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Updated : Dot Issues Loi For New Eligible Telecom Operators, More Competition !

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IndiaInfoline

2008-01-10 17:25

One could see five new mobile telecom brands being hawked in the country over the next few months with the Department of Telecommunications (DoT) on Thursday issuing Letter of Intents (LoIs) to all the eligible applicants who applied before Sept 25, 2007.

Four companies - Unitech, Datacom, Shipping Stop Dot Com-BPL and Shyam Telelink - received LoIs for pan-India mobile operations while Swan Communications got it for 13 circles.

At the same time, Parsvnath, Indiabulls, ByCell, Cheetah, Allianz Infra and HFCL failed to get any LoIs. Moreover, Idea received LoIs for 9 new circles, Tata Teleservices for 3 new circles and Spice Communications for 4 new circles.

These LoIs need to be converted into licenses by paying an upfront fee to DoT. This will differ from operator to operator depending upon the number of circles for which a company has got the LoIs.

Earlier, Telecom Minister A. Raja signed an in-principle order for the start- up GSM spectrum allotment to Reliance Communications (RCOM), and additional GSM spectrum to Bharti Airtel and Vodafone.

The development spells good news for RCOM as it can now go ahead and place orders for GSM equipment and put all the systems in place. And, whenever the Defence Forces vacate the spectrum, RCOM can roll out its GSM services.

Idea Cellular also got a start up spectrum for two circles i.e. Mumbai and Bihar. Idea currently operates only in 11 circles.

Unified Access Services Licence (UASL) authorizes a company to rollout telecom access services using any digital technology which includes wireline and/or wireless services. They can also provide Internet Telephony, Internet and Broadband.

DoT sources said that ByCell’s application was not rejected but only referred to the home ministry. This is because the company has not obtained the Foreign Investment Promotion Board’s clearance for increasing its investments in India. Each of these companies will have to pay Rs 1,651-crore licence fee for a pan-India licence (less if it has applied only for some circles), and wait in queue for spectrum, which will be allotted once the defence forces vacate a part of their spectrum.

On paying the licence fee, they will also have to apply to the DoT’s Wireless and Planning Co-ordination Wing (WPC) for a spectrum licence. Commercial services can be launched only after spectrum is allocated. Each LoI holder, after it pays the licence fee, will be entitled to 4.4 MHz of GSM spectrum per circle, subject to availability. Under the existing first-come-first-served policy, the priority in queue for the licence ensures the same priority in the queue for spectrum.

In broader terms, UASL is an umbrella licence and does not automatically authorise UASL licencees usage of spectrum to rollout mobile services. For this, UASL licencee has to obtain another licence, i.e. Wireless Operating Licence which is granted on first-come-first served basis subject to availability of spectrum.

The DoT has been implementing a policy of first-cum-first-served for grant of UASL. Under this policy, initially an application received first will be processed first and thereafter if found eligible will be granted LOI and then whosoever complies with the conditions of LOI first will be granted UASL.

UASL guidelines were issued on Dec. 14, 2005 by DoT. A reference was made to TRAI on April 13. The TRAI, on Aug. 28, 2007 recommended that no cap be placed on the number of access service providers in any service area. The Government accepted this recommendation.

Sources said the government has enough spectrum to accommodate at least 5-6 new players after meeting the demands of existing GSM players as well as Reliance Communications which has been permitted to start GSM services under the dual technology clause.

The opinion is divided among the analyst community on what is it going to do for the telecom landscape in this country.

A section of analysts believe that it is going to bring in more competition, lower tariffs which is good for the consumer, there is scope for another 2-3 operators at least to make money considering the fact that our teledensity is under 20%. However, there is another section of analysts, which believes that it is already an overcrowded market with 6-7 players and that there is no room really for any of these new entrants. We will have to wait and watch what happens.

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NEW DELHI: The Department of Telecom has given in-principle approval to two Tata Group firms for starting GSM-based mobile services across the country.

The applications of Tata Teleservices Ltd and Tata Teleservices (Maharashtra) Ltd have been approved for providing GSM-based mobile services under the new dual technology norms, official sources said.

Both the companies currently offer mobile services under CDMA technology platform. While TTML operates in Maharashtra, TTSL provides services in rest of the country.

The two firms had sought approval late last year from DoT after it allowed companies to offer mobile services under both GSM and CDMA technologies.

