SANCHAR NIGA}T TXESUTIVES' ASSOCIATION (INDIA}BIPIN 6. PAT€L

GUJARAT CIRCLE HEAD QUARTER

Circle Secretary SNEA (I), GujaratM. : +91-942€.2,70,944

CircleD. K. DAVC

President SNEA (I), GujaratM. : +91-9426505850

15'A' Hira Nagar $ociery, Akshar Chowk, Vadodara-390 020. Ph. : {oi 0265.?33i666 (R} 0265-23g03i0 Emait : bgpatel@bsnl.co.in

To,Shri Narendrabhai Modiji,The Honorable Prime Minister of India,South Block, Raisina Hill, New Delhi - 110011,7, Lok Kalyan Marg, New Delhi - 110011, Dated: LOIOGIZ:OL9

Our Earlier Ref.Letter: (1) SNEA/ Gujarat lL8-L9lLLc18 dated: 23 ltl 12018 addressed to Hon'blePrime Minister of India vide Registration number: PMOPG/E 1201810543322 & Reply received on26102120t9 and written again for review appeal on reply on dated: 03.03.2019 (Enclosed h/w)(2) SNEA/ Gujarat /18-19/03a19 dated: 04 103 120L9 addressed to Hon'ble Prime Minister of India videRegistration nu mber: PMOPG I El 20L9 I 0L26337 (Enclosed h/w)

Repofts of various Committees for Revival of BSNL:(1) IIM Ahmedabad had given the task for "revival / restructuring of BSNL"vide letter F.No.L0-3120L7-SU-IdatedApril 6, 2018 and July 31, 2018, "To undertake a study with the objective of 'Restructuring /Revival of BSNL', in accordance with the principles laid down in DPE guidelines dated 29.10.2015(2) 55th Report of Standing Committee on information technology presented to LS & RS on 02.01.2019(3) 24th Repoft of committee on public undeftakings for Review of loss making CPSUs presented to LS &RS on 20.L2.20L8(4) Various proposals and Report of BSNL management to DOT in reference of DOT letter dated19.12.2018 to BSNL(5) Information released by "Press information Bureau, Government of India" regarding decision takenby the then Group of Ministers while corporatization of The DTS & DTO to BSNL dated: 01.09.2000 andthe Cabinet note dated: 25.09.2000 which is approved by Central Cabinet Secretariat dated: 28,09.2000

Letter No: SNEA/ Gujarat lL9-20106a19 dated: 1010612019Subject: In connection of our earlier reference letters and repofts of various committees on BSNL asabove, our humble Request to your good self for consideration of revival and upliftment of BSNL and itsEmployees interest as contained in reports for taking necessary Policy decisions by Govt of India-Reg.

Respected Sir,First of all we whole heartedly extend our congratulations and best wishes to your

good self and to the Government for coming to the power due to good performance and upliftingthe pride of India to a prestigious level globally.

We again congratulate to your good self for being pioneer in bringing remarkable revolutionin the field of Telecommunication by launching the dream project of "Digital India". Now with thesame trust, we humbly and earnestly request for resolving the issues peftained to revival ofGovernment owned BSNL, with the spirit and recommendations as contained in the above citedvarious committee repofts and decisions taken by the then GOM while corporatization of the DTS &DTO to BSNL in the overall interest of our great Nation.

It is very much essential to consider on the part of BSNL that, it is working with the conceptof fulfilling roll of social obligation on behalf of Government for the entire population of countryresiding in naxalite, terrorist, hilly, rural and remote areas irrespective of profitability, since itsformation, For providing services to these areas expenditure of BSNL is much more compare toincome. Hence it is obvious that priority of BSNL is "service centered" not "profit centered" as like allother Telecom operators are functioning. In this connection once again our suggestions for resolvingvarious issues faced by BSNL are as under.

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Circle Sc,cretary SNEA (I), GujaratM. : +gt-g4Z6ZIOg44

SANCIIAR T{IffAJ}T EXECUTTVIS' ASSOSIATIOT{ fl HDIA)BTPIN G. PATEL

GUJARAT CIRCLE HEAD QUARTERD. K DAVC

ircle President SNEA (I), GujaratM. : +91-9426505850

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15r4, Hira Nagar $ociety, Akrhar chowk, vadodara-39o 020. Ph. : (o) 0?05-?33166$ {R} 0265.2350350 Emait : bgpatet@bsnt.co.in

(Operation-1a) Allotment of 4G Spectrum which is still not made available to BSNL,Subsequently giving priority for 5G trials and allotment of Spectrum.

