4006
462
261
3736
1681
1552
0564
093
1233
841
9055
236
3422
735
2180
5364
9812
414
Punj
ab44
3327
735
4662
1108
3215
1814
1214
537
9534
0134
009
2721
0721
8503
350
5523
2450
444
1859
6013
8081
13
Raj
asth
an35
1731
128
1385
9496
715
7209
1257
742
4539
8350
111
3186
8009
1075
5453
5544
3248
344
3545
9914
9696
77
TN45
7067
245
7067
1142
6714
7191
1471
936
8054
7848
935
5478
4893
1369
6223
1021
6790
6310
2167
906
2554
1977
UPE
3370
756
2696
6084
269
1236
8498
9530
9227
9813
013
2238
5041
6995
325
4484
0556
635
8724
4511
2101
39
UPW
3636
386
2909
1198
182
1580
4412
644
4267
3915
7689
531
3261
5210
5725
7665
4433
211
5235
4657
1766
9697
WB
1740
336
1392
2750
470
6999
856
0020
3016
7698
650
1341
5892
4863
261
2931
2900
123
4503
2085
0074
1
Tota
l UA
SL91
5966
2984
4869
025
0431
632
0444
929
1326
8761
376
1779
1443
6893
4108
920
8515
266
1311
6106
519
1178
2356
6635
8200
510
(` in
cro
re)
Tota
l am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
2,
082.
87
187
.63
5
6.93
Report No. 4 of 2016
- 248 -
Tata
AN
NE
XU
RE
-7.1
3 [P
ara
No.
7.3.
2]Im
pact
on
Lic
ence
fee
and
SUC
due
to n
on-c
onsi
dera
tion
of r
even
ue o
n pr
ofit o
n sa
le o
f inv
estm
ents
for
gros
s rev
enue
by
TT
ML
(A
mou
nt in
`)
Serv
ices
/ LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
FSU
CA
mou
nt o
f G
R/A
GR
LF
SUC
Am
ount
of
GR
/AG
RL
FSU
CA
mou
nt o
f G
R/A
GR
LF
SUC
Mah
aras
htra
(in
clud
ing
Mum
bai)
4700
000
4700
0015
4160
7000
0070
000
2296
030
0000
3000
098
4060
0000
6000
019
680
Tota
l UA
SL47
0000
047
0000
1541
6070
0000
7000
022
960
3000
0030
000
9840
6000
0060
000
1968
0
(` in
cro
re)
Tota
l am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
0
.63
0.06
0.02
Report No. 4 of 2016
- 249 -
Tata
AN
NE
XU
RE
-7.1
4 [P
ara
No.
7.3.
3]Im
pact
on
Lic
ence
fee
and
SUC
on
sale
of fi
xed
asse
ts n
ot c
onsi
dere
d fo
r gr
oss r
even
ue b
y T
TSL
(Am
ount
in `
)20
07-0
820
08-0
920
09-1
0
Serv
ices
/ LSA
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f GR
/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ct
AP
7695
8221
7695
822
2270
268
5541
3604
5541
360
1634
701
5606
1958
5606
196
1653
828
Ass
am-
--
2634
1815
805
6585
1320
370
7922
233
009
Bih
ar21
2077
2112
7246
357
2608
1791
1507
1074
690
4836
1119
7552
5111
8531
553
3392
Che
nnai
1708
5996
1708
600
4271
50-
--
--
-
Del
hi81
9732
5181
9732
522
9525
163
9839
4363
9839
417
9155
055
1820
5155
1820
515
4509
7
Guj
arat
3298
1780
3298
178
8905
0820
2256
9720
2257
054
6094
1736
2649
1736
265
4687
92
Har
yana
1672
4853
1337
988
4181
2113
1028
8510
4823
132
7572
1398
4482
1118
759
3496
12
HP
3073
019
1843
8182
972
2008
952
1205
3754
242
1763
734
1058
2447
621
J&K
--
-20
9850
1259
152
4616
0390
296
234
4009
8
Kar
nata
ka49
7710
7049
7710
713
4381
932
2129
7432
2129
786
9750
3917
2588
3917
259
1057
660
Ker
ala
2433
1889
1946
551
7056
2516
8633
4613
4906
848
9037
1499
1514
1199
321
4347
54
Kol
kata
2405
9740
2405
974
6736
7317
0559
9517
0560
047
7568
1560
4359
1560
436
4369
22
MP
1461
4884
1169
191
3946
0210
1597
7381
2782
2743
1414
5997
6211
6798
139
4194
NE
--
-68
414
4105
1710
7558
5045
351
1889
6
Oris
sa96
7641
958
0585
2612
6372
5493
143
5296
1958
8399
3035
859
5821
2681
20
Punj
ab23
5945
3318
8756
358
9863
1589
9221
1271
938
3974
8115
0920
1112
0736
137
7300
Raj
asth
an24
4330
1719
5464
165
9691
1862
0474
1489
638
5027
5315
1496
1012
1196
940
9039
TN22
8760
6422
8760
657
1902
2560
8646
2560
865
6402
1627
9169
0727
9169
169
7923
UPE
1922
2659
1537
813
4805
6613
0795
7710
4636
632
6989
1225
2474
9801
9830
6312
UPW
2456
2741
1965
019
6631
9418
3038
6714
6430
949
4204
1788
2084
1430
567
4828
16
WB
1087
8960
8703
1731
5490
7838
904
6271
1222
7328
8009
614
6407
6923
2279
Tota
l UA
SL49
8026
819
4527
7125
1361
6566
3560
8597
932
2225
5497
4683
635
8391
528
3219
4743
9787
663
(` in
cro
re)
Tota
l am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
121
.25
1
0.97
3
.32
Report No. 4 of 2016
- 250 -
Tata
ANNEXURE -7.15 [Para No.7.3.3]Impact on licence fee sale of fixed assets not considered for gross revenue by TTML
(Amount in `)
2009-10
Services/ LSA Amount of GR/AGR LF Impact SUC Impact
Maharashtra (including Mumbai) 354889478 35488948 11640375
Total UASL 354889478 35488948 11640375
(` in crore)Total amount of
GR/AGR LF Impact SUC Impact
35.49 3.55 1.16
Report No. 4 of 2016
- 251 -
Tata
ANNEXURE -7.16 [Para No.7.4.1]Impact on Licence fee and SUC due to non-consideration of bad debts written off (adjusted from
respective revenues) in respect of TTSL of 2009-10(Amount in `)
Services/ LSA Amount of GR/AGR LF Impact SUC Impact
AP 1034024491 103402449 30503722
Bihar 10303059 618184 278183
Delhi 633150438 63315044 17728212
Gujarat 192080943 19208094 5186185
Haryana 19408344 1552668 485209
HP 2933027 175982 79192
Karnataka 299570488 29957049 8088403
Kerala 32454902 2596392 941192
Kolkata 36034160 3603416 1008956
MP 56738984 4539119 1531953
Orissa 7011030 420662 189298
Punjab 39706081 3176486 992652
Rajasthan 32004900 2560392 864132
TN 252895892 25289589 6322397
UPE 36797881 2943830 919947
UPW 32572636 2605811 879461
WB 5173210 413857 150023
Total UASL 2722860466 266379024 76149117
(` in crore)Total amount of
GR/AGR LF Impact SUC Impact
272.29
26.64
7.61
Report No. 4 of 2016
- 252 -
Tata
AN
NE
XU
RE
-7.1
7 [P
ara
No.
7.4.
2]Im
pact
on
Lic
ence
fee
and
SUC
due
to n
on-c
onsi
dera
tion
of le
ased
line
and
por
t cha
rges
incl
uded
in th
e ac
cess
cha
rges
cla
imed
as d
educ
tion
by T
TSL
(A
mou
nt in
`)
Serv
ices
/ LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C
Impa
ct
AP
1102
9876
211
0298
7632
5381
377
3715
0677
3715
122
8245
997
0065
7697
0065
828
6169
478
2267
2278
2267
223
0768
8
Ass
am-
--
--
-26
3935
9015
8361
565
9840
4482
9829
2689
790
1120
746
Bih
ar21
3045
9312
7827
657
5224
1654
6212
9927
7344
6748
3027
9777
1816
787
8175
5429
8942
2317
9365
380
7144
Che
nnai
1822
8451
1822
845
4557
1118
6227
1518
6227
246
5568
--
--
--
Del
hi44
5499
8944
5499
912
4740
042
8294
3942
8294
411
9922
461
2946
8561
2946
917
1625
158
7194
9358
7194
916
4414
6
Guj
arat
4100
0795
4100
080
1107
021
3589
7125
3589
713
9692
2266
9991
3066
9991
318
0897
742
8798
4742
8798
511
5775
6
Har
yana
2138
5356
1710
828
5346
3411
6253
5593
0028
2906
3432
7709
4926
2167
681
9274
2281
6904
1825
352
5704
23
HP
1538
6399
9231
8441
5433
1045
5269
6273
1628
2292
1342
0302
8052
1836
2348
6334
754
3800
8517
1038
J&K
--
--
--
3258
456
1955
0781
461
1303
6799
7822
0832
5920
Kar
nata
ka45
0768
5445
0768
512
1707
552
8128
5852
8128
614
2594
752
9524
6052
9524
614
2971
629
5200
5329
5200
579
7041
Ker
ala
2453
6853
1962
948
7115
6921
4355
2517
1484
262
1630
4254
0483
3403
239
1233
674
3289
5298
2631
624
9539
64
Kol
kata
1670
6631
1670
663
4677
8613
0620
2113
0620
236
5737
3134
9070
3134
907
8777
7421
3714
8621
3714
959
8402
MP
1865
7137
1492
571
5037
4339
1922
5131
3538
010
5819
164
4567
4251
5653
917
4033
239
0918
3031
2734
610
5547
9
NE
--
--
--
1236
1590
7416
9530
9040
4000
7473
2400
448
1000
187
Oris
sa29
9962
6017
9977
680
9899
2593
2115
1555
927
7001
6722
8275
7013
6965
461
6344
2567
6346
1540
581
6932
61
Punj
ab26
5570
9821
2456
866
3927
1156
9329
9255
4628
9233
4502
6512
3602
121
1125
663
2730
9914
2184
793
6827
48
Raj
asth
an25
2159
5720
1727
768
0831
2833
0959
2266
477
7649
3648
4168
2338
7334
613
0725
433
2772
7526
6218
289
8486
TN29
7325
3229
7325
374
3313
4526
8457
4526
846
1131
711
5290
5827
5290
583
1322
646
3876
2713
3876
271
9690
68
UPE
2171
4806
1737
184
5428
7024
6582
5919
7266
161
6456
2912
6178
2330
094
7281
5424
3714
2519
4971
460
9286
UPW
1786
7353
1429
388
4824
1911
6896
0193
5168
3156
1927
0714
1621
6571
373
0928
1779
7919
1423
834
4805
44
WB
5448
2237
4358
579
1579
985
3475
4974
2780
398
1007
894
3933
8802
3147
104
1140
825
2273
2316
1818
585
6592
37
Tota
l UA
SL58
2698
063
5139
3980
1599
2653
5220
5397
046
4229
2814
2336
7079
9796
938
6906
3084
2168
9750
6495
5261
954
1582
2717
5025
64
(` in
cro
re)
Tota
l am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
255.
41
22.1
0 6.
94
Report No. 4 of 2016
- 253 -
Tata
AN
NE
XU
RE
-7.1
8 [P
ara
No.
7.4.