DoT has already allowed rival CDMA operator Reliance Communications Ltd to start GSM services. The Anil Ambani Group has also deposited Rs 1,651 crore as licence fee with the government and is awaiting award of spectrum.

With the approval, both the companies would now have to deposit Rs 1,651 crore for a pan-India GSM licence, after which they would be alloted the airwaves to launch operations.

well only DOT knows how many players would be there and thats sure the competetion is gonna get to8ugh

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At the same time, Parsvnath, Indiabulls, ByCell, Cheetah, Allianz Infra and HFCL failed to get any LoIs

DoT calls back 6 rejected cos for telecom licences

NEW DELHI: In a complete turnaround, the Department of Telecom (DoT) is now reconsidering the applications of six companies for telecom licences, which include Allainz Infratech, S Tel, Spice Communications, Indiabulls-owned Selene, Parsvnath and Cheetah Corporate Services, which it had rejected on Tuesday.

Importantly, ByCell, which heads the queue for telecom licences, whose application was not considered as it had not got clearance from the home ministry, has also been cleared to get Letters of Intent (LoI) for five circles.

This is because ByCell had already obtained the Foreign Investment Promotion Board’s approval for launching services in these five circles, Assam, Bihar/Jharkhand, North East, Orissa and West Bengal, as early as January 2006. The MHA clearance is only for the remaining 17 circles, for which the company had applied recently.

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Source - http://timesofindia.indiatimes.com/Idea_By...how/2693915.cms

Idea, Bycell write to telecom ministry

NEW DELHI: The award of letters of intents (LoIs) by DoT on Thursday to a clutch of firms, picked by creating an arbitrary cutoff date for applications, coupled with an unprofessional manner of handling applications, has triggered off protest from companies.

Idea Cellular and Bycell have been the first to log in protest. ToI has repeatedly pointed out that the manner and behaviour of the telecom ministry officials in processing LoIs without clear guidance on priority is a ground for manipulation and litigation. Idea and Bycell have shot off letters within 24 hours of LoIs being granted. Several others are expected to follow suit.

The lack of clarity is making even those who make payments nervous. The next round of fencing will come into the open as soon as priority for spectrum is decided because in the end, spectrum is all that matters.

Sanjeev Aga of Idea has written to DoT secretary, Siddharth Behura, alleging that DoT officials ensured that their company official could not make the payment for licences a moment sooner than he did. Idea points out that this is hardly the company's fault since it has been waiting with financing since mid 2006.

It writes: "On December 27, 2007, we asked the government to accept our payments along with guarantees. We were prevented from making payment purely because the government did not accept it. Yesterday, January 10 2008, at about 2:45 PM, the government posted a press release on its web site intimating that the process would commence at 3:30 PM. The process was highly unusual. Our authorized representative has been present at Sanchar Bhavan through all working hours, since January 8, 2008, ready with payments, guarantees and all documents. He was outside the second floor committee room when the press release appeared on the web. He received our nine LoIs as soon as they were given to him."

"He sprinted with LoIs to the reception. He deposited payment and documents, as soon as this was accepted from him. During those surreal minutes, all activities were controlled by DoT functionaries. We could not have made payment even a moment earlier than we did," the letter added.

Idea has asked DoT, "as per established practice of the government, as per Clause 23 of the unified access service licence guidelines of December 14, 2005, and as per expected conduct of the government in dealing with public property", to ensure that the seniority of its applications of June 26 2006, are not tampered with for issue of licences and spectrum.

ByCell sent out a press release alleging that it was refused LoIs on the basis of a forged complaint.

According to the DoT letter sent to ByCell on Friday, its applications dated January 31, 2006 for Assam, Orissa, Bihar, North East and West Bengal telecom circles has not been considered due to pending security clearance.

ByCell believes this has been due to false complaint related to security issue filed on behalf of a prominent MP to the PMO on October 2007. Later, the MP clarified that the earlier letter was a forged document and he had no complaints against ByCell.

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Source - http://economictimes.indiatimes.com/News/N...how/2692633.cms

Videocon to roll out mobile services by end of 2008

NEW DELHI: Consumer electronics major Videocon today said it will roll out its mobile services by the end of this year and is expecting 10 million subscribers in 3-4 years of the launch. Videocon is also planning to rope in a global service provider as the partner at an appropriate time, the company said in a statement here.