It is evidential that presently all private operators are given 4G spectrums sincearound 4 years back, while still BSNL is deprived for 4G spectrums by DOT due to reasons unknown,in spite of the repeated requests made by BSNL to DOT.

As a consequence without 4G spectrum BSNL is striving very hard for providing high speedconnectivity to the customers, as well losing huge business and tenders of Government, Govt U/Tand corporate which is resulting to huge lose in revenue and market share.

Now it is to be ensuring that BSNL need to stafts 4G service earliest by upgrading the licenseand with the last purchased Nokia equipments in existing spectrum without investing for 4Gspectrum and side by side without further delay initiate for 5G trial and spectrum allotment so THATBSNL can not face the problem which happened in the case of 4G.

(Operation-1b) Renewal of 2G Licence which expiring, for ful! fill need of good no.s ofusers who are still interested in Voice service only:

Now renewal of 2G is also essential at this juncture in market still there is and there will behigh volume of users are there who are interested and using only voice facility, More over if privateoperators are minimizing or closing 2G LSA in that case also BSNL will be fufther benefited byincreasing revenue by retaining existing customers as well as by adding new customers.

(Operation-Ic) Giving thought for procuring MSO, Dish TV or lP-TV licence to BSNL orallowing BSNL for tie-up with such Iicence owner for providing triple play service whichis presently being offered by private competitor and thereby to sustain market share ofFTTH service:

Presently our competitors are offering "Triple Play" (i.e. voice, high speed internet and TVChannels) services on FTTH. Now BSNL is also going forward in providing FTTH service but in theinitial stage itself BSNL is facing stiff competition with other operators in providing Triple Play servicedue non availability of licence more over BSNL is also speedily loosing even existing BSNLbroadband-ADsl based customers base and sharp decline in revenue in CFA segment which ishaving highest share in total revenue of BSNL. Hence earliest decision for procuring MSO, Dish W orIP-ry licence to BSNL is very much essential so that BSNL can provide triple play service andthereby retain and gain customers and increase revenue.

All above decisions are need of hour for revival and survival of Govt owned BSNL as well asfor protecting national and customer's interest in highly competitive environment along with fullfilling Government roll of rural digitalization.

(Operation-2al Regular compensation from USO fund to BSNL for providing services inTerrorist, Naxalite, Hilly, Remote and Rural areas as part of social obligation on behalf ofGovernment of lndia which are completely loss making business

BSNL is working with the concept of fulfilling roll of social obligation on behalf of Governmentof India for the entire population of country residing in Terrorist, Naxalite, Hilly, Remote and Ruralareas irrespective of profitability and which is completely loss making business since its formation.

For providing services to these areas, expenditure of BSNL is much more compare to income,this itself prove that BSNL is not functioning with concept of only profit centered. More over inpresent market competition the growth and revenue of most of the telecom operators are alsoseverely affected even in urban and potential areas. Thus regular Compensation is to be given to BSNL

from USO fund. Z

SANCHAR NIfiAM EXECUTIVIS' ASSOSIATION (IIYDIA}BTPIN G. PATEL

GUJARAT CIRCLE HEAD QUARTER

Circle Secretary SNEA (I), GujaratM. : +91-9426?-70/944

D. K. DAVECircle President SNEA (I), Gujarat

M. : +91-g426EObB5O

15'A' Hira Nagar Society, Akehar chowk, vadodara.390 020. Ph. ; (o) 0?65.2331666 (Rl0265.2350350 Emait : bgpatet@bsnt.co"in

(Operation-2b) Promoting BSNL services for Central Govt., State Govt., their U / T PSUsand digital lndia project on priority as done for lTl to uplift it:

Looking to the issues of secrecy, transparency, security etc, it is highly essential that, varioustelecom seruices required by Central Govt., State Govt., their U / T PSUs and roll out of digital Indiaproject may be awarded to BSNL on nomination based being Govt. Owned Company as well asbeing core and expeftise in telecom & IT.

In this line presently large number of ICT (Information, communication technology) projectsare being under execution I are under development across the country by Central Govt. Depts. /DOT / BBNL / State Governments / Civic Authorities include Smart city projects, Surveillance projectsof Railways, State Govt., Civic Authorities, Safety and security projects of Home Departments,Connecting GPs, connecting schools by internet, smaft class room projects, Wi-Fi Projects etc.

Hence policy decision is to be taken in this regard for providing these services andimplementing these projects and instruction can be issued to all concerned department of Centraland States Government including PSUs such that further BSNL Corporate Office & Circle Office orcounter depaftment vice a versa may approach and coordinate with each others.

