How to make India a no Tax regime.

How to make India a no Tax regime.

Short link

Exclusively Banked Money through Mobile (mTm) system

Introduction. Management of money through phones, both Mobile and Fixed ones, can greatly boost nation’s economy and as well can generate huge income for Government, considerably reduce need to print currency and reduce the malice of Black Money. It is time Government / RBI take necessary steps to mobilize, regulate and tap this great potential to revive Indian economy. Please see my blog in the link

  1. India has a Billion phones (Mobile plus Landlines) and growing.

With an average transaction of Rs.10,000 per month per phone, the monthly virtual money transaction will be about Rs.10 L Cr (Rs. 10 Trillion) Assuming that virtual money transactions and re-transactions happen on an average of 20 times a month, it will be Rs.200 L Cr per month that amounts to Rs.2400 L Cr (Rs.2400 Trillion) annual.

2. Revenue generation.

Hypothetically, with 1% transaction charge on every money transaction to start with, Government can fetch annual revenue of  Rs. 24 L Cr (Rs. 24 Trillion) that can cover entire annual budget expenditure in the current form and much more without burdening people with any tax at all. (The expenditure outlay of 2015-2016 Central budget is only about Rs. 17.8 L Cr. (Rs. 17.8 Trillion) The transaction charge can be partly a fixed charge and partly a variable charge according to amount of transaction involved.

3. Why Virtual systems, not regular banks.

Most banks, both Public and Private have its limitations to take care of the needs of the huge un-banked population, especially in the lower social and economic strata across the country. Naturally, handling of such enormously high volume of low value accounts   would eventually lead most banks to collapse due to severe HR constraints and gross customer dissatisfaction, for no fault of the banks. Of course, it will not be possible neither to bring everyone into this system nor every phone user to use virtual money route for quite some time. But a good majority population could be covered as explained in my blog  Others can continue the service of regular banking system or both and brought in in a phased manner.

4. What is the way out.

The way out is to bring in place ‘Exclusive special purpose Digital Online Virtual Banks’ that will take care of all forms of money management using phones, both Mobile as well as Fixed, that can function with minimum human interface, across the country deploying modern technology systems and network. It is good to see Government has finally understood this and gone ahead giving permission to implement payment banks.

Virtual money is best handled by virtual banks

5. By going virtual, money becomes a much higher dynamic resource and more so when almost every money transaction done virtually with more ease and comfort, number of transactions and the revenue earned by it would grow ten fold and more, taking the revenue from Rs. 24 L Cr to Rs. 240 L Cr (Rs. 240 Trillion) making it possible to realize much needed drastic increase in Government’s budget outlay and/or reduce transaction charge from 1% mentioned above to 0.5% or as low as 0.05% keeping balance between revenue and expenditure as needed from time to time.

mTm Money Chain, Physical and Virtual (R)

6. Looking the money chain above closely it can be seen that the system as envisaged will boost the physical money reserve in RBI by Rs.100s of trillions that can in turn boost the liquidity and nations  overall economy.

7. Telcos also can prosper with appropriate revenue share between them and the Government. Currently Telcos are burdened with high CAPEX & OPEX costs plus un-justified license & spectrum costs. Over and above Telecom  is at cross roads being stuck up between fast changing new technologies and inability to cater such high volume of users and their diverse service demands with heavily invested legacy systems and network. Money through Mobile mTm in the link mentioned above, is a non telephony based Value added service than can rescue Telcos at this  juncture.

By Abraham Paul. P.   Tweet @PA_Paul

Posted in Uncategorized | Leave a comment

Digital India: Views, Opinions, Suggestions and New Proposals on various Technology and Social and Community affairs.

Digital India: Views, Opinions, Suggestions and New Proposals on various Technology and Social and Community affairs.