"The company plans to use its extensive all India dealer network of over 10,000 to reach out to the customers and expects to have 10 million subscribers (on conservative basis) in 3-4 years of launch," it said. Videocon's subsidiary Datacom had yesterday received Letter of Intent from the Department of Telecom for starting GSM-based mobile services on a pan-India basis.

Datacom has deposited the Rs 1,507 crore as license fees alongwith bank guarantee of Rs 847 crore to the DoT. With an aim to improve efficiency and profitability of the business model, the company also plans to introduce various innovative services, the statement added. Videocon said a number of local and global banks and financial institutions have expressed interest in providing fund, non-fund and service based support to the project.

In another development, realty major Unitech informed the Bombay Stock Exchange that the DoT has issued LoIs to its eight subsidiaries for starting mobile services in 22 circles. The company has paid the required fees of Rs 1658 crore and bank guarantees of Rs 882 crore. Telecom player Idea Cellular also informed BSE that the company has received LoIs for nine circles and it intends to rollout services in these circles as soon as spectrum is made available.

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Source - http://economictimes.indiatimes.com/News/N...how/2693914.cms

Unitech likely to hive off telecom business

NEW DELHI: Real estate major Unitech, which was awarded a pan-India telecom licence on Thursday, plans to hive off its telecom business as a separate profit and loss centre. The company will transfer its existing telecom infrastructure business, where it manufactures towers for various service providers, into a fresh entity. At a later stage, the company would look at listing the business on the bourses in India.

Importantly, Unitech in also learnt to be in talks with several international majors and financial investors for technical and strategic partnerships for its telecom foray, although the company has not taken a final decision on this issue.

“Unitech sees the potential in the telecom business and believes that investment in this sector would provide immense potential for value addition to the group,” a source close to the development in the company said.

Unitech had applied for a pan-India licence through eight subsidiaries — Adonis Projects, Aska Properties, Azare Properties, Hudson Properties, Nahan Properties, Unitech Builders and Estates, Unitech Infrastructure and Volga Properties.

Unitech MD Sanjay Chandra was not available for comment. However, a source close to the development said that the company will start the process of structuring its telecom business as soon as its ongoing fund-raising exercise for its real estate business is complete.

The company is in the process of raising about $2 billion, of which, $700 million will be raised through an IPO on the Singapore Stock Exchange and $1-1.5 billion through a qualified institutional placement (QIP).

The company is looking at providing GSM services in 22 circles, for which, it has obtained Letters of Intent from DoT and has converted it into licence by paying the requisite money. The investment figure that the company is looking at for the telecom venture could not be confirmed.

So far, the company has deposited the entry fee of Rs 1,658 crore, financial bank guarantee of Rs 630 crore and performance bank guarantee of Rs 252 crore. The company can begin commercial services after it is allotted start-up spectrum of 4.4 MHz per circle. It is not clear where Unitech stands in the queue for spectrum.

First in line for radio frequencies are existing licence holders — Idea (2 circles), Vodafone (6 circles) and Aircel (13 circles) along with existing GSM operators who need additional spectrum to expand their networks in the areas where they currently operate, followed by dual technology licence holders such as Reliance Communications, Tatas, HFCL and Shyam.

New entrants such as Unitech come next. Department of Telecom officials say that at present, there is enough radio frequency to accommodate existing operators and dual technology licence holders and added that new entrants will be allotted radio frequency as soon as the defence forces vacate it.

For Unitech, the major thrust of the company will be in rural areas. “There is lot of untapped potential in the rural areas. Most of the new players are now entering rural markets for growth and we feel that new entrants will be in a competitive position vis a vis existing players in tapping the rural potential,” the company source close to the development said.

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In which circles did Tata get LoI?

Tata Teleservices got the 3 new LoIs for the circles of Jammu&Kashmir [JK], Assam [AS] and North-East[AR,MN,ML,MZ,NL,TR]

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DoT sitting over 343 pending applications for UASL license

8 Jul, 2008, 1549 hrs IST, PTI

NEW DELHI : The Department of Telecom, which has granted 120 new telecom licenses to 575 firms, is now giving the cold treatment to 343 other applications that are pending with it.

Sources said DoT is unlikely to take any action on these applications, which came between September 26-October 1, last year, as each circle now has over 10 players and the scarcity of spectrum (radio waves) is also a factor to deal with.