(Operation-2c) Ensuring priority to BSNL for giving Govt. Projects of Digital lndia andreassign the existing infrastructure and establishment of BBNL under the control ofBSNL (Merger of BSNL and BBNL):

Now Government of India had already announced the dream project of Digital India programsince 01st July, 2015. The initiative includes plans to connect rural areas with high-speedinternet networks. Digital India consists of three core components, (i) development of secure andstable digital infrastructure, (ii) delivering government services digitally, and (iii) universal digitalliteracy.

For that, Govt. has firmly plan & formed the Bharat Broadband Nigam Limited (BBNL) byproviding Very huge fund from USO to complete the task in time bound manner by developing allnecessary wide spread infrastructure up to the level of all "Gram Panchayat" for digitalization up toRural areas.

But due to lack of experience / man power / establishment etc, this dream project is notfulfilling its actual motive despite lot of fund is being already consumed on it.

Thus after elapse of couple of years and consumption of fund, large OFC network is laid,switches are also installed at "Gram Panchayat level" but many patching routs are either incompleteor damaged by others agencies and are not being attended due to non availability of maintenancemechanism. More over even the locations which are put through by BBNL, but BBNL is not havingtheir own mechanism for providing high speed internet seryices to general public of Rural in terms ofCommercial and technical.

Practically BBNL is totally dependent on BSNL for achieving purpose of Govt. of India for ruraldigitalization. On other hand BSNL is also helpless despite availability of this much recourses,because the technical establishment and administrative authorities of BBNL & BSNL are different andthis is the main lacuna due to which the services of telecom to be provided to rural area are notbeing delivered.

So if all these infrastructure and establishment of BBNL is brought under the control of BSNLwhere sufficient number of man power with experience in relevant field all over the India areavailable, will execute the telecom projects timely and also it will fulfill the real purpose of dreamproject of Govt. of India for upliftment "Rural" by way of digitalization of Rural part of India at parwith urban, by providing high speed internet services.

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- D. K DAV€Circle President SNEA (I), Gujarat

M. : +91-9426505850

SANSHAR NI6AM EXECUTIVAS' ASSOCIATION (INDIA}BIPIN G. PAT€L

GUJARAT CIRCLE HEAD QUARTER

Circle Secretary SNEA (I), GujaratM. : +91-94?'6.270944

15'A, Hira t'lagar society, Akshar chowk, vadodara-390 020. Ph. ; (0) 0265-2331606 {R} 0265.2350350 Emait : bgpatet@bsnt.co.in

(Operation-2d) Avoid splitting of BSNL by forming separate independent companies,Such as BSNL Tower Company:

In the same way one more company in the name of "subsidiary Tower Company" by split ofBSNL it is too with its independent administrative control is also formed by Govt. of India. This isalso in the line of earlier decision as formation of BBNL for playing roll of rural digitalization whichBSNL can do very well.

Now after this much time it seems that purpose is not getting full fill and ultimately BSNL isagain going to play roll, despite BBNL is not in the control of BSNL.

Thus by going through this experience, to form Tower Company from BSNL will not going tofulfill purpose and by this decision both company will be weaken and under this condition again thepurpose of Govt. to provide the telecom service at affordable rate across the country (Rural &Urban) will be defeated by splitting BSNL.

It is also worth to mention that at present Govt. has taken policy decision that other Govt.sectors like banking are being merged for making it more competitive and powerful for fulfillingpublic interest. While in telecom sectors same purpose for fulfilling public interest is contradictingand will get defeated by splitting it.

(Operation-3a) Hurdles and discrimination for permission and Taxes / Ievy charges,Property taxes by civic and other Govt. Agencies:

Since the formation of BSNL, Lot of hurdles are being faced for obtaining ROW (Right of way)Permission from Municipal Corporations, Nagar Palika's, i.e. various Civic Authorities, Highways,Railways etc. And they are imposing dissimilar charge rate within same jurisdiction and thesecharges are also varying between same types of one jurisdictional authority to same type of otherjurisdictional authorities for laying of cables. Even in many cases they are issuing bills to BSNL forthe cables which were laid during DOT period. All these are grave discriminations happening withBSNL. While in case of Private operators they are not facing these issues due to obvious reasons andthey are getting required ROW permission easily from all concerned Authorities.

Many State Govt.s are issuing ROW permission to Private Operators centrally from their StateSecretariat. In another example for cable laying charging pattern for BSNL is as per full length oflaying while for other Operators it is as per the number of pits they did in total length.