2]Im
pact
on
Lic
ence
fee
and
SUC
due
to n
on-c
onsi
dera
tion
of le
ased
line
and
por
t cha
rges
incl
uded
in th
e ac
cess
cha
rges
cl
aim
ed a
s ded
uctio
n b
y T
TM
L
(Am
ount
in `
)
Serv
ices
/ L
SA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
FSU
CA
mou
nt o
f G
R/A
GR
LF
SUC
Am
ount
of
GR
/AG
RL
FSU
CA
mou
nt o
f G
R/A
GR
LF
SUC
Mah
aras
htra
(in
clud
ing
Mum
bai)
1891
6836
818
9168
3762
0472
220
5385
522
2053
8552
6736
645
2681
8684
826
8186
8487
9652
920
9906
596
2099
0659
6884
936
Tota
l UA
SL18
9168
368
1891
6837
6204
722
2053
8552
220
5385
5267
3664
526
8186
848
2681
8684
8796
529
2099
0659
620
9906
5968
8493
6
(` in
cro
re)
Tota
l am
ount
of
GR
/AG
RL
FSU
C
87.2
6 8.
73
2.86
Report No. 4 of 2016
- 254 -
Tata
AN
NE
XU
RE
-7.1
9 [P
ara
No.
7.4.
3]Im
pact
on
SUC
due
to n
on-c
onsi
dera
tion
of r
even
ue fr
om sh
arin
g/le
asin
g of
Infr
astr
uctu
re/b
andw
idth
link
s for
pay
men
t of S
UC
by
TT
SL
(Am
ount
in `
)
Serv
ices
/ LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of G
R/A
GR
SUC
Impa
ctA
mou
nt o
f GR
/AG
RSU
C Im
pact
Am
ount
of G
R/A
GR
SUC
Impa
ctA
mou
nt o
f GR
/AG
RSU
C Im
pact
AP
2854
7811
684
2160
442
8650
588
1264
5192
2848
6473
384
0351
041
7656
346
1232
0862
Ass
am-
--
-26
568
664
1856
466
4641
2
Bih
ar97
1977
826
2434
3544
4044
9569
8933
2144
4289
6790
3521
7324
595
0867
8
Che
nnai
8638
0098
2159
502
1050
7162
126
2679
1-
--
-
Del
hi20
1006
556
5628
184
1021
5753
428
6041
179
1961
0922
1749
115
2035
594
4256
997
Guj
arat
1071
1621
228
9213
816
5636
253
4472
179
1024
8305
127
6704
210
0494
399
2713
349
Har
yana
1949
5053
4873
7645
8552
8211
4638
237
7482
494
371
1752
0762
4380
19
HP
1472
130
3974
859
5248
616
0717
1614
5243
5970
0928
718
9251
J&K
--
--
--
1786
114
4465
3
Kar
nata
ka57
8707
480
1562
5102
7770
7227
920
9809
5210
1493
2276
2740
3171
1081
8917
2729
2110
77
Ker
ala
1040
4813
130
1739
693
7284
5527
1812
573
2408
3721
2398
419
8908
984
5768
361
Kol
kata
2208
9794
6185
1418
1886
7950
9283
6556
473
1835
8186
0168
9824
0847
3
MP
3460
4054
9343
0913
2584
561
3579
783
5616
4676
1516
446
2859
6624
377
2108
9
NE
--
--
--
7243
1918
108
Oris
sa36
9945
0399
8852
3545
5272
9572
9299
1394
026
7676
8040
7946
2171
015
Punj
ab41
6669
0910
4167
358
2581
4014
5645
439
4637
6698
6594
6121
1186
1530
280
Raj
asth
an42
0612
2511
3565
358
1150
7315
6910
727
9510
6975
4679
1542
8744
041
6576
1
TN10
6249
362
2656
234
1090
5349
927
2633
730
9627
114
7740
678
4927
9849
712
3199
62
UPE
2355
6671
5889
1790
0987
3422
5246
831
3796
0278
4490
1499
3113
437
4827
8
UPW
1557
0329
4203
9996
9373
6626
1730
925
5299
5768
9309
1684
9337
245
4932
1
WB
2550
3805
7396
1025
9713
5475
3169
1628
5473
4722
7925
4241
663
7373
008
Tota
l UA
SL17
4172
0206
4766
7645
2384
2312
2064
9889
4121
1476
6361
5730
7115
4065
4116
2311
0502
952
(`
in c
rore
)
Tota
l am
ount
of G
R/A
GR
SU
C Im
pact
1,0
30.6
1 28
.05
Report No. 4 of 2016
- 255 -
TataA
NN
EX
UR
E -7
.20
[Par
a N
o.7.
4.4]
Impa
ct o
n L
icen
ce fe
e an
d SU
C d
ue to
non
-con
side
ratio
n of
Ren
tal I
ncom
e by
TT
SL
(Am
ount
in `
)
Serv
ices
/ LSA
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C
Impa
ct
AP
5976
411
5976
4117
6304
1904
0406
1904
041
5616
9218
7874
0618
7874
155
4228
1058
2987
1058
299
3121
98
Ass
am-
--
--
-15
2793
9168
3820
5215
2231
291
1303
8
Bih
ar43
4277
2605
711
725
1088
088
6528
529
378
2712
367
1627
4273
234
2454
645
1472
7966
275
Che
nnai
5668
0456
680
1417
084
2780
8427
821
070
2308
499
2308
5057
712
3078
000
3078
0076
950
Del
hi23
3784
123
3784
6546
040
8671
640
8672
1144
2839
3803
139
3803
1102
6591
2314
791
2315
2554
48
Guj
arat
1147
465
1147
4630
982
1626
853
1626
8543
925
1244
835
1244
8333
611
1465
929
1465
9339
580
Har
yana
4236
6733
893
1059
282
4967
6599
720
624
8064
4664
516
2016
128
1584
522
5268
7039
6
HP
7138
742
8319
2715
1579
9095
4093
1236
4574
1933
3837
7110
422
6266
1018
20
J&K
--
--
--
1291
677
532
335
8471
921
5083
8961
8
Kar
nata
ka15
5244
515
5245
4191
624
9356
624
9357
6732
627
5803
927
5804
7446
714
9869
114
9869
4046
5
Ker
ala
6262
4850
100
1816
112
0019
096
015
3480
613
1707
810
5366
3819
555
9269
4474
216
219
Kol
kata
7039
9670
400
1971
213
7816
4713
7816
538
5886
1049
748
1049
7529
393
1839
196
1839
2051
497
MP
5560
3644
483
1501
380
4891
6439
121
732
7397
4859
180
1997
321
9896
717
5917
5937
2
NE
--
--
--
1171
170
329
312
595
756
315
Oris
sa22
2920
1337
560
1947
7297
2863
812
887
5461
2532
768
1474
597
9840
5879
026
456
Punj
ab74
3981
5951
818
600
2458
461
1966
7761
462
1027
580
8220
625
690
9416
348
7533
0823
5409
Raj
asth
an64
1092
5128
717
309
1322
256
1057
8035
701
1569
566
1255
6542
378
1789
290
1431
4348
311
TN68
8720
6887
217
218
1128
380
1128
3828
210
2222
763
2222
7655
569
1111
802
1111
8027
795
UPE
5710
0045
680
1427
510
1117
380
894
2527
993
1011
7448
123
275
1174
577
9396
629
364
UPW
6737
9553
904
1819
213
3757
710
7006
3611
512
5255
110
0204
3381
910
9051
787
241
2944
4
WB
2622
8620
983
7606
5366
1342
929
1556
248
2462
3859
713
991
7340
2058
722
2128
7
Tota
l UA
SL18
2003
7117
0093
250
5182
5421
3440
5162
743
1520
174
4399
5322
4094
621
1228
482
5980
3010
5131
747
1611
257
(` in
cro
re)
Tota
l am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ct
17.
62
1
.61
0
.49
Report No. 4 of 2016
- 256 -
Tata
AN
NE
XU
RE
-7.2
1 [P
ara
No.
7.5]
Stat
emen
t sho
win
g in
tere
st o
n L
F &
SU
C u
pto
Mar
ch 2
015
(TT
SL)
(Am
ount
in `
)
Sl N
o.
Para
N
o.
No.
of M
onth
s(up
to M
arch
15)
9684
7260
TOTA
LR
ate@
(PL
R+2
)%14
.25
14.2
514
.25
13.7
5
Issu
es20
06-0
720
07-0
820
08-0
920
09-1
0
Inte
rest
on
LF
Inte
rest
on
SUC
Inte
rest
on
LF
Inte
rest
on
SUC
Inte
rest
on
LF
Inte
rest
on
SUC
Inte
rest
on
LF
Inte
rest
on
SUC
17.
2.1
Com
mis
sion
2334
7469
469
2053
3418
7696
524
5644
7536
1475
3457
844
6269
8113
8951
561
4224
3264
9201
8047
3
27.
2.2
Dis
coun
ts21
1802
3801
6272
3507
316
9705
0246
5004
9081
215
3714
3342
4553
6628
612
6338
5248
3773
8192
585
7607
6732
37.
2.3
Adj
ustm
ents
4404
0080
1318
4604
4211
3626
1296
0039
3150
1312
9837
534
4187
8361
1331
7752
2088
3330
9
47.
2.4
Star
ter K
it an
d M
isc
Rev
00
00
1400
9634
4612
035
7703
7637
2425
5912
1199
1521
7
57.
2.5
OPE
X in
com
e0
00
012
4444
0951
1026
913
0300
3526
1131
533
1960
28
67.
2.6
Fore
x G
ain
9826
0729
1259
1025
5177
730
8412
490
017
1588
311
5216
5303
3584
2050
6
77.
3.1
Inte
rest
Inco
me
7781
8773
2306
6629
2496
0686
7506
635
4103
7980
1241
3369
4217
3558
012
8213
654
7367
5330
6
87.
3.2
Profi
t on
sale
of i
nves
tmen
t17
7915
9352
7369
049
3975
1485
5792
3414
386
2793
1890
311
5582
4126
3513
8708
127
3365
2311
97.
3.3
Profi
t on
sale
of a
sset
00
7677
2259
2308
8360
4316
4074
1305
6480
3158
2358
9601
489
1972
6502
1
107.
4.1
Bad
deb
ts0
00
00
026
1312
156
7470
0664
3360
1282
0
117.
4.2
LL &
Por
t Cha
rges
1082
2752
333
6779
7678
7150
9624
1347
2392
5142
0929
0547
4053
1280
6817
1696
4343
6621
977
127.
4.3
Diff
eren
ce b
etw
een
Lice
nce
fee
AG
R &
Spe
ctru
m u
sage
AG
R0
1003
8045
60
1101
9577
40
7676
6372
010
8401
045
3957
4364
7
137.
4.4
Non
con
side
ratio
n of
rent
al in
com
e in
GR
3581
891
1063
832
8753
989
2577
620
5484
994
1645
626
5034
135
1580
609
2972
2695
TOTA
L26
0394
0962
8733
7885
222
1910
8179
7683
9130
528
4824
8919
9318
0859
636
3448
7576
1203
0296
5515
0823
9404
3
S
ay `
150
8.24
cro
re
Report No. 4 of 2016
- 257 -
Tata
Stat
emen
t sho
win
g in
tere
st o
n L
F &
SU
C u
pto
Mar
15
(TT
ML
)(A
mou
nt in
`)
Para
No.
No.
of M
onth
s(up
to M
arch
15)
9684
7260
TOTA
LR
ate@
(PL
R+2
)%14
.25
14.2
514
.25
13.7
5
Issu
es20
06-0
720
07-0
820
08-0
920
09-1
0
Inte
rest
on
LF
Inte
rest
on
SUC
Inte
rest
on
LF
Inte
rest
on
SUC
Inte
rest
on
LF
Inte
rest
on
SUC
Inte
rest
on
LF
Inte
rest
on
SUC
7.2.
1C
omm
issi
on-
--
--
--
--
7.2.
2D
isco
unts
5834
5725
019
1373
977
5507
8614
518
0657
856
5392
2204
717
6864
832
4627
7633
615
1790
638
2836
9290
80
7.2.
3A
djus
tmen
ts93
2620
5130
5899
5365
5190
8121
4902
5935
7628
7711
7302
2437
3795
4912
2604
9230
7994
485
7.2.
