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/t'mw DELHf - 110001.·' './l TEL: 23734110, 2?7j~4109(Fax:) ..". ,.,-'.. N( ~OO-130/AS~OlS-16'-CAIIIlPart IIIBSNL/308

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BHARA! SANCHAR,NIGAM LlMrrED~,-:-~(A Govt't>f India Enterprisei :. :,' - .'

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Shri Anil Kumar DhingraJt. Advisor (F&EA)Telecom Regulatory Authority .of IndiaMahanagar Doorsanchar BhawanJawahar Lal Nehru Marg(Old Minto Road), New Delhi-l 10002

Sub: TRAl's draft "The Reporting system on Aeeounting-Separetioa ReguJatio.ns.J016:;_. __~,Ref: TRAI press release No. 16/2016 dated 22.02.2016 . --

Kindly refer to your office press release under reference cited above wherein comments have beenasked from Telecom Service Providers on Draft "The Reporting system on Accounting SeparationRegulations, 2016". The new draft regulation is definitely a welcome step as it has incorporated manychanges like updation of definitions ego Broadband etc, rationalization of services, detailing of allocationand attribution methods etc. Following are some ofthe observations of BSNL in this regard:-

1. The time period for submission. of Reports has not been changed i.e reports are to be submittedwithin six months of the end of the accounting year. The companies are already under pressure tocomply with many Statutory and legal requirements within this time frame that this additionalrequirement which involve preparation of detailed reports, its approval from Board of Directors,Audit and submission of reports both in hard copy and softcopy becomes a challenge in itself Hereit will be appreciated, that Accounting Separation Reports can be fmalized only after thefinalization of the financial accounts of the company and its adoption by the Board of Directors of"the Company. Also, every alternate year, Accounting Separation Reports based on Replacementcost Basis are also required to be submitted which involves additional work. BStvL is, therefore,of the view that TRAI may consider the extension of the period of six months for submission ofthe report.

2. There are penal provisions for contravention of the time limit for submission of the reports and. submission of the false reports. These financial disincentives are like 'sticks' and promote fear.

TRAI may review thisprovision related tofinancial disincentives.

3. Accounting Separation Reports is a report which is Technical in nature but involve Accountingdetails as well. It is, therefore, suggested that TRAI may consider arranging regular Training sessionsto make the TSPs aware about the significant aspects of the Regulations and highlighting theimportant areas. This will help in providing clarity and submission of more accurate reports therebyreducing paperwork and time involved both on the part of TSPs and T~.!: .

4. The frequency of Submission of Accounting Separation Reports based on Replacement CostAccounting may be reviewed like once in three orfour years if it cannot be dispensed with.

Regd. and Corporate Office: BP.ARi1...T S.1U"'JCI-LA..'tBHA 'N :\N"H.C. MATHUR LANE, JANP ATH, NEW Df:LHI-ll 0001Corporate Identity Number (Cflv): U/4899DL2000GOII07739. Website www.bsnl.co.ln

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S. TRAI hasA~tciiled out the Allocation"'and Attribution metho~·_l1iese appear simple foraT8~providingon~·~r two services, how~er for the companies like BSNKproviding thewhole,R"';ket of.Telecom Services on pan Jndia b~is,· analYSISarid distributiOIi-of each compqnent oLi~tworkelement and revenue is n6f~easibl~. :'F{pwever,BSNL will try its level best to m~~tthe requirementsofTRAI. - . .t

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