Thus it is very unfoftunate that only BSNL being a Govt. owned Company is facing lot ofhurdles & issues in obtaining ROW permission in time and as per need. Which are very muchessential for development work and maintenance work. In all the states & within states various civicauthorities are imposing different charges for permission for same kind of work & thus imposingdissimilar charge rate within same jurisdiction also vary between same types of one authority tosame type of other authorities for cable lay. Even they are issuing bills for the cables which were laidduring DOT period. And forcing for doing all these payments, otherwise charging heavy penaltiesalso. Similarly various civic authorities are also imposing property taxes to BSNL and it is for eventhose properties which are still on name of DOT & BSNL are still not allowed for revenue generation.

To overcome all these, policy decision is to be taken and direction are given to all concernedministries of central & State Government so that they may issue necessary instruction to their downto line sections along with standardized rate & procedure (with some relaxed rate structure forBSNL) with intimation to BSNL Corporate office to maintain similarity at all stages. These all willproved as a saving of procedural time for permission, money, man hours and legal litigations arisingdue to absence of above procedures & rates and thus all project will be executed as per target ,needand urgency.

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SANSHAR NIGAIII EXECUTTVES' ASSOCTATION (INDIA)BIPIN 6. PAT€L

GUJARAT CIRCLE HEAD QUARTERD. K. DAV€

Circle Secretary SNEA (I), GujaratM.: +91-9426270,9.44

Circle President SNEA (I), GujaratM. : +9L-9426505850

t5-A, Hira Nagar Society, Akshar Chowk, Vadodara-390 020. Ph. : {0} 0265.2331666 (R) 0265-2350350 Email : bgpatet@bsnl"co.in

(Operation-3b) Not considering BSNL for paying electricity charges as per industriattariff, as laid in letter no: BSNL H/Q 3-29/EW-2002 dated 1111',12002 according to directionof Hon'ble Supreme Court of lndia:

As per BSNL HQ Ltr No : 3-29lEW-2002 Dated 11.11.2002 as the erstwhile Departments ofDTS/DTO were already an industry under ID Act, as held by Hon'ble Supreme Court of India, sincethe DTS/DTO have been corporatized BSNL falls in the category of Industry. Further Finance Act2003-03 has also accorded the status of Industrial Undertakings to the TelecommunicationCompanies under Section 72A (7) (aa) by insertion of sub-clause (iiia) below item No. (iii).

The Govt should suitably amend the relevant electricity regulation to allow BSNL industrialtariff instead of commercial at present. This pro active action will give a much needed support to thecompany. And accordingly Industrial Tariff for Electricity is to be made applicable for BSNL.

(Operation-4) Facilitate BSNL by providing duct while implementing infrastructureprojects of Govt:

To avoid frequent damages to properties of BSNL as well for all such other utility serviceproviders for their easy maintenance & development and providing uninterrupted services to theirrespective customers, provisions & construction of Duct for them is to be facilitated while executingnew projects for State & National Highways, Smaft cities, urban & rural civic authorities etc.Accordingly all concerned authorities can be given directions that while planning & executing theirrespective projects they must coordinate with counterpart of BSNL and all such utility agencies.

Apart from that it is also need to ensure that all these agencies must coordinate withcounterpaft of BSNL and all such utility agencies while doing their maintenance and expansion workto avoid the frequent and irreparable damage of network of BSNL,

(Finance-1) Allowing BSNL to take Loans from Banks as it is still not allowed by DOT:It is known to all that Telecom Sector is an intensive capital investment Sector. Accordingly

all Private Telecom operators are growing & developing by replacing old technology with latest one.Thus it is evident from the fact that debt of all Private Telecom operator has reached to the tune ofmore than 7 lakh crores from our Nationalized Banks.

Same is not happening for BSNL. Since formation of BSNL in October 2000, it did alldevelopmental work by generating revenue & resources by its own, which can be seen by the factthat despite huge liabilities, at present BSNL is having debt of around 9600 crores only against whichthe asset base is of more than 2 lakh crores.

As we are aware that since last 3 to 4 years, due to stiff tariff war in Telecom Sector, andpredatory pricing by private operators, revenues of BSNL and all incumbent operators have gonedown by 25-30o/o. On other hand, over heads of BSNL are fixed or might have increased.