Submitted by:   Abraham Paul. P.                Dated 22 June 2015

Ex. Owner, FCOMNET Futregroups India/UAE, VP (TS) SPCNL, SIEMENS ICN Germany/ Director (SC) SIEMENS RHQ, UAE/ GM & SMT TBG, BPL Mobile, India/ TES (I) DOT India. e-mail:

The suggestions and opinions are strictly based on my personal views. The intention is not to contradict the policies of Governments or any other Institutions organizations or individuals. I do not disagree with anyone who chose not to agree with me and my views. Due apologies for anything herein are contradictory, or in violation of any standing instructions or policies of the government or anyone else; it is un-intentional and therefore, may please be condoned. The ideas contained are free for anyone to take and use. Take what one like and ignore the rest. Abraham Paul. P. ______________________________________________________________Salient points:

  1. Government’s role in Digital India.  Private telecom players are doing great. However, they cannot be fully depended to fulfil social commitment especially in areas where revenue potential is low  making Government’s role important and un-avoidable. One area to focus is diversification and effective use of Country’s 150,000 Post offices combined with pan India coverage by BSNL for Digital India projects such as un-banked money management service.
  2. Digital India program need to take on with pragmatic approach. There is nothing known as perfect in planning. Technology is changing fast. What is good today may become obsolete later. It will take quite many years for 65,000 villages in India networked with redundant and fail proof OF cables connectivity. Probable that the technology will undergo changes by then and the effort would go waste. Pragmatic approach will be to take on digitisation wherever eco system needed is readily available by rolling out features, products and services for financial inclusion and inclusive growth in urban and semi urban areas and towns and villages and then grow towards remotely rural areas in a phased manner. The way forward is to keep in mind that Telecom growth in rural and remote areas shall happen hand in hand with improvement of over all eco system and basic standard of living. Please see my blog in the link on this.
  3. Cloud Computing , India Cloud and indigenous Internet explorer servers.  INTERNET is the best thing that happened in the technology space. Openness is its greatest merit. However, being come into existence as a by chance baby with no regulatory controls in place, INTERNET is slowly turning boon to bane in many counts, security is one among those. Future wars may not be with guns and bombs but in the cyber space that can paralyze any country in no time.

4. The need of the day is to build an exclusive fully firewalled India INTERNET Cloud that can provide secure internet network and connectivity for nation’s various needs and uses. Future ICT networks will be using cloud computing over exclusive clouds by all sorts of service providers, organizations and the Government for almost all of its communication and business & management services. Along with it India should have its own indigenous INTERNET explorer servers located within the country.

5. Government should have exclusive own communication network for disaster/crisis management, administration, and security purposes. Quick means of communication is one of the vital needs at the time of major crisis and disaster and Counter terror activities.

The irony is that public telecom networks are of no help when it is most needed.  The normal telecom systems and networks are designed for optimum busy hour telephone use of a routine day. These get choked due to sudden spurt in usage in case of any calamity. Failure due to overload in one of system can cause congestion and failure of other systems in the network also.

It is impossible to design a public telephone network that is capable of handling the sudden spurt of telephone traffic of sporadic nature that happen at the time of any major events, crisis and disaster.

The way out  is to have non chocking full availability system and  network exclusively for  essential services such as security, army, police, ambulance, hospitals, road transport & traffic control, air traffic control, railways and important persons/ organizations and local administration, that are vital in the crisis control/disaster management system.

  1. Make Telecom Systems, network, Phones, product and services for the common man.

Phones are no more just phones but mini computers. However, super hyped high profile Mobile phones can reverse the telecom growth and to a great extent kill the business itself. Moreover, super hyped phones are good for phone manufacturers, but ‘It is like putting the cart before the horse” where advance systems and networks are yet to be ready across the service area.

Therefore,  there is urgent need to make Telecom systems, Networks, Phones, Products and Services that are available, accessible and affordable to common man. As in every business, success of telecom business is in its user volume; and ‘Cost of user devices’ and “Cost of Usage’ are important factors in bringing in business volume.