4St
arte
r Kit
and
Mis
c R
ev-
--
--
-83
3702
827
3454
511
0715
73
7.2.
5O
PEX
inco
me
--
--
--
--
-
7.2.
6Fo
rex
Gai
n18
3608
8960
2237
237
3534
5712
2519
3415
4691
4450
7387
916
6389
7054
5758
211
6628
228
7.3.
1In
tere
st In
com
e-
--
--
--
--
7.3.
2Pr
ofit o
n sa
le o
f inv
estm
ent
9897
4532
4636
1186
9338
931
4018
713
181
5885
919
306
1603
538
7.3.
3Pr
ofit o
n sa
le o
f ass
et-
--
--
-34
8139
0311
4189
6046
2328
63
7.4.
1B
ad d
ebts
--
--
--
--
-
7.4.
2LL
& P
ort C
harg
es39
8358
4113
0661
5634
8253
3511
4227
1035
9252
6111
7834
8620
5913
9067
5397
617
4204
155
7.4.
3D
iffer
ence
bet
wee
n lic
ense
fee
AG
R &
spec
trum
usa
ge A
GR
--
--
--
--
TO
TAL
=73
5905
776
2413
7709
368
8602
711
2258
6169
062
6419
516
2054
6560
258
0596
035
1904
3549
934
9466
3922
Say
` 34
9.47
cro
re
Report No. 4 of 2016
- 258 -
Aircel
AN
NE
XU
RE
- 8.0
1 [P
ara
8.2.
1 A
]St
atem
ent s
how
ing
the
deta
ils o
f am
ount
of W
aive
rs, D
isco
unts
, Pro
mo
offe
rs e
tc. n
ot c
onsi
dere
d fo
r re
venu
e sh
arin
g by
Air
cel G
roup (A
mou
nt in
`)
Des
crip
tion
200
6-07
2
007-
08
200
8-09
2
009-
10
TOTA
L
Deb
it en
try n
otic
ed in
the
Rev
enue
hea
ds o
n ac
coun
t of "
Wai
ver o
f-fe
red
to c
usto
mer
s"59
5109
1524
0436
740
4030
3288
628
7916
983
9908
9752
4
Deb
it en
try n
otic
ed in
the
Rev
enue
hea
ds o
n ac
coun
t of "
Dis
coun
t of
fere
d to
cus
tom
ers"
4615
2419
7
-
-
62
2217
046
7746
367
Deb
it en
try n
otic
ed in
the
Rev
enue
hea
ds o
n ac
coun
t of "
Prom
o Ta
lk
Tim
e Tr
ansf
er"
7696
6957
0080
820
2846
010
9122
695
9016
4
Am
ount
Boo
ked
unde
r Exp
Hea
d "3
3300
11-P
rom
o ta
lk T
ime/
usag
e",
whi
ch w
as g
roup
ed/n
et o
ff ag
ains
t rev
enue
, whi
le d
eriv
ing
"Tot
al
Inco
me
as p
er F
inan
cial
s"69
8275
7654
9321
6311
398
2935
6454
2471
3162
0
Tota
l net
ting
off a
gain
st re
venu
e52
2503
055
2469
0304
162
1372
744
3245
8683
417
1536
5675
Am
ount
add
ed b
ack
in re
venu
e w
hile
cal
cula
ting
GR
/AG
R -
unde
r de
scrip
tion
"Pro
mo
talk
tim
e gi
ven
as d
isco
unt"
69
8285
4209
779
2163
1139
865
4744
922
7766
911
Am
ount
add
ed b
ack
in re
venu
e w
hile
cal
cula
ting
GR
/AG
R -
unde
r de
scrip
tion
"Goo
dwill
wai
ver a
nd ro
yalty
dis
coun
t"
2540
4373
3246
2939
1909
8986
-
7696
6298
Am
ount
not
con
side
red
for A
GR
4964
0039
821
0230
323
3859
6236
031
8039
385
1410
6324
66
Say
` in
cro
re
49.
64
2
1.02
38.
60
3
1.80
141.
06
Report No. 4 of 2016
- 259 -
AircelA
NN
EX
UR
E-8
.02
[Par
a 8.
2.1
A]
Impa
ct o
n pa
ymen
t of L
F an
d SU
C d
ue to
non
-con
side
ratio
n of
wai
vers
dis
coun
ts p
rom
otio
n of
fers
etc
(Am
ount
in `
)
Serv
ices
/L
SA
Com
pany
2
006-
07
200
7-08
2
008-
09
200
9-10
A
mou
nt o
f G
R/A
GR
L
F Im
pact
S
UC
Im
pact
A
mou
nt o
f G
R/A
GR
L
F Im
pact
S
UC
Im
pact
A
mou
nt o
f G
R/A
GR
L
F Im
pact
S
UC
Im
pact
A
mou
nt o
f G
R/A
GR
L
F Im
pact
S
UC
Impa
ct
Ass
amD
WL
2348
3614
090
6223
2042
9912
258
6844
00
00
00
Bih
arD
WL
00
017
3240
310
3944
4071
132
1288
1927
775
5095
4905
5729
422
440
HP
DW
L16
2798
3837
7922
789
1980
9111
885
4655
8193
549
1619
25J&
KD
WL
4067
124
4095
630
5361
1832
271
7615
0908
190
545
3546
335
732
2144
840
Ker
ala
DW
L-
--
--
--
--
6384
546
5107
6415
0037
Kol
kata
DW
L-
--
--
--
--
-657
898
--
NE
DW
L23
117
1387
543
--
--
--
--
-O
rissa
DW
L18
5565
1113
443
6110
680
641
251
00
013
2046
2879
2278
3103
09W
BD
WL
3086
724
6972
51
--
--
--
--
TO
TAL
DW
L U
ASL
5166
8331
618
1284
722
5652
213
5391
5507
120
2846
012
1708
4766
920
0038
4813
6739
648
5551
AP
AL
--
--
--
4869
248
6911
4496
9889
096
9889
2279
24D
elhi
AL
--
--
--
7712
177
1217
3513
6528
9513
6529
030
7190
Kar
nata
kaA
L-
--
--
-10
9151
1091
525
6579
6821
079
6821
1872
53M
ahar
ash-
traA
L-
--
--
--
--
2682
322
2682
3263
035
Mum
bai
AL
--
--
--
--
-91
5364
691
5365
2059
57TN
AL
3079
4388
224
6355
1113
3955
5913
3181
033
1065
4483
5793
375
2849
2941
528
4929
4212
3944
3020
3093
665
2030
9367
8834
574
TO
TAL
AL
3079
4388
224
6355
1113
3955
5913
3181
033
1065
4483
5793
375
2851
6437
828
5164
3812
3998
7424
6249
629
2462
4963
9825
933
Che
nnai
AC
L18
7939
833
1879
3983
7987
443
7479
2767
7479
277
3178
693
9641
6795
9641
680
4097
714
5178
5908
5178
591
2200
901
TO
TAL
AC
L18
7939
833
1879
3983
7987
443
7479
2767
7479
277
3178
693
9641
6795
9641
680
4097
714
5178
5908
5178
591
2200
901
TO
TAL
UA
SL49
6400
398
4346
1112
2139
5848
2102
3032
318
2691
5190
2713
938
3609
634
3827
9825
1654
5257
3180
3938
531
1709
4912
5123
85
ISP
DW
L-
--
--
-23
5272
614
1164
--
--
G
RA
ND
TO
TAL
4964
0039
843
4611
1221
3958
4821
0230
323
1826
9151
9027
139
3859
6236
038
4209
8916
5452
5731
8039
385
3117
0949
1251
2385
(` in
cro
re)
Serv
ices
/Com
pany
Tota
l am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
ISP
0.
24
0
.01
-
DW
L U
ASL
2.
48
0
.17
0.0
6
AL
UA
SL
97.
25
8
.84
4.1
4
AC
L U
ASL
41.
09
4
.11
1.7
5
GR
AN
D T
OTA
L
141
.06
13
.13
5.9
5
Report No. 4 of 2016
- 260 -
Aircel
AN
NE
XU
RE
-8.0
3 [P
ara
8.2.
1 B
]Im
pact
on
paym
ent o
f LF
and
SUC
due
to n
on-c
onsi
dera
tion
of F
ull T
alk
time
(FT
T)
(Am
ount
in `
)
Serv
ices
/ L
SA
Com
pany
200
6-07
2
007-
08
200
8-09
2
009-
10
Am
ount
of
GR
/AG
R
LF
Impa
ct
SU
C
Impa
ct
Am
ount
of
GR
/AG
R
LF
Impa
ct
SU
C Im
pact
A
mou
nt o
f G
R/A
GR
L
F Im
-pa
ct
SU
C
Impa
ct
Am
ount
of
GR
/AG
R
LF
Im-
pact
S
UC
Im
pact
Ass
am
DW
L -
--
1265
1752
775
9105
242
3833
732
7460
224
1964
7613
1096
9918
1777
1134
610
6626
8159
5333
0
Bih
ar
DW
L -
--
5619
5226
3371
714
1320
588
7497
4705
4498
482
1761
906
--
-
Kol
kata
D
WL
--
--
--
1192
6263
1192
626
2683
4188
3813
588
3814
1988
58
NE
DW
L -
--
8503
2126
5101
928
1998
255
1932
0513
011
5923
0845
4032
140
7166
5324
4299
995
6841
Oris
sa
DW
L -
--
5567
0865
3340
252
1308
265
1277
4988
076
6499
330
0212
287
1997
852
3199
2049
19
WB
D
WL
--
-13
0966
861
1047
7349
3077
721
4970
7110
3976
569
1168
117
1203
2212
9625
7728
2757
T
OTA
L D
WL
--
-45
4382
605
2988
2294
1194
3166
7850
2331
348
5725
9121
7107
2424
8018
325
1547
5269
7596
706
TN
A
L 45
8904
3236
7123
519
9623
4-
--
--
--
--
T
OTA
L A
L 45
8904
3236
7123
519
9623
4-
--
--
--
--
T
OTA
L U
ASL
45
8904
3236
7123
519
9623
445
4382
605
2988
2294
1194
3166
7850
2331
348
5725
9121
7107
2424
8018
325
1547
5269
7596
706
(` in
cro
re)
Serv
ices
/Com
pany
Tota
l am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ct
DW
L
1
48.7
4
9.3
9
4
.12
AL
4.59
0.3
7
0
.20
TOTA
L U
ASL
153
.33
9
.76
4.3
2
Report No. 4 of 2016
- 261 -
Aircel
AN
NE
XU
RE
-8.0
4 [P
ara
8.2.
1 C
]Im
pact
on
paym
ent o
f LF
and
SUC
due
to n
on-c
onsi
dera
tion
of F
ree A
irtim
e (F
AT)
(Am
ount
in `
)
Serv
ices
/ L
SA
Com
pany
2
006-
07
200
7-08
2
008-
09
200
9-10
Am
ount
of
GR
/AG
R
LF
Impa
ct
SU
C
Impa
ct
Am
ount
of
GR
/AG
R
LF
Im-
pact
S
UC
Im
pact
A
mou
nt o
f G
R/A
GR
L
F Im
pact
S
UC
Im
pact
A
mou
nt o
f G
R/A
GR
L
F Im
pact
S
UC
Im
pact
HP
DW
L -
--
--
-18
0320
1081
942
3840
7300
2443
895
72
Ker
ala
DW
L -
--
--
-54
055
4324
1270
1481
5311
852
3482
UPE
D
WL
--
--
--
--
-92
4683
7397
521
730
UPW
D
WL
--
--
--
--
-22
1187
1769
551
98
WB
D
WL
3091
6224
733
7265
--
--
--
--
-
T
OTA
L D
WL
3091
6224
733
7265
--
-23
4375
1514
455
0817
0132
312
7960
3998
1
AP
AL
--
--
--
7497
1674
972
1761
890
8433
990
8434
2134
82
Del
hi
AL
--
--
--
--
-41
5365
841
5366
9345
7
Kar
nata
ka
AL
--
--
--
--
-20
0991
420
0991
4723
3
Mah
aras
htra
A
L -
--
--
--
--
8486
7184
867
1994
4
Mum
bai
AL
--
--
--
--
-69
6286
369
6286
1566
64
TN
A
L 16
0856
193
1286
8495
6997
244
2917
7723
2334
218
1269
231
--
-55
1492
0955
1492
123
9899
1
T
OTA
L A
L 16
0856
193
1286
8495
6997
244
2917
7723
2334
218
1269
231
7497
1674
972
1761
878
2086
5478
2086
529
2977
1
Che
nnai
A
CL
--
--
--
2830
4178
2830
418
1202
928
3402
9072
3402
907
1446
236
T
OTA
L A
CL
--
--
--
2830
4178
2830
418
1202
928
3402
9072
3402
907
1446
236
T
OTA
L U
ASL
16
1165
355
1289
3228
7004
510
2917
7723
2334
218
1269
231
2928
8268
2920
533
1226
054
1139
3904
911
3517
3244
1598
8
(`
in c
rore
)
Serv
ices
/Com
pany
Tota
l am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
DW
L
0.2
3
0.