Now days the condition of BSNL is deteriorated in extremely worst condition and not able topay the electricity bills, rent of rented building and mobile towers, Due to these services to EB andesteemed customers is badly affected and it is resulting to loss of confidence towards BSNL as wellas loss in revenue. And this condition is restricting BSNL for its technical up gradation as per marketneed and for fulfilling its timely need. More over it is also essential in order to remain competitive inthe market and for making available the latest technology to the customers, capital investment isrequired to be done by BSNL. For fulfilling above need, in spite of repeated requests, permission isnot given to BSNL to borrow fund from Banks due reason unknown.

Now further delay in this regard will create irreversible loss to BSNL, hence it is to be

5permitted quickly.

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SANCHAR NISAMBIPIN G. PAT€L

EXESUTMS' ASSOCIATION (INDIA)GUJARAT CIRCLE HEAD QUARTER

D. K. DAV€C'iircle President SNEA (I), Gujarat

M. : +91-9426505850

15'A' Hira Nagar $ociety, Akshar Chorrk, Vadodara-390 020. Ph. ; {O} 0265-2331666 {R) 0265-2350350 Email : bgpatet@bsnl.co.in

(Finance-2) Excluding 8olo licensee fee on AG& payable by BSNL on ICT project i.e.other than Telecom service --- Affecting Revenue of BSNL:

Due to Digital India plan / Smaft City plans of Govt. of India different models / Agencies /State Govt.s are working on it and a parallel infrastructure development is started across pan Indiaparticularly in Optical Fiber deployment, Cloud services and data Centre Services. BSNL has takeninitiative and has identified various system Integrators (SIs), Technology Paftners so that BSNL canpafticipate in the bids issued by State Govt.s / Civic Authorities / SPVs etc. Major hurdle in winningthe bid is, Sis are ready to share the profit of 6-7 % with BSNL to meet Turnover / some technicalparameter in participating the bid. But with 8% License fee it becomes 14-15 o/o cost to SIs, thusproject are not becoming financially viable for SI to bid with BSNL. In order to ensure that BSNL maypafticipate such bids successfully,If Bo/o license fee should be excluded in considering revenue asAGR for projects other than Telecom Service as above. BSNL can definitely generate revenue ofmore than 1200-1500 crores annually.

(Finance-3a) Carry out mutation of DOT / DTS propefties centrally at Delhi itselfbetween DOT and BSNL for all such Iand & buildings which are under control of BSNLbut Ownership not transferred to BSNL due to lack of any documents or coordinationamongst concerned authorities and permit for renting to earn revenue:

(I) For the many years by now, BSNL has been making out combined efforts by involvementof Management, Associations and the employees for exploring the possibilities of revenue-generationfrom various possible areas. One of those possible areas is generating revenue by renting out theassets. The lots of consistent efforts have yielded fruitful results and many of the building assetshave been rented out all over India.

There are bright opportunities of revenue generation by renting out the land assets, too.There are many such cases of renting out portion of land-assets to the Government ownedpetroleum Companies for installing their petrol-pumps. This is also going to be the major source ofrevenue-generation for BSNL in the present times of economic crisis. Many finalized and mutually-agreed proposals have been forwarded to DOT for approval as the powers to rent out the landassets are vested not with BSNL Board but with the DOT. For not receiving approval of suchproposals for a very long time by now, many more such proposals which are already flnalizedbetween BSNL and petroleum CPSUs like HPCL, IOCL etc. are ready but not submitted to DOTawaiting approval of already submitted cases.

The matter regarding delegating powers in such cases of renting out land-assets for revenue-generation has already been taken up with DOT long back but these are yet to materialize. Thereare 5 categories of land assets.

(i) Asset jointly shared by DOT/POSTAL (erstwhile Dept. of P & T)(ii) Free hold Land in the name of DOT(iii) Free hold Land mutated in the name of BSNL(iv)Lease hold Land in the name of DOT(v) Lease hold Land mutated in the name of BSNL

It is very peftinent to mention that all the above land assets are in the custody of BSNL andbeing maintained by BSNL. All the revenue expenditure in the form of prescribed taxes levied by thelocal civic bodies is also being paid by BSNL.(II) In many building assets, DOT has occupied major areas for their use which is not of their actualand genuine need and kept vacant and idle which also can be the major source of revenue-generation if given for such utilization to BSNL. 6

Circle Secretary SNEA(D, GujaratM. : +91-94?'6270/944

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SANCHAR NIGAM EXESUTIVES' ASSOCIATION (INI}IA}BIPIN G. PAT€L

GUJAR,AT CIRCLE HEAD QUARTERD. K. DAV€

Circle Secretar5r SNEA (I), GujaratM.: +91-942627A944

Circle President SNEA (I), GujaralM. : +91-9426505850

15-A, Hira Nagar $ociety, i*"nu, Crrowfc, VaOoUara-390 020. Ph. : 1O1 ozOS+1S1666 tR);ZOE-rrUOi* Eruif , bgpatet@bsnt.co.in

