This was stated by BSNL in its response on the regualtor's second IUC (interconnect) consultation paper.

In the IUC regulations especially in second phase, certain amounts have been wrongfully deducted on account of local call surplus and licence fee reimbursement.

For ADC alone, if the difference between costs based rental and actual rental would have been taken, the ADC requirement would be at least Rs 8708 crore (Rs 87.08 billion) a year, BSNL said.

A total ADC funding allowed is just Rs 4792 crore (Rs 47.92 billion) after deducting license fee reimbursement and local call surplus. This shift in methodology of calculation of adc in the second phase of IUC regulation has resulted in a an uncovered deficit of Rs 3916 crore (Rs 39.16 billion).

No ADC was also allowed for free calls and below cost units charges. In the first phase of IUC regulations, the deficit was Rs 2549 crore (Rs 25.49 billion) and in case the deficit on account of both the first and scond phase of IUC regualtion, the uncovered deficit rises to Rs 6465 crore (Rs 64.65 billion).

In the first phase of IUC regulation, Trai provided for Rs 12381 crore (Rs 123.81 billion) ADC for BSNL while the estimated ADC receipts of BSNL was Rs 7851 crore leading to a shortfall of Rs 4530 crore (Rs 45.3 billion).

In the second phase of IUC regulation, Trai provided for Rs 4792 crore (Rs 47.92 billion) and BSNL's estimated ADC receipts was Rs 4559 crore (Rs 45.59 billion) - a shortfall of Rs 233 crore (Rs 2.33 billion).