02
0.0
1
AL
26.
90
2.31
1
.12
AC
L
6.2
3
0.
62
0.2
6
TOTA
L U
ASL
33.
36
2.95
1
.39
Report No. 4 of 2016
- 262 -
Aircel
ANNEXURE-8.05 [Para 8.2.1 D]Impact on payment of LF and SUC due to non-consideration of Discount ER
(Amount in `)
Services/LSA Company 2009-10
Amount of GR/AGR LF Impact SUC Impact
Karnataka AL 12015448 1201545 282363
Maharastra AL 2615017 261502 61453
Mumbai AL 13534767 1353477 304532
TOTAL UASL (AL) 28165232 2816523 648348
(` in crore)
Services/Company Total amount of GR/AGR LF Impact SUC Impact
TOTAL UASL (AL)
2.82
0.28
0.06
Report No. 4 of 2016
- 263 -
AircelA
NN
EX
UR
E-8
.06
[Par
a 8.
2.3]
Impa
ct o
n pa
ymen
t of L
F an
d SU
C d
ue to
non
-con
side
ratio
n of
Com
mis
sion
(Am
ount
in `
)
Serv
ices
/L
SAC
ompa
ny20
06-0
720
07-0
820
08-0
920
09-1
0
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
Ass
amD
WL
2643
1141
1585
868
7004
2578
1959
8346
9175
926
1956
510
9255
413
6555
325
3660
056
1355
3318
981
3199
145
4036
2
Bih
arD
WL
1283
3377
0030
1613
9083
3683
4500
3268
4634
9294
5520
9576
782
0842
6741
1195
4044
672
1584
163
HP
DW
L40
178
2411
944
9351
9656
112
2197
727
6934
916
6161
6508
091
6636
854
9982
2154
10
J&K
DW
L34
3907
820
6345
8081
817
7394
1010
6436
541
6876
4225
1708
2535
102
9929
1574
8834
5644
9300
717
5976
1
Ker
ala
DW
L-
--
--
-21
6690
1733
550
9216
2140
3912
9712
338
1030
Kol
kata
DW
L-
--
--
-79
4470
379
4470
1787
5627
5418
3927
5418
461
9691
NE
DW
L20
8414
9612
5049
048
9775
5281
3433
3168
806
1241
116
7673
7962
4604
278
1803
342
1112
5903
766
7554
226
1458
7
Odi
sha
DW
L42
1191
225
2715
9898
021
9370
0013
1622
051
5520
2743
0567
1645
834
6446
1844
5504
1526
7302
510
4693
5
UPE
DW
L-
--
--
-34
327
811
0521
6988
4173
2597
26
UPW
DW
L-
--
--
-13
010
312
7774
3210
2219
530
0270
WB
DW
L27
6384
222
1107
6495
016
5788
7213
2631
038
9603
2659
1716
2127
337
6249
0553
6507
3642
9205
912
6079
2
TO
TAL
DW
L57
8559
8035
2663
614
3890
920
2108
231
1245
8071
5531
503
3281
2803
620
5416
4887
9561
856
4039
876
3681
7954
1458
2727
AP
AL
--
--
--
7695
576
9618
0822
8432
1022
8432
153
6815
Del
hiA
L-
--
--
-42
718
4272
961
3174
1139
3174
114
7141
76
Kar
nata
kaA
L-
--
--
-16
1278
1612
837
9015
8523
5015
8523
537
2530
Mah
aras
htra
AL
--
--
--
--
-61
3000
561
3000
1440
55
Mum
bai
AL
--
--
--
--
-22
6651
2222
6651
250
9965
TNA
L14
5965
875
1167
7270
6349
516
2319
0815
218
5526
5210
0880
0528
0470
379
2804
7038
1220
0462
4421
6781
544
2167
8219
2343
00
TO
TAL
AL
1459
6587
511
6772
7063
4951
623
1908
152
1855
2652
1008
8005
2807
5133
128
0751
3312
2070
2154
1399
641
5413
9964
2151
1842
Che
nnai
AC
L68
3417
4068
3417
429
0452
497
1032
4297
1032
441
2688
810
0628
501
1006
2850
4276
711
1078
7348
910
7873
4945
8462
3
TO
TAL
AC
L68
3417
4068
3417
429
0452
497
1032
4297
1032
441
2688
810
0628
501
1006
2850
4276
711
1078
7348
910
7873
4945
8462
3
TO
TAL
UA
SL27
2163
595
2203
8080
1069
2948
5311
1962
540
7210
4819
7463
9670
9507
868
5867
9631
2527
9351
1213
3130
0510
1745
267
4067
9192
(` in
cro
re)
Serv
ice/
Com
-pa
nyTo
tal a
mou
nt o
f GR
/AG
RL
F Im
pact
SUC
Impa
ct
DW
L
1
15.2
0
7
.33
3.0
3
AL
120
.00
11.2
4
5
.02
AC
L
37.
40
3.7
4
1
.59
TOTA
L U
ASL
272
.60
22.3
1
9
.64
Report No. 4 of 2016
- 264 -
Aircel
AN
NE
XU
RE
-8.0
7 [P
ara
8.2.
4]Im
pact
on
paym
ent o
f LF
and
SUC
due
to n
on-c
onsi
dera
tion
of In
com
e on
acc
ount
of M
arke
t Sto
ck
(Am
ount
in `
)
Serv
ices
/LSA
Com
pany
2008
-09
2009
-10
Am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
Bih
ar
DW
L 25
5861
1535
260
13-
--
T
OTA
L D
WL
2558
6115
352
6013
--
-
AP
AL
1329
133
3159
5064
5950
613
984
Del
hi
AL
2105
211
4788
0465
8804
619
810
Kar
nata
ka
AL
2979
298
7044
6185
4461
910
485
Mah
aras
htra
A
L -
--
1746
3417
463
4104
Mum
bai
AL
--
-61
7634
6176
313
897
TN
A
L 81
0614
881
0615
3526
1713
0959
4513
0959
456
9674
T
OTA
L A
L 81
1256
281
1256
3527
6615
8099
2615
8099
363
1954
Che
nnai
A
CL
2439
333
2439
3310
3672
7340
571
7340
5731
1974
T
OTA
L A
CL
2439
333
2439
3310
3672
7340
571
7340
5731
1974
TO
TAL
UA
SL10
8077
5510
7054
146
2450
2315
0497
2315
050
9439
28
(` in
cro
re)
Serv
ice/
Com
pany
Tota
l am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
DW
L
0
.03
0.0
0
0.
00
AL
2.3
9
0
.24
0.10
AC
L
0
.98
0.1
0
0.
04
TOTA
L U
ASL
3.4
0
0
.34
0.14
Report No. 4 of 2016
- 265 -
AircelA
NN
EX
UR
E-8
.08
[Par
a 8.
2.5]
Impa
ct o
n pa
ymen
t of L
F an
d SU
C d
ue to
non
-con
side
ratio
n of
Site
shar
ing
inco
me
(Am
ount
in `
)
Serv
ices
/LSA
Com
pany
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f GR
/A
GR
LF
Impa
ctSU
C Im
pact
Ass
am
DW
L 24
2130
1452
864
1625
1061
815
0637
8410
682
0920
549
2552
2750
0893
1069
455
8642
3119
08 B
ihar
D
WL
--
-97
8860
758
7316
2300
3243
7047
1226
2228
310
2706
136
7412
9722
0447
886
3420
HP
DW
L -
--
--
-17
3273
8810
3964
340
7194
1158
1800
6949
0827
2172
J &
K
DW
L -
--
3906
106
2343
6691
793
1810
6475
1086
389
4255
0219
8554
1711
9132
546
6602
Ker
ala
DW
L -
--
--
-12
010
357
3468
845
8775
1347
65 K
olka
ta
DW
L -
--
--
-35
0707
035
0707
7890
923
9894
923
9895
5397
6 N
E D
WL
--
-25
4070
415
2442
5970
765
7970
539
4782
1546
2366
5343
539
9206
1563
56 O
rissa
D
WL
1767
6410
606
4154
6593
286
3955
9715
4942
3064
6165
1838
770
7201
8511
4399
0368
6394
2688
38 U
PW
DW
L -
--
--
--
--
4199
443
3359
5598
687
WB
D
WL
--
-16
0717
1012
8573
737
7685
2243
7758
1795
021
5272
8712
8453
4310
2762
730
1866
T
OTA
L D
WL
UA
SL
4188
9425
134
1057
041
4110
3128
0609
699
8265
1505
1859
896
2015
636
1577
212
0760
969
7797
206
2928
591
AP
AL
--
--
--
1080
110
8025
432
2522
632
2523
7579
3 D
elhi
A
L -
--
--
-17
108
1711
385
4451
868
4451
8710
0167
Kar
nata
ka
AL
--
--
--
2421
324
2156
921
5554
621
5555
5065
5 M
ahar
asht
ra
AL
--
--
--
--
-72
7555
972
7556
1709
76 M
umba
i A
L -
--
--
--
--
3505
235
3505
2378
868
TN
A
L 18
3697
1414
6957
779
9083
6130
7886
4904
631
2666
893
6587
7511
6587
751
2865
672
6177
3754
6177
375
2687
158
T
OTA
L A
L 18
3697
1414
6957
779
9083
6130
7886
4904
631
2666
893
6592
9634
6592
963
2866
880
8238
7188
8238
719
3163
617
Che
nnai
A
CL
2664
7955
2664
796
1132
538
3211
2735
3211
274
1364
791
3519
0829
3519
083
1495
610
3612
9772
3612
977
1535
515
T
OTA
L A
CL
2664
7955
2664
796
1132
538
3211
2735
3211
274
1364
791
3519
0829
3519
083
1495
610
3612
9772
3612
977
1535
515
TO
TAL
UA
SL45
4365
6341
5950
619
4219
113
4831
652
1092
2000
5029
950
2516
3906
119
7322
0379
7826
223
9277
929
1964
8902
7627
723
NL
D
DW
L -
--
--
-10
774
646
--
--
ILD
D
WL
--
--
--
8938
536
--
--
ISP
DW
L -
--
--
-62
8237
7-
--
-
G
RA
ND
TO
TAL
4543
6563
4159
506
1942
191
1348
3165
210
9220
0050
2995
025
1665
056
1973
3762
7978
262
2392
7792
919
6489
0276
2772
3
(` in
cro
re)
Serv
ices
/Com
pany
Tota
l am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
NL
D
0.0
0
0.00
-
ILD
0
.00
0.
00
- IS
P
0.0
0
0.00
-
DW
L U
ASL
31.
31
2.
03
0
.76
AL
UA
SL
22.
80
2.
12
0
.95
AC
L U
ASL
13.