(Finance-3b) Depreciation calculation is to be reviewed and considered in balance sheetfor BSNL i.e. Government establishment, in terms of appreciation while vatuation ofasset such as land, copper or any metals etc for which present market rates is verymuch high compare to purchase value :

Presently according to the Indian Accounting Standards, while working out balance sheet, asper the regular practice the value of Land and copper or any such property for which the presentmarket value is much higher compare to the purchase value, is reflected as history value instead ofpresent market value which is much higher is not being reflected. This is leading to huge undervaluation of our BSNL Company and may be the case for other such Government establishment also.

Hence in this regard some policy decision is to be taken that while assessing the valuation ofGovernment asset, the principle of appreciation / the actual market value is to be followed for theasset such as land, copper or any metals etc. for which present value is more compare to thepurchase value. This is very much impoftant for projecting the real I actual value of BSNL in marketi.e. for Government Establishment in market.

(Finance-4) For stability of BSNL and other telecom operators, predatory pricing shouldbe restricted to avoid imbalance in telecom sector and thereby increases in liabilities oftelecom operators which may further lead up to bankruptcy fotlowed by NPA andirreversible harm to BSNL, other telecom operators and to Nation as a whole :

It is wofth to mention that at presently tariff competition / war is prevailing in telecommarket amongst all operators for their existence and as a result total telecom market is in stress. Itis resulted up to such an extent that the private operators are facing too much difficulty in repayingtheir loans. An overall telecom sector debt is in tune of lakhs of crores. BSNL is also a one of victimof that, due to which BSNL along with others operators is also continuously pushing towards loss. Ifthis situation is continuing than, there will be no hope of any relief or improvement in this condition.Hence it is very much essential that TRAI may play important role for bringing stability in telecommarket as did in case of TV Channels by way of restricting operators for predatory pricing.

(Finance-S) Allow Input Tax Credit of GST on BSNL Mobile Towers:Presently as per Section 17 of Central GST Act, 20L7 Input Tax Credit on Telecommunication

Towers is not allowed for the reason that Telecommunication Towers are not treated as plant andmachinery. The Section is reproduced below:Section 17(5) Notwithstanding anything contained in sub-section (1) of section 16 and subsection(1) of section 18, input tax credit shall not be available in respect of the following, namely:-(c) Works contract services when supplied for construction of an immovable propefi (other thanplant and machinery) except where it is an input service for further supply of works contract service;The Explanation to Section 17 reads as under:Explanation.-For the purposes of this Chapter and Chapter VI, the expression "plant andmachinery" means apparatus, equipment, and machinery fixed to eafth by foundation or structuralsupport that are used for making outward supply of goods or services or both and includes suchfoundation and structural supports but excludes-(i) land, building or any other civil structures;(ii) telecommunicationtowers;and(iii) pipelines laid outside the factory premises

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D. K. DAV€Circle President SNEA (I), G.ujarat

1y1. : +91-9426505850

sAncHAR ilI$Am EXECUTMS' ASSOSIATION 0ilDrA]BIPIN G. PAT€L

GUJARAT CIRCLE HEAD QUARTER

Circle Secretary SNEA (I), GujaratM. : +91-942627A944

15.A, Hira Nagar $ociety, Akehar chowk, vadodara-39{l 020. Ph. ; (o} 0265-?331666 {R} 0265.2350350 Emait ; bgpatet@bsnt.co"in

BSNL Towers under CGST Ac',, 20t7 is categorized under the category of "Works Contract" (due towhich) where Input Tax credit is not available except when such works contract services are treatedas "Plant and Machinery."

While actually looking, BSNL invest a substantial portion of its income in erection ofTelecommunication Towers for providing output service and should well qualify in the definition as"Plant and Machinery", thus excluding the Telecommunication Towers from the definition of plantand machinery is unjust and unfair to BSNL which increases the cost of its Towers by about L9o/o ofGST. The Govt. should consider allowing the Input Tax credit to BSNL on its TelecommunicationTowers considering the beleaguered financial condition of BSNL.