6.  Technology based Universal Emergency support Systems, Solutions and Services.

7. How to reduce accidents due to Drunk Driving.

8.  Quality consciousness is of prime importance for success of ‘Make in India’.  >>>  and more. Please click on the caption below to open the list and summary of articles and  links to full articles.   Digital India

Abraham Paul. P. ______________________________________________________________

Posted in IT based services, Life science technologies, Mobile through Mobile (mTm), Personal messages and other, Politics & Governance, safety & security, Social and Community affairs, Telecom Technology | Leave a comment

How to reduce road accidents due to driving under influence of alcohol

How to reduce accidents caused due to driving under influence of Alcohol and careless driving.               Short link:

Solution: Simple. Do not allow anyone who has consumed Alcohol beyond a limit, to drive.

How: By making the Vehicle refuse to start and move if the person in driver’s seat is drunk.

1. What all are needed for this: A special purpose system in every vehicle comprising:-

i. A breath analyser at the middle area space of the driving wheel.

ii. A CCTV camera near to the breath analyser that has full profile view of the Driver.

iii. A mini size computer connected to the above that has facility to analyse breath and send signal to the vehicle starting mechanism and keep the driver under continuous observation.

iv. Optional provision to initiate a voice or data call to a predefined number of emergency or other service.

2. Method of working:

2.1. Breath analyzer at the middle  area of driving wheel.

  • The person in the driving seat after turning on ignition will have to blow into the breathing system in the driving wheel. The special purpose mini computer system analyses and if the level of alcohol content is within predefined limit, then sends an OK signal allowing vehicle to start and move. In case of excess alcohol level, the system refuses to send start signal and plays out a recorded message or a warning sounder.
  • The CCTV camera registers drivers photo and associate it with the system and continues to observe during the drive to ensure the one who started the vehicle is driving. It also ensures the person in driver’s seat do not consume drinks while driving. If there is need, the vehicle has to stop and then restart after blowing into the breath tester again.
  • A finger print identification can be incorporated to check or prevent others driving the vehicle.

2.2. Breath analyzer in Driver’s seat belt.

Alternately the breath analysis module could be incorporated in Driver’s seat belt. In this method, driver has to blow into a module built in on the seat belt of the driver which ensures the clutch is engaged with drive mechanism only is the driver has not consumed Alcohol . CCTV camera in front of the driver ensures that same person who blow into breathing analyzer is driving the vehicle. This also ensures that driver always wear the seat belt.

3. Can be implemented in any type of vehicle.

Same concept and systems suitably modified can be used in any type of vehicle and also Auto Rickshaws,  Motor bikes and Scooters. Can be useful to ensure usage of helmet by two wheeler users.

4. Useful for observing traffic rules violations.

Later, the system can be incorporated with features to ensure vehicles follow traffic rules with the help of GPS  assisted and monitored navigational system and warn the erring drivers. More features can be built into the system to check drivers using Mobile phones,  texting on phones while driving, over speeding beyond set speed limits etc., and other peculiar behaviour of drivers as they remain in observation and the system compares video against set parameters. This can reduce many road accidents.

Also see my blog on: Autonomous Charging of Road Toll, Vehicle Parking, Fines & penalties. and


Abraham Paul. P.

Posted in IT based services, Life science technologies, safety & security, Social and Community affairs | Leave a comment

Counter comments on TRAI Consultancy paper on Regulatory Framework for Over-the-top (OTT) services.

Counter comments on CP of TRAI on Regulatory Framework for Over-the-top (OTT) services.  


To Chairman, TRAI India.

Submitted by  Abraham Paul. P.

Ex. VP (TS) SPCNL, SIEMENS ICN Germany/ Director (SC) SIEMENS RHQ, UAE/ GM & SMT TBG, BPL Mobile, India/ TES (I) DOT India. e-mail:

Subject: Counter comments on CP of TRAI on Regulatory Framework for Over-the-top (OTT) services. Dated 08 May 2015.

Ref: Please refer to my comments and response to TRAI in the links.   and my paper on Net “Neutrality without hurting Telcos and End users.