01
1.
30
0
.55
GR
AN
D T
OTA
L
6
7.12
5.
45
2
.26
Report No. 4 of 2016
- 266 -
Aircel
AN
NE
XU
RE
-8.0
9 [P
ara
8.2.
6]Im
pact
on
paym
ent o
f LF
and
SUC
due
to n
on-c
onsi
dera
tion
of F
orex
gai
n in
com
e(A
mou
nt in
`)
Serv
ices
/LSA
Com
pany
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
pact
Ass
am
DW
L -
--
1053
2563
1935
2830
901
1854
1035
3040
918
2510
19 B
ihar
D
WL
--
-20
810
1249
489
1085
065
125
515
904
954
374
HP
DW
L -
--
1958
117
4691
055
2120
5612
348
J &
K
DW
L -
--
1479
0088
7434
7611
555
693
272
1821
710
9342
8 K
eral
a D
WL
--
--
--
534
124
321
1946
572
Kol
kata
D
WL
--
-5
--
1131
8311
318
2547
1018
079
1018
0822
907
NE
DW
L -
--
6694
140
1615
7320
041
1202
471
2285
113
7153
7 O
rissa
D
WL
--
-30
447
1827
716
8188
491
192
1047
562
824
6 U
PE
DW
L -
--
--
--
--
4968
3004
3974
640
1167
551
UPW
D
WL
--
--
--
3864
830
9290
842
7521
3634
2017
110
0467
5 W
B
DW
L -
--
2209
717
6851
978
6562
918
512
466
997
293
T
OTA
L D
WL
- -
- 39
5483
2417
110
347
2421
9419
990
5887
9358
9918
7505
557
2198
649
AP
AL
--
--
--
409
4110
2711
4327
114
6372
Del
hi
AL
--
--
--
647
6515
9393
223
9393
2221
1348
Kar
nata
ka
AL
--
--
--
916
9222
2033
0620
331
4778
Mah
aras
htra
A
L -
--
--
--
--
7957
379
5718
70 M
umba
i A
L -
--
--
--
--
1445
7724
1445
772
3252
99 T
N
AL
--
--
--
1639
678
1639
6871
326
5967
217
5967
2225
9574
T
OTA
L A
L -
- -
- -
- 16
4164
916
4165
7137
230
3721
8630
3721
980
9240
Che
nnai
A
CL
--
--
--
--
-31
100
3110
1322
T
OTA
L A
CL
- -
- -
- -
- -
- 31
100
3110
1322
T
OTA
L U
ASL
-
- -
3954
8324
171
1034
718
8384
318
4155
7725
912
3993
203
1054
5885
3009
211
NL
D
DW
L -
--
1023
61-
4734
284
-49
9243
429
9546
- IL
D
DW
L -
--
- -
- 23
5554
214
1333
-32
0062
619
2038
- IS
P D
WL
1306
6278
40-
1415
4879
8492
93-
8597
351
58-
8601
851
61-
G
RA
ND
TO
TAL
1306
6278
40-
1455
1385
8735
2510
347
4330
093
3309
3077
259
1322
7228
111
0426
3030
0921
1
(` in
cro
re)
Serv
ices
/Com
pany
Tota
l am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
NL
D0.
50
0.03
-
ILD
0.56
0.
03
-IS
P1.
45
0.09
-
DW
L U
ASL
9.42
0.
76
0.22
A
L U
ASL
3.
20
0.32
0.
09
AC
L U
ASL
0.00
0.
00
0.00
G
RA
ND
TO
TAL
15.1
3 1.
23
0.31
Report No. 4 of 2016
- 267 -
AircelA
NN
EX
UR
E-8
.10
[Par
a 8.
2.7]
Impa
ct o
n pa
ymen
t of L
F an
d SU
C d
ue to
non
-con
side
ratio
n of
Inte
rezs
t on
depo
sits
(Am
ount
in `
)
Serv
ices
/LSA
Com
pany
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
Am
ount
of G
R/
AG
RL
F Im
pact
SUC
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C Im
-pa
ctA
mou
nt o
f GR
/A
GR
LF
Impa
ctSU
C Im
pact
Ass
amD
WL
1896
3782
411
3782
6950
2540
288
3254
6152
9952
829
5890
334
1512
3720
4907
411
4406
641
9546
825
1728
1405
48B
ihar
DW
L91
7345
5504
121
558
1745
1356
1047
081
4101
0711
9908
1371
9449
2817
8421
9427
313
1656
5156
5H
PD
WL
7615
2045
691
1789
616
4219
898
532
3859
210
0592
560
356
2363
934
8650
2091
981
93J&
KD
WL
3178
1616
1906
897
7468
6821
0247
8212
6148
749
4082
1277
0389
7662
2330
0104
2756
056
1653
6364
767
Ker
ala
DW
L-
--
00
058
081
4647
1365
4934
1339
473
1159
5K
olka
ttaD
WL
--
-39
6039
689
2968
710
2968
7166
796
9645
5196
455
2170
2N
ED
WL
1289
8528
577
3911
730
3115
456
1367
3733
6820
413
1921
322
1489
5113
2893
752
0500
3191
539
1914
9275
001
Oris
saD
WL
3224
2825
1934
570
7577
0628
3779
3317
0267
666
6881
9049
465
5429
6821
2662
1708
239
1024
9440
144
UPE
DW
L-
--
--
-98
82
3247
6325
981
7632
UPW
DW
L-
--
--
-71
62
3772
2130
178
8865
WB
DW
L20
1323
9916
1059
247
3111
1858
6709
1486
937
4367
8886
9198
469
5359
2042
6218
1700
914
5361
4270
0
TO
TAL
DW
L U
ASL
4044
5881
424
6701
7710
0736
9623
1549
137
1426
4841
6324
655
1028
3572
464
6389
727
5518
318
3711
8212
0110
147
2713
AP
AL
--
--
--
1828
183
4353
5283
753
5284
1257
92D
elhi
AL
--
--
--
2896
290
6583
4242
683
4243
1877
05K
arna
taka
AL
--
--
--
4098
410
9640
1361
840
1362
9432
0M
ahar
asht
raA
L-
--
--
--
--
1570
902
1570
9036
916
Mum
bai
AL
--
--
--
--
-55
5663
355
5663
1250
24TN
AL
--
--
--
1115
0083
1115
008
4850
2911
8287
822
1182
8782
5145
520
TO
TAL
AL
--
--
--
1115
8905
1115
891
4852
3314
3124
239
1431
2424
5715
277
Che
nnai
A
CL
--
--
--
2185
479
2185
4892
883
1554
1312
1554
131
6605
06
TOTA
L A
CL
- -
- -
- -
2185
479
2185
4892
883
1554
1312
1554
131
6605
06
TO
TAL
UA
SL
4044
5881
424
6701
7710
0736
9623
1549
137
1426
4841
6324
655
1161
8010
877
9833
533
3329
917
7036
733
1706
7656
6848
496
NL
DD
WL
--
-86
5824
5194
9-
5232
119
3139
27-
2770
787
1662
47-
ILD
DW
L-
--
--
-43
4079
026
0447
-24
7824
514
8695
-IS
PD
WL
3246
9640
1948
178
-81
2277
348
7366
-30
5093
818
3056
-32
3823
1942
9-
G
RA
ND
TO
-TA
L43
6928
454
2661
8355
1007
3696
2405
3773
414
8041
5763
2465
512
8803
955
8555
766
3333
299
1826
0958
817
4020
2768
4849
6
(` in
cro
re)
Serv
ices
/Com
pany
Tota
l am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
NL
D0.
89
0.05
-
ILD
0.68
0.
04
- IS
P4.
40
0.27
-
DW
L U
ASL
75.7
2 4.
66
1.96
A
L U
ASL
15
.43
1.54
0.
62
AC
L U
ASL
1.77
0.
18
0.08
G
RA
ND
TO
TAL
98.8
9
6.7
4
2.
66
Report No. 4 of 2016
- 268 -
Aircel
AN
NE
XU
RE
-8.1
1 [P
ara
8.2.
8]Im
pact
on
paym
ent o
f LF
and
SUC
due
to n
on-c
onsi
dera
tion
of In
tere
st o
n In
vest
men
ts(A
mou
nt in
`)
Serv
ices
/LSA
Com
pany
2008
-09
2009
-10
Am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
AP
AL
2336
234
5526
4086
926
4087
6206
0
Del
hiA
L37
0037
083
3907
470
3907
4787
918
Kar
nata
kaA
L52
3652
412
319
8015
419
8015
4653
4
Mah
aras
htra
AL
--
-77
5018
7750
218
213
Mum
bai
AL
--
-27
4103
527
4104
6167
3
TNA
L14
2459
9614
2460
061
9701
5811
9306
5811
931
2528
190
TO
TAL
AL
1425
7267
1425
727
6199
6270
1638
5370
1638
528
0458
8
Che
nnai
AC
L-
--
5676
401
5676
4024
1247
TO
TAL
AC
L-
- -
5676
401
5676
4024
1247
TO
TAL
UA
SL14
2572
6714
2572
761
9962
7584
0254
7584
025
3045
835
(` in
cro
re)
Serv
ices
/Com
pany
Tota
l am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
AL
8
.44
0.
84
0.3
4
AC
L
0.5
7
0.06
0
.03
TOTA
L U
ASL
9
.01
0.
90
0.3
7
Report No. 4 of 2016
- 269 -
Aircel
ANNEXURE-8.12 [Para 8.2.9 (i)]Impact on payment of LF and SUC due to non-consideration of Corporate income (Composite contract/
Software services/Project management income)(Amount in `)
Services/LSA Company
2006-07 2008-09
Amount of GR/AGR LF Impact SUC Impact Amount of
GR/AGR LF Impact SUC Impact
Assam DWL 406195115 24371707 10764171 221803 13308 7430
Bihar DWL 1964555 117873 46167 77908 4675 1831
HP DWL 1580999 94860 37153 6524 391 153
J & K DWL 67880050 4072803 1595181 82932 4976 1949
Kerala DWL - - - 375 30 9
Kolkata DWL - - - 19271 1927 434
Orissa DWL 69068138 4144088 1623101 58787 3527 1382
WB DWL 43061173 3444894 1011938 56463 4517 1327
NE DWL 276207065 16572424 6490866 143819 8629 3380
TOTAL DWL UASL 865957093 52818649 21568577 667882 41981 17894
NLD DWL - - - 33968 2038 -
ILD DWL - - - 28194 1692 -
ISP DWL 69545244 4172715 - 19796 1188 -
GRAND TOTAL 935502337 56991364 21568577 749840 46898 17894
(` in crore)
Services/Company Total amount of GR/AGR LF Impact SUC Impact
DWL UASL 86.67 5.29 2.16
NLD 0.00 0.00 -
ILD 0.00 0.00 -
ISP 6.96 0.41 -
TOTAL UASL 93.63 5.70 2.16
Report No. 4 of 2016
- 270 -
Aircel
AN
NE
XU
RE
-8.1
3 [P
ara
8.2.