(HR-l) Suggestions while Government is going to plan for reduction of manpower forBSNL revival:

It is wofth to state that the manpower available in BSNL is originally recruited by DOT(Govt. Of India) as per the need of DOT at that time. After formation of BSNL, they absorbed inBSNL with the hope of the betterment in the interest of company and employees both,

After that BSNL continue to work with the spirit of social obligation on behalf of Governmentof India irrespective of profit and loss in areas of country, In first decade performance and financialcondition of company was up to the mark.

Subsequently due to stiff competition, tariff war, delay in procurement of mobile equipmentwhen demand was high, non availability of 4G spectrum, and delay & discontinuation of USO fundsetc. many such unfavorable conditions played role for deterioration of the financial condition starts.Thus occurrence of above issues is the actual fact for down fall of company, not due to theworkforce.

Now for securing the better future of company as well as our younger employees who haveto still serve for more than 15 years in BSNL by way of revival of company, if Government resort toany step pertain to staff reduction, than as a justice it is to be considered that the interest ofemployees is to be protected at par with other Government / DOT employees, as originally theyhave been recruited by Government, In this regard our suggestions are as under.

(I) Firstly, all possibilities are to be explored for knowing the requirement of various category ofstaff at DOT and others Central and State Government department and PSUs by approaching theirconcerned authorities. After obtaining the staff requirement, it is to be widely published within BSNLand, the applications of willing BSNL employees are to be forwarded to counterpart as per theirchoice of depaftment and station.(II) Next to that in case of fufther requirement of reduction of staff by VRS, all possibilities are tobe explored by Government / Management while Offering VRS that maximum and attractive benefitare to be given to employees such that maximum employees may be motivated to come fonryard forVRS willingly & with pleasure and it may full fill actual purpose.(IU) Next to that in case of further requirement of reduction of staff by reduction in retirement ageit is to be ensure that affected employees is to be benefited by giving adding increments ofremaining years of service so as to protect the pension benefit.

All these will motivational to the retiring by age reduction and by VRS as well as consequentlyto protect the interest of our younger workforce whose future is dependent on BSNL as well inoverall interest BSNL.

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D. K. DAV€Circle President SNDA (I), Gujarat

M. : +91-9426606850

SAilgHAR NIffAJ}T EXECUTIVES' ASSOCIATION (INDIA}BIPIN G. PATEL

GUJARAT CIRCLE HEAD QUARTER

Circle Secretary SNEA (I), GujaratM. : +91-94?,6?-70944

15.A' Hira Nagar society, Akshar chowk, vadodara-390 020. ph. : (o) 0?05-2331666 (Rl 0265-2350350 Emait : bgpatel@bsnt.co.in

(HR-2) Implementation of Standard pay scale E2-E3 for JTOs / JAOs , SDEs / AOs andequivalent cadres : We are thank full that Our BSNL board had approved and recommended theissue of E2-E3 for JTOs, SDEs and equivalent cadres , however all these issue is pending at DOT.

Hence we further request for expedite at DOT for revision of the intermediary pay scales ofE1A and E2A to the next higher standard pay scales of E2 and E3 for the JTO, SDE and equivalentExecutives in BSNL w.e.f. 01.01.2007 (Notionally) as per 2nd PRC recommendations, based on the(I) pay scales notified by DOT in the Presidential order dated 28.07,2003 for the BSNL Executives(II) affordability clause for 2nd PRC, the Profit Before Tax for the year 2007-08 and (III) based onthe advice given by DPE in its OM dated 29.08.2018,regarding implementation of standard payscales.

(HR-3) Implementation of CPSU Cadre hierarchy at BSNL, which is awaited from DOT:Notification of "BSNL Executive Promotion Policy & Recruitment Rules -2077" approved by the

BSNL Board on 28.05.2018, w.e.f .29.06.2018 or the review date 01.07.2018 in order to maintainUniformity, Seniority and Parity in promotions at par with the Juniors already promoted on29,06,2018.

It is worth to mention that maximum no.s of executives are retiring every month withoutgetting their due promotion, More over there is over stagnation in all executive cadres for their nextpromotions which are not taking place due to various court cases coming up while processing anypromotion. This is resulted to the demoralization in all executive cadres.

Thus to overcome this, the recommendation of BSNL Board on "BSNL Executive PromotionPolicy & Recruitment Rules -20t7" (CPSU) which is pending with DOT, is to be permitted at theearliest in the overall interest of executive fraternity and BSNL.

(HR-4) Implementation of 3rd PRC for BSNL:BSNL management did all efforts sincerely and provided all required information to DOT and

other concerned establishment for implementation of 3rd PRC during last one year.In this respect it is to be considered that BSNL is working with the concept of fulfilling roll of

social obligation on behalf of Government for the entire population of country residing in terrorist,naxalite hilly rural and remote areas irrespective of profitability, since its formation.