DoT has to first allocate spectrum to those who have already been given the license and even if it does, there is no way 15-16 players can survive in a circle - which would be the scenario if the pending applications are cleared, sources said.

DoT would first consider the performance of the players, who applied till September 25 and subsequently allocate spectrum on a first-come-first-serve basis, sources added.

DoT is struggling with the developments so far, but by now it has managed to award spectrum for 5 circles Kerala, Tamil Nadu, Orissa, Andhra Pradesh and Assam.

This at least, for the time being seals the fate of companies who applied between September 26-October 1. They include US major AT&T, real estate giant DLF, realty company BPTP, Sterlite and Moser Baer.

Each of these companies, who have been given license have paid Rs 1,651-crore fee for a pan-India licence and waited in queue to apply for the DoT's Wireless and Planning Co-ordination Win g (WPC) for a spectrum licence.-+

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New telcos may get spectrum in Mumbai, Maharashtra, MP,Kolkata

24 Aug, 2008, 1548 hrs IST, PTI

NEW DELHI: Within days of Delhi High Court giving clean chit to the government, the Department of Telecom is all set to allocate start-up spectrum to new players in four more circles of Maharashtra, Mumbai, Kolkata and Madhya Pradesh.

The new players include Datacom promoted by Mahendra Nahata of HFCL, realty major Unitech, BPL led Loop Telecom, Swan Telecom and Tata Teleservice under the dual technology clause and others.

The DoT has already alloted start-up spectrum in five circles of Tamil Nadu, including Chennai, Karnataka, Kerala, Andhra Pradesh and Orissa.

Spectrum refers to the radio frequency that enables wireless communications and has been the sources of considerable controversy over the past one year due to differences between the existing players and the policy makers over the dual technology and revised norms of spectrum allocation.

The association of existing GSM players, Cellular Operators Association of India (COAI), had strongly opposed the move to give new licences saying there was not enough spectrum.

The DoT had earlier said that enough spectrum was available to meet the demands by the existing players as well as new players.

Shyam Telecom, which has opted to adopt CDMA technology for the mobile services has already got spectrum in most of the circles, except in two major circles of Delhi and Mumbai.

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Valuations leapfrog for new telecom entrants

24 Sep, 2008, 1146 hrs IST, ET

NEW DELHI: Swan Telecom, which bagged a licence to run mobile services in 13 circles in January for less than $351 million, has walked away with a $2 billion valuation, more than 6.5 times in just a few months and with very little spectrum in hand.

This handsome valuation comes despite the knowledge that spectrum is available in only a handful of the 22 circles for new entrants and is a testimony of the high growth path that lies ahead for India.

In January 2008, the telecom ministry awarded 120 licences to nine companies at roughly Rs 1,651 crore or $351 million for a 23-circle pan-India licence. The main beneficiaries were Swan, Unitech, Loop (Essar), Videocon, Idea, and Shyam among others and the government earned around Rs 9,000 crore from this sale.

While Swan is the first to close a deal, almost all the other new entrants are boasting of similar $2 to $3 billion valuations or six to eight times what they paid for entry only eight months ago. This confirms the finance ministry and Central Vigilance Commissions (CVC) fears that the telecom ministry’s 2G spectrum sale in January has been undervalued.

The finance ministry had argued for at least a 3.5 times higher valuation, thus indicating a loss of at least Rs 25,000 crore. However, with a market valuation of over six times what the ministry sold it for, the loss to the exchequer is now closer to Rs 40,000 crore.

Had the government consolidated the spectrum and sold it through an auction process, this money would have flowed into its own coffers rather than into the hands of a few gold diggers.

Several government departments and analysts had protested that this sale of spectrum bundled with 2G licences at 2001 prices had caused huge losses to the exchequer . The Prime Minister himself questioned the process and pricing on several occasions while the CVC launched a probe over spectrum being sold at a price that was far below the market rate.

Till now, these numbers have been debated without any actual deal in place. This first closure establishes a market-based pricing, confirming that while the private sector will make a killing, government has taken a hit on revenues and raises more questions than it answers.

India’s telecom sector has registered brilliant growth, one of the reasons why companies are willing to pay top dollar for scarce spectrum. Its subscriber base is expected to double from 300 million to nearly 620 million by 2012.