9(ii)
]Im
pact
on
paym
ent o
f LF
and
SUC
due
to n
on-c
onsi
dera
tion
of N
otic
e Pa
y(A
mou
nt in
`)
Serv
ices
/L
SAC
ompa
ny20
06-0
720
07-0
820
08-0
920
09-1
0A
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C
Impa
ctA
mou
nt o
f G
R/A
GR
LF
Impa
ctSU
C
Impa
ct K
eral
aD
WL
--
--
--
5876
147
0113
8169
8341
5586
716
411
Ass
amD
WL
3669
7922
019
9725
3107
9818
648
1041
224
6993
214
8196
8274
345
2145
2712
915
147
Bih
ar
DW
L31
348
1881
737
5081
0330
486
1194
023
2126
813
9276
5455
023
6937
1421
655
68H
PD
WL
8366
502
197
1477
8688
6734
7328
9787
1738
768
1057
8088
3468
513
585
J&K
DW
L15
0175
9011
3529
2429
2514
576
5709
1481
766
8890
634
822
1113
517
6681
126
168
Kol
kata
DW
L86
321
8632
021
8535
2185
349
1718
9616
118
9616
4266
439
2093
239
2093
8822
1N
ED
WL
1971
9811
832
4634
1745
5010
473
4102
1445
352
8672
133
966
3396
0920
377
7981
Oris
saD
WL
1702
2810
214
4000
3446
1720
677
8098
1650
699
9904
238
791
1616
018
9696
137
976
UPE
DW
L-
--
--
-19
3624
1549
045
5014
1058
211
2847
3314
9U
PWD
WL
--
--
--
4030
932
2594
740
763
3261
958
WB
DW
L23
0557
1844
554
1858
0255
4642
013
636
1736
938
1389
5540
818
1634
955
1307
9638
421
TO
TAL
DW
L U
ASL
1241
173
8253
428
240
2527
568
1720
0162
287
1358
4597
9315
1534
2041
1204
1886
9550
4328
3585
AP
AL
--
--
--
3356
033
5678
962
8133
6281
314
761
Del
hiA
L-
--
--
-24
614
2461
554
1433
143
1433
1432
246
Kar
nata
kaA
L-
--
--
-17
8542
1785
441
9620
0507
420
0507
4711
9M
ahar
asht
raA
L-
--
--
--
--
2637
1226
371
6197
Mum
bai
AL
--
--
--
2662
4626
625
5991
1798
996
1799
0040
477
TNA
L67
6619
6766
229
433
1190
200
1190
2051
774
2043
577
2043
5888
896
2280
790
2280
7999
214
TO
TAL
AL
6766
1967
662
2943
311
9020
011
9020
5177
425
4654
025
4654
1004
2484
0984
984
0985
2400
15C
henn
aiA
CL
1807
0418
070
7680
8507
9085
079
3615
984
0768
8407
735
733
1867
081
1867
0879
351
TO
TAL
AC
L18
0704
1807
076
8085
0790
8507
936
159
8407
6884
077
3573
318
6708
118
6708
7935
1
TOTA
L U
ASL
2098
496
1682
6765
353
4568
558
3761
0015
0220
1697
1905
1270
246
4781
9822
3188
1619
8273
660
2951
NL
DD
WL
--
-12
1573
-26
9238
1615
4-
2985
9617
916
-IL
DD
WL
--
--
--
2233
7513
403
-26
7085
1602
5-
ISP
DW
L45
2036
2712
2-
6887
3941
324
-10
0153
060
092
-64
9863
3899
2-
G
RA
ND
TO
TAL
2550
532
1953
8965
353
5258
511
4174
9715
0220
1846
6048
1359
894
4781
9823
5343
6020
5566
960
2951
(` in
cro
re)
Serv
ices
/Com
pany
Tota
l am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
NL
D
0.0
6
0.0
0
-
IL
D
0.0
5
0.0
0
-
IS
P
0.2
8
0.0
2
-
D
WL
UA
SL
2.9
4
0.2
1
0.0
7 A
L U
ASL
1.2
8
0.1
3
0.0
4 A
CL
UA
SL
0.3
7
0.0
4
0.0
2 G
RA
ND
TO
TAL
4
.98
0
.40
0
.13
Report No. 4 of 2016
- 271 -
AircelA
NN
EX
UR
E-8
.14
[Par
a 8.
2.9(
iii)]
Impa
ct o
n pa
ymen
t of L
F an
d SU
C d
ue to
non
-con
side
ratio
n of
Oth
er In
com
e (A
mou
nt in
`)
Serv
ices
/LSA
Com
pany
2006
-07
2007
-08
2008
-09
2009
-10
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
Am
ount
of
GR
/AG
RL
F Im
pact
SUC
Im
pact
Am
ount
of
GR
/A
GR
LF
Impa
ctSU
C
Impa
ctA
mou
nt o
f GR
/A
GR
LF
Impa
ctSU
C Im
pact
Ass
amD
WL
--
--
--
--
-22
2914
413
3749
7467
6B
ihar
DW
L-
--
--
--
--
1165
865
6995
227
398
HP
DW
L-
--
--
--
--
1507
2790
4435
42J&
KD
WL
9200
155
2021
62-
--
--
-28
5099
917
1060
6699
8K
eral
aD
WL
--
-10
3182
5-
--
1402
210
1121
7732
952
Kol
katta
DW
L-
--
--
--
--
4971
9149
719
1118
7N
ED
WL
2201
413
2151
7-
--
--
-16
7515
410
0509
3936
6O
rissa
DW
L91
455
21-
--
--
-76
7876
4607
318
045
UPE
DW
L-
--
--
--
--
1725
5413
804
4055
UPW
DW
L-
--
--
--
--
2004
2616
034
4710
WB
DW
L31
7525
475
--
--
--
3653
1529
225
8585
TO
TAL
DW
L U
ASL
1181
0471
5027
7510
3182
5-
- -
1147
7462
7513
4529
1515
AP
AL
--
--
--
--
-12
490
1249
294
Del
hiA
L-
--
--
--
--
1848
018
4841
6K
arna
taka
AL
--
--
--
--
-93
6593
722
0M
ahar
asht
raA
L-
--
--
--
--
3665
367
86M
umba
iA
L-
--
--
--
--
1296
312
9629
2TN
AL
--
--
--
--
-27
4869
2748
711
957
TO
TAL
AL
- -
- -
- -
- -
- 33
1832
3318
313
264
Che
nnai
-
--
--
-92
8578
9285
839
465
--
-
TOTA
L A
CL
- -
- -
- -
9285
7892
858
3946
5-
- -
TO
TAL
UA
SL11
8104
7150
2775
1031
825
9285
7892
858
3946
511
8092
9478
4529
3047
79N
LD
DW
L-
--
897
54-
--
-14
7218
088
331
-IL
DD
WL
--
--
--
--
-83
3424
5000
5-
ISP
DW
L-
--
--
--
--
7432
9544
598
-
GR
AN
D T
OTA
L11
8104
7150
2775
1928
136
592
8578
9285
839
465
1485
8193
9674
6330
4779
(` in
cro
re)
Serv
ices
/Com
pany
Tota
l am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
NL
D
0.15
0
.01
-
IL
D
0.08
0
.01
-
IS
P
0.08
0
.00
-
D
WL
UA
SL
1.16
0
.08
0.03
A
L U
ASL
0.03
0
.00
0.00
A
CL
UA
SL
0.09
0
.01
0.00
G
RA
ND
TO
TAL
1.
59
0.1
1
0.
03
Report No. 4 of 2016
- 272 -
Aircel
ANNEXURE -8.15 [Para 8.2.10]Statement showing the Profit on Sale of Assets Netted off with Loss on sale of assets-
Dishnet Wireless Ltd -2007-2008(Amount in `)
GL Account Name of the Account Amount(Credit amount/Gain)
Amount (Debit amount/Loss)
4900022 Profit on Sale of Plant & Machinery 6800
4900023 Profit on Sale of Office Equipment 43498
4900024 Profit on Sale of Computer System & software 1573407
4900025 Profit on Sale of Furniture and Fittings 121917
4900026 Profit on Sale of Vehicles 368136
4900028 Profit on Sale of Bandwidth 98225000
4900029 Profit on Sale of Low VSAT 31300
3350209 Loss on Sale of Plant & Machinery 203365
3350210 Loss on Sale of Office Equipment 69834
3350211 Loss on Sale of Computer System & Software 6977
3350210 Loss on Sale of Furniture and Fittings 556345
Gross figure 100370058 836521
Net Amount as per Financial Statement 99533537
Say ` 10.04 crore
Report No. 4 of 2016
- 273 -
Aircel
ANNEXURE -8.16 [Para 8.2.10]Statement showing the Profit on Sale of Assets Netted off with Loss on sale of assets-Aircel Ltd -2009-2010
(Amount in `)
Period GL Account and Name of the Account GL Balance Amount
Amount as per TB/SAP
Gross Revenue of Profit on
sale of assets
Amount included in
the AGR
Amount not considered in
the AGR
2006-07 GL-4900026-Profit on sale of Vehicles 335189 335189 335189 335189 -
2007-08 GL-4900026-Profit on sale of Vehicles 2201771 2201771 2201771 2201771 -
2008-09 GL-4900026-Profit on sale of Vehicles - - - -
2009-10 GL-3303009-R&M Others 236468441** 236468441** 238775552*** - 238775552
2009-10 GL-3350209-Loss on sale of P&M 2005987* 2005987* - - -
As per Financial statement (Sch-12) -Other income (Net amount was booked.)
234462454#*
TOTAL 238775552
Say ` 23.88 crore
*Represents debit balance/loss .#* Represents ** minus *** This is after netting off the debit balances of ` 2307112 (under the Business Areas of Karnataka- ` 63600 Andhra Pradesh- ` 220476 Delhi- ` 2020466 and Rest of Maharashtra- ` 2570) which has been added back to arrive at Gross Revenue.*** Includes ` 2307112 being the debit balances added back.
Report No. 4 of 2016
- 274 -
Aircel
ANNEXURE -8.17 [Para 8.2.10]Statement showing the Profit on Sale of Assets Netted off with Loss on sale of assets
M/s Aircel Cellular Ltd -2007-2008 and 2009-10
(Amount in `)
Period GL Account and Name of the Account
GL Balance as per TB
Amount as per Finance Statement
Gross revenue of Profit on
sale of assets
Amount included in
the AGR
Amount not considered in the
AGR
2006-07 GL-4900022- Profit on sale of Plant & Machinery - - - - -
2007-08 GL-4900022- Profit on sale of Plant & Machinery 220835 220835 220835 75800 145035
2008-09 GL-4900022-Profit on sale of Plant and Machinery 322981 322428* 322981 322981 -
2009-10 GL-3303009-Repairs & Maintenance –Others 72404196 72404196 72404196 - 72404196
Total 72549231
Say ` 7.25 crore
*The loss on Sale of Furniture and Fittings ( Account Head 3350212) – ` 553 has been adjusted.
Report No. 4 of 2016
- 275 -
Aircel
AN
NE
XU
RE
- 8.1
8 [P
ara
8.2.
10]
Impa
ct o
n pa
ymen
t of L
F an
d SU
C d
ue to
non
-con
side
ratio
n of
Pro
fit o
n Sa
le o
f Ass
ets
(Am
ount
in `
)
Serv
ices
/LSA
Com
pany
2007
-08
2009
-10
Am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
Am
ount
of G
R/A
GR
LF
Impa
ctSU
C Im
pact
Ass
amD
WL
7977
8947
867
2672
6-
--
Bih
arD
WL
1576
2794
5837
04-
--
HP
DW
L14
833
890
349
--
-J&
KD
WL
1886
0811
316
4432
--
-K
olka
taD
WL
364
--
-N
ED
WL
5070
4830
423
1191
6-
--
Oris
saD
WL
2306
2613
838
5420
--
-W
BD
WL
1673
7613
390
3933
--
-
TOTA
L D
WL
UA
SL20
6394
312
7186
5648
1
-
-
-
AP
AL
--
-64
5645
6456
515
173
Del
hiA
L-
--
9553
0695
531
2149
4K
arna
taka
AL
--
-48
4112
4841
111
377
Mah
aras
htra
AL
--
-18
9478
1894
844
53M
umba
iA
L-
--
2926
703
2926
7065
851
TNA
L-
--
2335
7430
823
3574
3110
1604
82
TOTA
L A
L
-
-
-
2387
7555
223
8775
5510
2788
30C
henn
ai
1450
3514
503
6164
7240
4196
7240
420
3077
178
TO
TAL
AC
L14
5035
1450
361
6472
4041
9672
4042
030
7717
8
TOTA
L U
ASL
2208
977
1416
8962
644
3111
7974
831
1179
7513
3560
08N
LD
DW
L98
2327
4758
9396
5-
--
-IS
PD
WL
7336
844
02-
--
-
GR
AN
D T
OTA
L10
0515
093
6040
056
6264
431
1179
748
3111
7975
1335
6008
(` in
cro
re)
Serv
ices
/Com
pany
Tota
l am
ount
of
GR
/AG
RL
F Im
pact
SUC
Impa
ct
NL
D
9.