Thus for providing services to these areas expenditure of BSNL is much more compare toincome. More over in present market competition the growth and revenue of most of the telecomoperators are severely affected.

Accordingly it is obvious that priority of BSNL is "service centered" not "profit centered" aslike all other Telecom operators are functioning.

Subsequently due to stiff competition, tariff war, delay in procurement of mobile equipmentwhen demand was high, non availability of 4G spectrum, and delay & discontinuation of USO fundsetc. many such unfavorable conditions played role for deterioration of the financial condition stafts.Thus occurrence of above issues is the actual fact for down fall of company, not due to theworkforce.

Hence looking to all such / these aspects the clause of affordability is to be exempted forBSNL, so that 3rd PRC can be implemented for BSNL, otherwise it is gross injustice with the BSNLstaff which is recruited by DOT but absorbed in BSNL is not getting 3'd PRC, while the same staffwhich is still in DOT have already got 7th CPC benefit.

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D. K. DAVCCircle President SNEA (I), Gujarat

M. : +91-94266OEBSO

SAI{CHAR I{ rGAm EXE C UTIVTS' ASSOCTATT O r{ (I N DrA}BIPIN G. PAT€L

GUJARAT CIRCLE HEAD QUARTER

Circle Secretary SNEA (I), GujaratM. : +91-9426,270/944

15'A, Hira Nagar Socioty, Akshar chowk, vadodara-390 020. Ph. : {o} s265-2331666 (R} 0265-2350350 Emait : bgpatet@bsnl.co.in

(HR-s) Revision of pension of DOT employees, absorbed in BSNL and retiring from BSNLunder Rule 37-A:

DOT employees, absorbed in BSNL and retiring from BSNL are basically DOT / Central Govt.Pensioners under rule 37 A. In this case it is found that even after revision of pension of DOT /Central Govt. Pensioners, revision of pension for Employees recruited by DOT but absorbed in BSNLand retiring from BSNL is not taking place.

Hence policy decision is to be taken that while revision of Pension for Employees recruited byDOT and retiring from BSNL should be delinked from any pay revision of BSNL.

And thus as soon as the central Govt. pay commission is implemented for DOT / CentralGovt. pensioners, accordingly equal fixation should be extended to DOT pensioners retired fromBSNL also, as it has nothing to do with BSNL revenues / Net Profit etc.

It is worth to mentioned that for all these DOT recruited and BSNL absorbed executives /employees the necessary pension contribution amount as per norms are already paid by both theemployer to consolidated fund of Govt. of India. Hence they must be equally treated as good asGovt.servant for pensioner benefit at par and at the same time being legitimate right.

(HR-6) Payment of pension contribution by BSNL as per the Government Rule: ThePension Contribution for the Govt employees absorbed in BSNL is to be calculated based on theactual basic pay, instead of maximum of the pay scales as per DOPT order dated 19.11.2009,However, the DOT is collecting Pension Contribution from BSNL, based on the maximum of the payscale of each BSNL employee, since 01.0t.2007. In the meeting held on 24.02.2018, the HonMinster directed that only the Government of India Rule should be made applicable to BSNL. TheDOT has so far not implemented the direction given by the Hon Minster. BSNL made excesspayment of more than Rs 2200 Crores in this regard and continue to make excess payment.

(HR-7) Peftain to implementation of higher pension by EPFO:in respect of BSNL Recruited Employee & Executive for Higher pension, necessary instructions

are issued by BSNL-CO, Vide Letter No: 500- 85, CA II /BSNL IEPF I 2013 I Vol VI, Dated:30.03.2017, many Employee & Executive have approached Regional / local EPF office throughproper channel, But EPFO is not responding to higher pension plan option, Hence we suggest thatBSNL - Corporate office may approach the concerned ministry dealing EPF, through DOT forimplementation of same.

Hence we request your good self to consider our suggestion so that it will be helpful touphold the interest of Employer (BSNL), Employee and Customers in overall interest of our Nation.

SNEA Gujarat.

Copy to:(1) Hon'ble MOC (IT & Com), Union Govt. of India, for information and N/A Please.(2) Hon'ble Principal Secretary to PM, Union Govt. of India, for information and N/A Please.(3) Hon'ble MOC (HI and PE), Union Govt. of India, for information and N/A Please.(4) Hon'ble MOS (PMO) Union Govt. of India, for information and N/A Please.

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Thanking you,

(BGPatel):Ci