Counter comments on TRAI Consultancy paper on Regulatory Framework for Over-the-top (OTT) services. I appreciate TRAI’s effort in bringing out a comprehensive document on the subject which will serve as a reference paper to any student of technology.

Counter comments:

  1. As has been explained in detail in my comments and answers to TRAI’s consultancy paper on this, the subject matter is very complex; going into details will be like opening another Pandora’s box.

Any attempt to regulate Internet will be a horrendous mistake. Internet being what it is and openness its main strength; reigning in it under sorts of regulatory controls by a particular country or region is going to be almost an impossible task  and it will defeat its basic strength, purpose and utility.  Such being my view on this, it is felt that going in detail on various comments will be a futile exercise. It will be more fruitful to see  what are TRAIs counter comments of on various comments from major stake holders.

2. None the less,  there are valid points in Telecom Service Provider’s concerns about disparate Over the top (OTT) players eating into their means of revenue, especially in the area of Telecommunication based value added services. It is more so when it is done by external OTT players that have no agreements either with the Government or with any Telecom Companies (TELCOs) in this region, and having no licensed spectrum in the Country but using Telecom Service Providers (TSP’s) spectrum, network, systems and customer base and sell TSPs products and services; free of charge or at competitive cost. Most probable that they will slowly start charging once they gain more access and business in the field.

These OTT players can tie up with regional Internet Service Providers (ISPs) that can be accessed over TV cable connectivity and totally bye pass Telcos by providing Voice over Internet protocol (VOIP) connectivity between computers and through new generation Mobile phones by logging into ISP over local WiFi link. May be that is why some of the ISP owners keenly voicing for #Netneutrality.

However, increasing cost of usage by TSPs as being indicated by COAI to overcome this is no solution as it will only push more of their loyal customers to OTT services that will further diminish TSPs revenue on one side and higher cost of usage will make huge volume of low end customers to fall off killing TSPs business volume on the other side.

3. Ultimate solution is elsewhere. Please see my paper on “Net Neutrality without hurting Telcos and End users.

Fact is IP based Information Communication Technology (ICT) will disrupt legacy TELCOS. Even phones are no more just phones but mini Computers that take care of almost all forms end users technology needs that can be realized through advanced Computers in addition to Information Communication service which is now becoming just a small area of the whole range of products and service that getting wider and wider everyday. I had predicted a decade back the possible impact of transition from Voice to Data and Multimedia in my blog  Currently it is experienced by all mobile users how bad the is the quality of simple voice call services by almost all Mobile phone service providers. Reasons of this are explained in my papers in the links above.

Therefore, it becomes necessary to take the arguments beyond Net neutrality. According to me, the way out is to collate TSPs and ISPs.  As mentioned in my above paper, and comments and answer to questions in TRAI consultancy paper on the subject, the ultimate solution is in switching over to end to end systems products and service to IP based Systems, Networks, Transport and User end devices that can then function truly net neutral.

It means that functionalities and service delivery of TSPs & ISPs can be rolled into one. With such a scenario, though there can still be various modes of same service and  delivery; its tariff could be based mostly on its quality, efficiency and user friendliness and finally left for the market and competition will to decide and set the tariff, cost and pricing. OTT(2)

4. Security shall be major concern. Various forms of Security risks in leaving any country’s entire communication systems open to large number of unlicensed and unregulated external players from around the globe is a major concern, it is for the Government to ponder what and how something can be done to safeguard nation’s interest on top priority. There are options like what I had been propagating for many years in my paper, “Exclusive Govt. owned Communication Systems and Networks for Crisis and Disaster management and national security.” Future wars will be less with Guns and Bombs but more in the Cyber space.  Hope Government will seriously look at it.