82
0
.59
-
IS
P
0.
01
0
.00
-
D
WL
UA
SL
0.
21
0
.01
0.0
1 A
L U
ASL
23.
88
2
.39
1.0
3 A
CL
UA
SL
7.
25
0
.73
0.3
0 G
RA
ND
TO
TAL
4
1.17
3.7
2
1
.34
Report No. 4 of 2016
- 276 -
Aircel
AN
NE
XU
RE
-8.1
9 [P
ara
8.3.
2]Im
pact
on
paym
ent o
f LF
due
to n
on-c
onsi
dera
tion
of e
xces
s ded
uctio
n cl
aim
ed o
n ac
coun
t of I
nter
net s
ervi
ces
(Am
ount
in `
)
Com
pany
GL
Cod
e D
escr
iptio
n 2
006-
07
200
7-08
2
008-
09
200
9-20
10
Tot
al
DW
L (I
SP)
4004
119
INC
OM
E FR
OM
LEA
SE L
INE
REG
ISTR
ATIO
N
INTE
R C
O
--
-15
0360
1503
60
4004
120
INC
OM
E FR
OM
LEA
SE L
INE
REN
TAL
INTE
R C
O
--
-27
3808
3627
3808
36
4006
003
INC
OM
E FR
OM
LEA
SE L
INE-
MO
NTH
LT R
ENTA
L 12
4231
455
1824
4948
726
9994
150
2458
6289
382
2537
985
4006
004
INC
OM
E FR
OM
LEA
SE L
INE-
REG
ISTR
ATIO
N
CH
AR
GES
18
8774
765
6663
512
3401
9316
0078
9036
8024
65
4008
001
INC
OM
E FR
OM
WIF
I 17
5066
178
9574
4621
4529
2718
3295
098
4006
900
INC
OM
E FR
OM
INTE
R D
IVIS
ION
AL
SERV
ICES
(A
mou
nt re
late
s to
Port
Cha
rges
onl
y)36
8594
327
3336
975
7152
097
3576
323
7265
95
Tota
l13
1555
806
1925
3906
529
0368
008
2994
3046
091
3893
340
As P
ER A
GR
1363
4489
821
0442
383
3012
6652
731
7149
012
9652
0282
0
Am
ount
exc
ess c
laim
ed a
s ded
uctio
n47
8909
217
9033
1810
8985
1917
7185
5251
3094
80
LF
Am
ount
2873
4610
7419
965
3911
1063
113
3078
569
(` in
cro
re)
Am
ount
of G
R/A
GR
LF
Impa
ct (@
6%)
5.13
0.31
Report No. 4 of 2016
- 277 -
AircelA
NN
EX
UR
E-8
.20
[Par
a 8.
4]St
atem
ent s
how
ing
inte
rest
on
LF
and
SUC
upt
o M
ar 2
015
(Am
ount
in `
)
Sl
No.
A
nnex
No.
of M
onth
s(up
to M
arch
15
)96
8472
60
TOTA
LR
ate@
(PL
R+2
)%14
.25
14.2
514
.25
13.7
5
Issu
es
2006
-07
2007
-08
2008
-09
2009
-10
Inte
rest
on
LF
Inte
rest
on
SUC
Inte
rest
on
LF
Inte
rest
on
SUC
Inte
rest
on
LF
Inte
rest
on
SUC
Inte
rest
on
LF
Inte
rest
on
SUC
18.
2.1A
Wai
vers
, Dis
coun
ts, P
rom
o of
fers
, etc
9152
2169
4505
6243
3097
7320
1530
6490
5146
7255
2216
3379
3051
3500
1225
9863
2992
6621
9
28.
2.1B
Ful
l Tal
k Ti
me
7731
034
4203
750
5066
8659
2025
0930
6506
5945
2908
2837
1518
0910
7452
207
1996
3627
2
38.
2.1C
FAT
2715
1082
1475
0380
3957
919
2152
118
3912
232
1642
374
1113
5808
4331
990
6903
3903
48.
2.1D
Dis
coun
t ER
--
--
--
2762
949
6360
1633
9896
5
58.
2.3
Com
mis
sion
4640
8680
2251
7644
6904
6938
3348
2148
7860
4941
3386
3230
9980
9942
3990
5422
4236
3894
6
68.
2.4
Mar
ket s
tock
--
--
1434
055
6194
8122
7101
592
5974
5250
524
78.
2.5
Site
shar
ing
reve
nue
8759
257
4089
944
1851
9432
8528
823
2643
4577
1068
7368
1927
5154
7482
634
1037
7719
0
88.
2.6
Fore
x16
509
-14
8115
617
545
4433
0110
3493
1083
2585
2951
972
1584
6561
98.
2.7
Inte
rest
on
depo
sits
5605
4010
2121
3596
2510
2048
1072
4137
1146
0969
4465
157
1707
1019
6718
229
1528
0916
4
108.
2.8
Inte
rest
on
inve
stm
ent
--
--
1909
848
8304
7774
3976
829
8790
013
1679
92
118.
2.9(
i)C
orpo
rate
(Com
posi
te)
Inco
me
1200
1472
045
4199
83-
-62
823
2397
0-
-16
5521
496
128.
2.9(
ii)N
otic
e Pa
y41
1458
1376
2370
7911
2547
1318
2166
164
0576
2016
567
5914
8265
8199
1
138.
2.9(
iii)
Oth
er In
com
e15
056
5845
231
912
4389
5286
594
9060
2989
8114
4643
6
148.
2.10
Profi
t on
sale
of a
sset
s-
-10
2415
6810
6220
--
3052
6071
1310
1960
5397
5819
158.
3.1
Ded
uctio
n of
Bad
Deb
t writ
-te
n of
f-
--
--
-24
2340
1110
2994
5534
5334
66
168.
3.2
ISP
Ded
uctio
n60
5104
-18
2142
1-
8759
54-
1042
891
-43
4537
0
TO
TAL
3586
8907
915
7395
007
2125
2460
290
8231
3424
3617
950
1041
7520
727
5061
252
1099
4408
215
5223
0313
Say
` 1
55.2
2 cr
ore
Report No. 4 of 2016
- 278 -
Airtel
ANNEXURE 9.01 [Para 9.2.7]Disallowance of deduction claim in spite of availability of proof
Name of the TSP
Deduction disallowed by
CCA (` in crore)
Audit Observation Response of CsCA
BAL 7.85
Deduction claim disallowed despite availability of required document
Out of 4 LSAs, in 3 LSAs CCA accepted audit observation and reply awaited from one LSA
VODAFONE 378.33
Deduction claim disallowed despite availability of required document by 8 CsCA
CsCA Gujarat, Haryana and Mumbai replied that the cases would be considered during re-verification. CCA Kerala informed that bank statements were not available and CCA Punjab replied that invoices not available while in both the cases relevant document were available. Reply from other CsCA were awaited.
RCL 128.17
CCA Kolkata and CCA Bhopal disallowed the deduction claims of PSTN charges despite availability of proof documents
CCA Kolkata replied that the amount was inadvertently disallowed by arithmetical mistake.
Replies from CCA Bhopal was awaited
IDEA 23.78
(i) Deduction claim of ` 11.69 crore in respect of PSTN charges,
(ii) ` 14.50 crore national / international roaming charges
(i) CCA Bangalore accepted the contention of audit and stated that fact will be intimated to DoT hqrs. CCA Punjab replied that claim was disallowed inadvertently
(ii) CCA Delhi replied that invoices have been raised by MACH and payment was also paid to MACH and hence deduction was not allowed. However DoT specifically stated that Roaming settlement of account authenticated by operator may be considered.
In respect of inter-circle roaming, Pr. CCA Delhi accepted audit contention
TTSL /TTML 85.76
Deduction on IUC disallowed despite availability of auditor certificate and proof of payment
CCAs replied that (i) the matter would be replied on request from licensee (ii) the claimed amount was not reflected in the auditor’s certificate
CCA
Report No. 4 of 2016
- 279 -
Airtel
NNEXURE 9.02 [Para 9.2.9(f)]
Delay in submission of verification report by CsCA and re-verification
(A ) Delay in submission of verification report by CsCA
Year No. of LSAs
No. of LSAs where details
of delay available
No. of LSAs that submitted verification
reports on or before due date
No. of LSAs that did
not submit verification
reports on or before due
date
Delay ranging from ( in months)
2006-07 116 13 Nil 13 3 to 302007-08 117 16 Nil 16 4 to 682008-09 220 20 Nil 20 7 to 532009-10 220 18 Nil 18 8 to 50
(B) Delay in re-verification
Year No. of LSAs No. of LSAs where re-verification completed
No. of LSAs where re-verification pending
2007-08 17 4 132008-09 20 3 172009-10 20 3 17
CCA
Report No. 4 of 2016
- 280 -
Airtel
ANNEXURE 10.01[Para 10.2.1]
Under assessment of LF due to omission of revenues during assessment by DoT
S. No Year Name of Company
Disclosed In
Nature of Income Amount(in `)
Remarks
1 2006-07 VIL RECO Recovery of Bad Debts Written Off
6428126
2 2006-07 VIL SCH-12 Forex Gain Net 23100000 3 2006-07 VWL RECO Bad Debts written
off857458
4 2008-09 VEL AGR STT Bad Debts written off
102151052
5 2009-10 VEL SCH-13 Misc. Income 28300000
6 2009-10 VEL SCH-16 Net of recovery on account of sharing of infrastructure
12600000
7 2009-10 VWL SCH-11 Misc. Income 106100000 Balance amount between Sch-11 and AGR(15.66 crore -5.05 crore) of ` 10.61 crore in respect of Misc. Income shown in Sch-11 of P&L Account was not considered for as-sessment during 2009-10 resulted in short assessment of AGR by ` 10.61 crore.
8 2009-10 VIL RECO Profit on Sale of Fixed Assets
1522370
9 2009-10 VSL RECO Interest Income 2156255
10 2009-10 VSL RECO Forex Gain Net 39746821
11 2009-10 VSL RECO Profit on Sale of Fixed Assets
71553233
12 2009-10 VSL RECO Interest Income 2046977 13 2009-10 VSL RECO Profit on Sale of
Fixed Assets4182018
14 2009-10 VSL RECO Interest Income 1648310
15 2009-10 VSL RECO Forex Gain Net 9046438
16 2009-10 VSL RECO Interest Income 616551
17 2009-10 VSL RECO Forex Gain Net 54334299 18 2009-10 VSL RECO Profit on Sale of
Fixed Assets829849
19 2009-10 VSL RECO Interest Income 1538191 20 2009-10 VSL RECO Forex Gain Net 24157126 21 2009-10 VSL RECO Profit on Sale of
Fixed Assets6841955
22 2009-10 VSL RECO Interest Income 1833599 23 2009-10 VSL RECO Forex Gain Net 35727387 24 2009-10 VSL RECO IRU Income 459012756
25 2009-10 VSL RECO Profit on Sale of Fixed Assets
67172073
DoT
Report No. 4 of 2016
- 281 -
Airtel
26 2009-10 VSL SCH-13 Net of recovery on account of sharing of infrastructure
84100000
27 2009-10 VCL RECO Interest Income 16505826 28 2009-10 VCL RECO Forex Gain Net 69816932
29 2009-10 VCL RECO Profit on Sale of Fixed Assets
3052541
30 2009-10 VCL SCH-12 Net of recovery on account of sharing of infrastructure
74400000
31 2009-10 VSPL RECO Interest Income 1124590 32 2009-10 VSPL RECO Forex Gain Net 3996073 33 2009-10 VSPL RECO Forex Gain Net 3831597
34 2009-10 VSPL RECO Forex Gain Net 47658128 35 2009-10 VSPL RECO Forex Gain Net 16040392
36 2009-10 VSPL RECO Forex Gain Net 5051665
37 2009-10 VSPL RECO Profit on Sale of Fixed Assets
29217221
38 2009-10 VSPL RECO Insurance 1996254
39 2009-10 VSPL SCH-12 Net of recovery on account of sharing of infrastructure
80500000
Total 1500794063
Say ` 150.08 crore
DoT
Report No. 4 of 2016
- 282 -
Airtel
AN
NE
XU
RE
10.