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Unitech sells its 60% telecom stake to Telenor

New Delhi, Oct 29: Real estate major Unitech on Wednesday announced selling of 60 per cent stake in its telecom venture for Rs 6,120 crore (about 1.23 billion dollar) to Norway-based Telenor, which has mobile operations in 12 countries with 160 million subscribers.

Unitech was awarded pan-India mobile telecom license for Rs 1,651 crore early this year and has got GSM spectrum in 13 circles. The company plans to launch services in the first half of 2009.

"This is a landmark deal. At a time when lot of foreign exchange is outflowing, this deal will bring in much needed foreign exchange into the country," Unitech's telecom venture Chairman Sanjay Chandra said.

The deal has put the enterprise value of Unitech's telecom business at a whopping Rs 11,620 crore (2.35 billion dollar), he said adding the company would now start the process of rolling out network through out the country.

Telenor, world's seventh largest mobile operator has operations in Europe and Asian countries, including 100 per cent subsidiary in Pakistan.

This is the second deal among the new GSM operators. Earlier, Swan Telecom with license for 13 circles had sold 45 per cent stake to UAE-based Etisalat for 900 million dollars.

Chandra said the approval for sale of 49 per cent stake has already been received and the company would soon approach FIPB (Foreign Investment Promotion Board) for 60 per cent stake-sale.

In a filing to the Bombay Stock Exchange, Unitech said that its telecom arm intends to play a significant role in India's exciting story of telecom growth and become a long term and successful telecom operator.

"In light of this aspiration, the company will be investing over USD three billion over the next three years," it said.

Unitech Wireless has pan-India telecom licenses in all 22 circles and plan to launch its services in first half of 2009. The company has already recruited more than 250 employees and established offices across several cities.

Headquartered in Oslo, Norway, Telenor is a global provider of high quality telecommunications, data and media communication services. It is owned 54 per cent by Ministry of Industry and Trade, Norway.

Shares of Unitech Ltd were trading at Rs 49.15 at 1230 hrs today.

[vIa:zeenews]

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DoT to allot spectrum to telecom cos in 10 days: Sources

CNBC-TV18 l 24 Nov

The Department of Telecom, or DoT, will allot spectrum to Datacom, Unitech, Swan, Loop, Tata Telecommunications, and Bharti in 10 days, reports CNBC-TV18, quoting sources.

Among all, Datacom is the first in queue for Delhi allotment and might also get Rajasthan, sources said, adding Loop, Swan, Bharti will be allotted spectrum only in Rajasthan.

According to data provided by sources, Datacom will get 3.2 MHz pair in Delhi, and 4.4 MHz pair in Rajasthan.

Meanwhile, Unitech, Loop and Swan will get 4.4 MHz pair in Rajasthan, while Bharti will get 1 MHz pair in Rajasthan.

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Rollout norms for new telcos may be scrapped

Economic Times l 26 Nov l New Delhi

In a volte-face, telecom minister A Raja on Tuesday said the rollout deadline mandating new telecom operators to cover 10% of districts in a telecom circle in the first year is likely to be scrapped as ‘the government could neither monitor nor penalise errant telcos’.

Another norm mandating new telcos to cover 50% of the circle within three years remains. Under current norms, any company that gets the government nod to launch mobile services must ensure its services are available in least 10% of the districts in that circle or area within the first year of obtaining the licence, and 50% of the districts within three years of the effective date of licence.

Clarifying the move, the department of telecom (DoT) said it wants to liberalise rollout norms and has proposed that telcos be monitored only after three years. “The one-year obligation to roll out 10% of services is unfair and an irritant. The existing players have also appealed to us regarding the obligation and we have sent the matter to the Telecom Commission for review.

The three-year time period is fair and realistic,” telecom secretary Siddharth Behura said on the sidelines of the Economic Editor’s Conference. Relaxation of the rollout norms would benefit new telecom players such as Swan, Unitech, Datacom, S Tel and Loop Telecom.

These companies, which received licences in January this year, are mandated to roll out their services by January 2009. A new operator needs to invest about Rs 22,000 crore to meet the rollout obligation in the first year, in case of a pan-India network.

In the wake of the credit crunch, new telcos are finding it difficult to raise funds to meet the obligations. Licensees failing to meet the one-year deadline are levied a maximum penalty of Rs 7 crore per circle.