5. CLOUD and CLOUD COMPUTING is one of the options.

It is understood that ISRO had already put or orbit three satellites for this purpose and three more are in the anvil. With this in place India should have an exclusive CLOUD for security reasons.  How is it related to #Netneutrality is explained in my paper, this shall be a fully firewalled INDIA cloud that would include the communication spectrum in the region so as to prevent illegal and un-authorised technology players getting into the India networks under the cloud. The sooner it happens, the better. Conclusion. Till then TRAIs paper and efforts on Net neutrality will remain as a good exercise to make awareness of the issues involved among various stake holders including Government and the general public.

Abraham Paul. P.



1. Impact of transition from Voice to Data and Multimedia.

2. Telecom Industrialists need caution on broad band network ideas that do not fit in the future.

3. Net Neutrality without hurting Telcos and End users.

4. Response TRAI on Regulatory Framework for Over-the-top (OTT) services.

5. Government  owned Communication Systems and Networks for Crisis and Disaster management and national security.”


Posted in IT based services, Social and Community affairs, Telecom Technology | Leave a comment

Response to TRAI Consultancy paper on Regulatory Framework for Over-the-top (OTT) services

Response to TRAI Consultancy paper on Regulatory Framework for Over-the-top (OTT) services.  

Short link:

To                                                                           Dated 22 April 2015.

Chairman, TRAI India 

Submitted by   Abraham Paul. P          

Ex. VP (TS) SPCNL, SIEMENS ICN Germany/ Director (SC) SIEMENS RHQ, UAE/ GM & SMT TBG, BPL Mobile, India/ TES (I) DOT India.


Subject: Regulatory Framework for Over-the-top (OTT) services.

Ref: Consultancy paper on the above.

Please see my blog: Net Neutrality without hurting Telcos and End users.


Answers to the questions in the above consultancy paper.  

Question 1: Is it too early to establish a regulatory framework for OTT services, since internet penetration is still evolving, access speeds are generally low and there is limited coverage of high-speed broadband in the country? Or, should some beginning be made now with a regulatory framework that could be adapted to changes in the future? Please comment with justifications. 

Answer 1:  Yes. Some beginning should be made now with a regulatory framework that could be adapted to changes in the future.

INTERNET is the best thing happened in the world of communication technology. INTERNET came into existence like a by chance bastard with no regulatory control in place and it is almost impossible to fully reign in now.

It so happened, that openness is main strength and virtue of Internet that make it a boon to ICT as a whole; anything done to restrict it will fully defeat it.

Internet being an umbrella system that nurture everything under it without discriminating what, why, who, secure or unsecure, good, bad or ugly and what not; thus making it a boon to most but can also be bane to many.

Security and discreteness being important requirements in any business, same shall be applicable in Telecom business also. Though telecom operation by nature is interworking between domains of different service providers, there shall be clearly defined business practices in using others resources and customer base.

The way out is not to remove openness of Internet but to regulate its access at subsystem level where it infringes into areas of business of other licensed service providers without appropriate business understanding with them.

World wide web being like one big sea, and information interchange happen in pure chance manner In millions of alternate paths, it is impossible to bring this regulation within itself. However, while trying to regulate externally, it should not totally turn it to something else that curtail its openness which is its main virtue.

The only way to do this is by creating subnets as regulated INTRANET CLOUDS below it keeping World Wide Web intact at the top level.

Analogy can be in viewing INTERNET as a universal train, INTRANET  CLOUDS as Cabins attached in it. Travelling between CLOUDS can be done by entering and existing world wide web as happening now without any problem.

So if it is found that something needs to be done, it should be in the peripheral networks and not in the Internet. It may be kept in mind this discussion is only about OTTs who are using TSPs network or switch in their service delivery encroaching TSP’s legal business without clear understanding between them. All other Internet services for PSTN/PLMN shall continue in the same way as it is without hindrance.

              Please see a simple schematic on this given below.

Net Neutrality (1)

Question 2: Should the OTT players offering communication services (voice, messaging and video call services) through applications (resident either in the country or outside) be brought under the licensing regime? Please comment with justifications.

Answer 2. Yes. (Conditionally of course.)