02[P
ara
10.2
.2]
Stat
emen
t sho
win
g sh
ort a
sses
smen
t of S
UC
in G
ujar
at C
ircl
e fo
r th
e ye
ar 2
009-
10 (`
4.1
5 cr
ore)
Cal
cula
tion
of p
ropo
rtio
nate
ded
uctio
ns d
isal
low
ed(A
mou
nt in
`)
PST
N D
ED
UC
TIO
NS
CL
AIM
ED
B
Y O
PER
ATO
R
(Act
ually
pai
d to
oth
er
PSPs
)
Am
ount
LF
AG
R
Ref
Ded
uctio
ns
disa
llow
ed
by C
CA
Prop
ortio
nate
ded
uctio
ns d
isal
low
ed b
y C
CA
(w
orke
d ou
t by
audi
t *)
Per
cent
age
Am
ount
A) W
IREL
INE
SERV
ICES
1293
2974
0Sl
. B(1
)(a)
(i)16
7464
8792
5.66
9473
3827
B) W
LL S
ERV
ICES
1334
8138
81Sl
. B(1
)(b)
+
Sl. B
(1)(
d)58
.38
9777
4902
4C
) CD
MA
BA
SED
M
OB
ILE
SERV
ICES
D) G
SM B
ASE
D
MO
BIL
E SE
RVIC
ES82
2071
347
Sl. B
(1)(
c)35
.96
6021
6594
1
Tota
l22
8621
4968
1674
6487
9210
016
7464
8792
(*) T
he p
ropo
rtion
ate
dedu
ctio
ns w
ere
wor
ked
out o
n th
e ba
sis o
f ser
vice
wis
e de
duct
ions
cla
imed
by
the
PSP
Cal
cula
tion
of sh
ort p
aym
ent o
f SU
C
(Am
ount
in `
)
Nat
ure
of se
rvic
esA
GR
wor
ked
out b
y D
oT
with
out c
onsi
deri
ng d
educ
tion
Pro
port
iona
tede
duct
ion
disa
llow
ed b
y C
CA
Rev
ised
AG
R
afte
r in
clud
ing
in
adm
issi
ble
dedu
ctio
ns
Shor
t pay
men
t of S
UC
SUC
Rat
e (%
)A
mou
nt (
`)
(col
3x5
)
CD
MA
2652
6856
1097
7749
024
3630
4346
342.
70%
2639
9224
GSM
5417
3890
160
2165
941
1143
9048
422.
50%
1505
4149
Tota
l41
4533
72
DoT
Report No. 4 of 2016
- 283 -
Airtel
ANNEXURE – 10.03 [Para 10.2.4]Statement showing delay in submission of documents by RCL
(in days)
Sl. No. Name of the LSA 2006-07 2007-08 2008-09 2009-10
1 Odisha 34-215 117-223 - 90
2 Delhi 676-936 658-917 643-901 456-622
3 Patna 600-810 720-1110 720-870
4 Bangalore 480 1470 1230 1020
5 U.P. West 443-701 1513-1772 1148-1406 783-1041
6 U.P. East 789-1047 158-682 51-1296 1002-1260
7 Kerala 31-289 283-542 1310-1568 663-921
DoT
Report No. 4 of 2016
- 285 -
Airtel
Glossary of Terms and abbreviations1 Access Service Access Services is the collection, carriage, transmission and delivery of voice and/
or non-voice messages over Licensee's network by deploying circuit and/or packet switched equipment
2 AGR Adjusted Gross Revenue - AGR is Gross revenue reduced by permissible deductions (i.e. PSTN related call charges paid to other telecom service providers for carriage of calls (IUC)/Roaming and service/sales tax actually paid to the Government, as per the license agreement
3 Basic Services A Service Provider must offer customers the ability to place and receive voicegrade calls over all distances utilizing the public switched telephone network or successor network
4 BSOs Basic Service Operators - They were permitted to offer “limited-mobility” services over Wireless Local Loop (WLL (M)) using CDMA technology in their coverage areas
5 BWA Broadband wireless access
6 CAG Comptroller and Auditor General of India
7 Call Charges Call charges are variable and are used to pay for the cost of the equipment to route a call from the caller's exchange to the recipient's exchange.
8 CAPEX Capital Expenditure
9 Carrier Service Provision of wired or wireless facilities to originate, terminate or transit calls, charging for interconnection, settlement or termination of domestic or international calls, charging for jointly used facilities including pole attachments, charging for the exclusive use of circuits, a leased circuit or a dedicated link including a speech circuit, data circuit or a telegraph circuit
10 CCA Controller of Communication Accounts
11 CDMA Code Division Multiple Access (CDMA) is a technology for providing wireless services.
12 CMTS Cellular Mobile Telephone Service - It is a type of short-wave analog or digital telecommunication service in which a subscriber has a wireless connection from a mobile phone to a relatively nearby transmitter. The transmitter's span of coverage is called a cell. As the cellular telephone user moves from one cell or area of coverage to another, the telephone is effectively passed on to the local cell transmitter.
13 Data Service Provision of access to wired or wireless facilities and services specifically designed for efficient transmission of data
14 DoT Department of Telecommunications
15 Entry fee One time non-refundable Entry Fee fixed by DoT has to be paid by the Licensee prior to signing of the License agreement.
16 FAT Free Air Time
17 Fixed license fee regime
During the National Telecom Policy-1994 regime, licensees were selected through a bidding process and were to pay to the Government a fixed amount of annual license fee, agreed during the bidding process.
18 FOC Free of Cost
19 FTT Full talk time
20 GR GR - The Gross Revenue shall be inclusive of installation charges, late fees, sale proceeds of handsets (or any other terminal equipment etc.), revenue on account of interest, dividend, value added services, supplementary services, access or interconnection charges, roaming charges, revenue from permissible sharing of infrastructure and any other miscellaneous revenue, without any set-off for related item of expense, etc.
Report No. 4 of 2016
- 286 -
Airtel
21 GSM Global System for Mobile communication is a technology for providing wireless services.
22 ILD International Long Distance - The ILD Service is basically a network carriage service (also called Bearer) providing International connectivity to the Network operated by foreign carriers.
23 Installation charges Charges for installation of customer terminal equipment
24 Interconnection charges
A ‘charge’ levied by network operators on other service providers to recover the costs of the interconnection facilities (including the hardware and software for routing, signaling, and other basic service functions) provided by the network operators.
25 Internet Services Internet services provides for accessing, using, or participating in the Internet
26 Internet Telephony Internet telephony offers digital telecommunications services based on Voice over Internet Protocol (VoIP) that are provisioned via the Internet
27 IOT Inter Operator traffic
28 IP-I Infrastructure provider category- I -No license is issued for IP-I. Companies registered as IP-I can provide assets such as Dark Fibre, Right of Way, Duct space and Tower.
29 IP-II Infrastructure provider category- II - An IP-II license can lease / rent out /sell end to end bandwidth i.e. digital transmission capacity capable to carry a message. Issuance of IP-II License has been discontinued w.e.f. 14.12.05.
30 ISP Internet Service Provider
31 ISP (IT) Internet Service Provider (including Internet Telephony)
32 IUC Interconnection Usage Charges as defined at serial 24.
33 License Fee The Licensee shall pay Licence Fee as a percentage of Adjusted Gross Revenue (AGR) for providing telecom services on basis of licenses granted by DoT.
34 LSAs Licensed Service Areas (Circle)
35 Microwave Access Microwave (MW) Access is normally in the frequency band 10 GHz and beyond for GSM and CDMA based telecom service providers
36 Microwave Backbone
Microwave (MW) Backbone networks are generally below 10 GHz frequency band for GSM and CDMA based telecom service providers
37 MoC&IT Ministry of Communications and IT
38 NLD National Long Distance - National Long Distance (NLD) service refers to the carriage of switched-bearer telecommunications services over a long distance network i.e., a network connecting different short distance charging areas (SDCAs)
39 NTP-94 National Telecom Policy-1994
40 NTP-99 New Telecom Policy-1999
41 OPEX Operating Expenditure
42 PSPs Private Service Providers
43 PSTN charges Public Switched Telecom Network charges
44 Revenue sharing regime
New Telecom Policy - 99 introduced the 'Revenue Share Regime' in which telecom service providers, in place of the fixed license fee were required to pay a percentage of their Adjusted Gross Revenue (AGR) as licence fee
45 Roaming charges Roaming is the ability for a cellular customer to automatically make & receive voice calls, send & receive data, or access other services when traveling outside the geographical coverage area of the home network, by means of using a visited network. The charges for this facility is Roaming charges
Report No. 4 of 2016
- 287 -
Airtel
46 Sales Tax Sales tax is a consumption tax imposed by the government on the sale of goods and services
47 Service Tax Service tax is a tax levied by the government on service providers on certain service transactions, but is actually borne by the customers. It is categorized under Indirect Tax and came into existence under the Finance Act, 1994
48 SUC Spectrum Usage Charges - In addition to License Fee, wireless service providers are required to pay Spectrum Usage Charges as a percentage of AGR.
49 Supplementary services
GSM offers three basic types of services: Telephony services or teleservices, Data services or bearer services & Supplementary services. Supplementary services are additional services that are provided in addition to teleservices and bearer services. These services include caller identification, call forwarding, call hold, call waiting, conferencing, number identification, closed user group and barring of outgoing (international) calls
50 TB Trial Balance
51 TDSAT Telecom Disputes Settlement and Appellate Tribunal
52 Terminal equipment
A device that constitutes a point of termination of a communications circuit or channel. Terminal equipment includes all customer premises equipment (CPE), including voice terminal equipment and data terminal equipment (DTE)
53 TRAI Telecom Regulatory Authority of India
54 UASL Unified Access Services License - The UASL services cover collection, carriage, transmission and delivery of voice and/or non-voice messages over licensee’s network in the designated service area and include provision of all types of access services. Access Service Provider can also provide Internet Telephony, Internet Services and Broadband Services. If required, access service provider can use the network of NLD/ILD service licensee. The access service includes but not limited to wireline and / or wireless and fixed wireless access.
55 UL Unified License - The Licensee may establish, operate and maintain Telecommunication Networks and telecommunication services using any technology as per prescribed standards in the service area as per scope of services authorized under this License. In case, the Licensee obtains Access Spectrum, the terms and conditions of the allotment of spectrum regarding use of technology shall be applicable.
56 USO Universal Service Obligation - NTP’99 provided that the resources for meeting the USO would be raised through a ‘Universal Access Levy (UAL)’, which would be a percentage of the revenue earned by the operators under various licenses.
57 Value added services
Value-added service (VAS) is a popular telecommunications industry term for non-core services, or in short, all services beyond standard voice calls and fax transmissions. In the telecommunication industry, on a conceptual level, value-added services add value to the standard service.
58 VSAT Very Small Aperture Terminal - VSAT License is to establish, install, operate and maintain VSAT Closed Users Group Domestic Data Network service via INSAT Satellite System on non- exclusive basis within territorial boundary of India.
59 WFD Wireless Finance Division of DoT
60 WLL (M) Wireless in Local Loop (Mobile)
61 WPC Charges Charges levied by the Wireless Planning & Coordination Wing of DoT