The telecom minister has also sought the opinion of telecom regulator Trai and corporate affairs ministry on imposing a three-year ‘lock-in’ on sale of promoter equity in telecom start-ups. Ironically, this comes after the Telecom Commission, which is the apex decision-making body within the DoT, approved the lock-in period to rein in potential windfall gains of start-up promoters.

In a late realisation, Mr Raja said this move may amount to tinkering with licence conditions and so has now sought Trai’s recommendations.

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Raja, Behura differ on rollout obligations

TNN l 26 Nov 2008 l New Delhi

Telecom minister A Raja and his secretary S Behura on Tuesday were not quite on the same page on the controversial issue of rollout obligations for new operators.

At a press conference, Behura said, “Rollout conditions are an irritant. Globally they have been removed”. According to him, “No company in India has ever violated rollout obligations till date or ever paid penalties”.

Raja has said that new telecom companies will have to face licence termination and subsequent surrender of spectrum if they fail to start services within the stipulated three-year period.

According to the licence terms, in the first year, telecom companies are required to cover at least 10% of each district headquarter in a circle and 50% of the districts within three years from the date of allotment of spectrum. In metros , the companies have to cover 90% of service area within one year.

When asked under which section of the licence the DoT will take back spectrum, Raja failed to respond. When asked why he removed the linkage between rollout obligations and M&As that were recommended by the TRAI in August 2007 while formulating M&A guidelines in April 2008, Raja asked Behura to respond.

Behura, in turn, said rollout obligations in general were impractical since the DoT could neither monitor nor penalize violation of rollout violations.

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Unitech, Idea Cellular receive spectrum

Economic Times l 8 Dec l New Delhi

Real estate giant Unitech, which recently tied up with Norwegian telecom operator Telenor to launch mobile services in India, and Idea Cellular have been alloted 4.4 MHz of spectrum in the 1,800 MHz GSM band, the companies said on Monday.

'The Department of Telecommunications (DoT) has issued the letter to the company's telecom subsidiaries for allotment of 4.4 MHz of spectrum in 1800 MHz GSM band in respect of Haryana, Himachal Pradesh and Kolkata service areas,' Unitech's official statement said.

With this, the company has been allotted initial spectrum in 16 service areas out of total 22 service areas. Idea Cellular said in a separate statement that it has been allotted spectrum in the same bandwidth in respect to Kolkata Metro Service Area.

Unitech Wireless, part of the Unitech group, is scheduled to start operations in the second quarter of 2009. Reeling under liquidity crunch, the company earlier said it would mobilise up to Rs.2,500 crore (Rs.25 bn) through sale of some assets and equity to retire part of its Rs.8,000 crore (Rs.80 bn) debt by March 2009.

'We are working on many options to raise funds,' Unitech chairman Ramesh Chandra said, adding it could be through sale of some completed projects or offloading equity at project level to private equity funds.

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Idea Cellular gets competitive edge

Business Line

Indus Towers stake a shot in the arm.

Idea Cellular’s pan-India expansion has received a boost with the allocation of 4.4 Mhz start-up spectrum for the Kolkata circle.

This follows the allocation of spectrum to the company in Tamil Nadu (including Chennai). New entrants to the mobile telephony space such as Unitech have also been allotted start-up spectrum in 16 circles, with Kolkata being the most recent allocation.

But Idea would have a clear edge over these players in the newer circles that it has launched services.

It would leverage the benefit of being a stakeholder in the tower infrastructure company Indus Towers, and this can lead to a quicker rollout.

Once mobile number portability is introduced, Idea may steal a march over new entrants and gain from any churn of subscribers from incumbent players.

The other key advantage that Idea may possess is that new spectrum has been allocated in the 1800 MHz band. This makes capex rollout more expensive for new entrant such as Unitech. For Idea, except the newer circles, in as many as nine circles, it has spectrum allocated in the more efficient 900 MHz band.

Idea would hope to replicate the robust subscriber addition that it has managed in Mumbai and Bihar where it has launched operation over the last three months.

The company has managed to garner 18.5 per cent and 21 per cent of incremental market share in Mumbai and Bihar, respectively, despite Idea being the sixth or seventh operator in these states.

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When is idea going to launch IT'S services in ORISSA circle remains to be seen.

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