ITU-T regulates Telephony, ETSI regulate Mobile telephony and defines rules about access and controls. Having in place such well established system of fully regulated Licensed Telecom service providers handling Voice, messaging and video cal services, it becomes unfair to the principle of level playing that OTT services offering same services over the top OTT mode remain un-regulated and unlicensed and treated differently.

Question is how OTT players using WWW can be brought under licensing regime by some country somewhere unless there is scope to regulate ‘world wide web’?

Earlier Telephone exchanges handled only voice calls, Telegraph managed text messages and TELEX handled text between Tele-printers. Then came dial up access that provided 64kbps pipe for Voice and Data. Digital land line and mobile phone exchanges provide access for Voice, FACSIMILE and Data and access to Internet through ISPs.

With advent of Word wide web, things have changed a lot. The omnipresent and omnipotent world wide web that caters for almost all needs of everyone without barriers, time, place or distance with no bias to any one, has made it look like the old regulatory regimes impediment to progress.

Can we go back and say Telephony systems shall handle only Voice, not Data or transact Data only between the subscribers of PSTN/PLMN? Perhaps not.

Question 3: Is the growth of OTT impacting the traditional revenue stream of TSPs? If so, is the increase in data revenues of the TSPs sufficient to compensate for this impact? Please comment with reasons.  

Answer 3 – Part 1. Obviously, Yes.

Growth of OTT impacts the traditional revenue stream of TSPs.

It is a natural consequence of technology advancement.

Reasons: No one can stop advancement of technology and changes that happen too quickly now.  It is a fact that advancement in technology and convergence of Voice and Data had adverse impact on Telecom business.  This major shift of Voice based usage to  other high speed Data and multi-media services over Internet took the business away from Telecom Service providers to external digital, multimedia and various mobile managed e-commerce  service providers and along with it went out a major chunk of its revenue.

Please see my blogs: ‘Impact of transition from Voice to Data & Multimedia. and It is suicidal for Telcos to allow banking industry hijack pay by phone VAS.

Answer 3. Part 2. Does the increase in data revenues of the TSPs sufficient to compensate for this impact? 

Depends on what the Telcos and OTT combined business models are.

Reasons. OTTs by nature are using TSPs overall infrastructure network and customer base in carrying out their business. Otherwise, it will not come under OTT category.

Here comes the need to look at the term “Net neutrality” in a different perspective.

From the point of view of TSPs, can Net neutrality shall also mean: Method of call charging of Telephony related services shall be NEUTRAL to the type of system that handles it. It means, be it that the service is rendered over Land line systems, Mobile Phone systems or IP based systems which include Internet & OTT players; same method of charging shall apply and of course, leaving the competition in the market place to decide it.

Such an ideology of with understanding of all stakeholders involved can turn Net neutrality as an advantage to Telecom Service Providers.

Please see my paper: Net Neutrality without hurting and safeguarding End users

Average holding time of IP related Telephony calls over circuit switched paths with in the telecom system being about 6 times that of voice calls; charging and billing of such calls based on the call duration according to various tariff package can generate enough revenue of the TSPs to compensate for the impact of OTTs poaching telephony related services from TSPs.

In order to realize this, the basic need is to make OTT players as licensed service providers. Like ISPs, all OTTs shall be subscribers of one or many Licensed Telecom Service providers and access to OTT players shall not be on toll free basis.

In addition to the above, by making OTTs licensed and subscribers of TSP’s a revenue sharing model can be established between the OTTs and TSPs using ‘payment gateways’  to apportion and share revenue between various stake holders that can further enhance revenue of TPSs thus converting the set back of #Network neutrality as an advantage to TSPs.

Question 4: Should the OTT players pay for use of the TSPs network over and above data charges paid by consumers? If yes, what pricing options can be adopted? Could such options include prices based on bandwidth consumption? Can prices be used as a means of product/service differentiation? Please comment with justifications.  

Answer 4: As already answered in Answer to Questions 1 & 3.

As average holding time of Data calls is about 12 minutes, charging by duration of calls can generate enough revenue. Tariff can be kept low and without looking into data volume so as not to burden the consumers. Additional revenue can be earned from connectivity charges and revenue share with OTT players.  

Question 5: Do you agree that imbalances exist in the regulatory environment in the operation of OTT players? If so, what shall be the framework to address these issues? How can the prevailing laws and regulations be applied to OTT players (who operate in the virtual world) and compliance enforced? What could be the impact on the economy? Please comment with justifications.  

Answer: 5. As already answered to Question 3. 

Question 6: How should the security concerns be addressed with regard to OTT players providing communication services? What security conditions such as maintaining data records, logs etc. need to be mandated for such OTT players? And, how can compliance with these conditions be ensured if the applications of such OTT players reside outside the country? Please comment with justifications.

 Answer 6:

6/1: Security is a major concern. This can be fully addressed only when India has its own INDIA-CLOUD below World Wide Web for insulating the country as I have written in my blog: Exclusive Govt. owned GSM Systems & Networks for Administration and Crisis / Disaster management.

Moreover, making OTTs as licensed players and making it legal subscribers of one or of many TSPs, some of the security concerns can be addressed.

Ans. 6/2. As mentioned under Answer 3; OTTs are made licensed and legal subscriber of a TSP call data records for all data calls on circuit switched paths shall be available.

Ans. 6/3. There shall be a universal agreement that every OTT player that wants to handle Telephony related service like switching voice calls in VOIP mode shall be licensed and become subscriber of a PSTN/PLMN within the country or anywhere.  There shall be methods to refuse access unlicensed OTT players through TSPs in TSPs and associated ISPs. How to ensure this is the question?

Charging, billing and apportioning of revenue share shall be done by associated payment gateways as being done now in Roaming houses as the calls handled via ISPs which are licensed subscribers of TSP involved. (See the schematic in Answer 1)

Question 7: How should the OTT players offering app services ensure security, safety and privacy of the consumer? How should they ensure protection of consumer interest? Please comment with justifications.  

Answer 7: Same as given in the answer to questions 3 and 6 above.  

Question 8: In what manner can the proposals for a regulatory framework for OTTs in India draw from those of ETNO, referred to in para 4.23 or the best practices summarized in para 4.29?

And, what practices should be proscribed by regulatory fiat? Please comment with justifications.

Answer: 8. India will have a billion phones soon. E-Commerce, Pay by phone services are growing enormously and Direct beneficiary transfers to Mobiles etc in the anvil. So India should take a lead in these things. Please see what I have been propagating over a decade for an ‘Exclusively banked Universal Money Management by Phones system’ in the link

My point is, instead looking into other countries; India should come up with ideas that are suitable for us.   As may be seen in my papers mentioned above, India is in urgent need of an India cloud with required number of GPS satellites systems and networked across the country. For security reasons it shall be fully firewalled and the server part of all important systems shall be under this cloud so that these can be properly regulated.  

Question 9: What are your views on net-neutrality in the Indian context? How should the various principles discussed in para 5.47 be dealt with? Please comment with justifications.

Answer 9: As mentioned earlier, Net-neutrality in Indian context shall mean that as far the end users as consumers of the service, all forms of technology advantages shall be made accessible and at affordable cost to them while safe guarding the business interest of the Telcos and ISPs involved. It is therefore, there is some justification of considering that net-neutrality shall mean providing services rendered through every network; Land lines, Mobile Phones, Computers and user end devices on identical mode of charging on ‘same service – same charge’ basis making it network neutral.

Nevertheless, there shall be different tariff plans based on the level of service and then left to the market place so that competition based on quality and efficiency will decide the pricing.  If this can achieved it will be a win-win solution for the service providers as well as for the consumers.

Question 10: What forms of discrimination or traffic management practices are reasonable and consistent with a pragmatic approach? 

What should or can be permitted? Please comment with justifications. 

Answer 10: Partly answered under previous questions. In addition to that please see my blog: Net Neutrality without hurting and safeguarding End users

The traffic management shall be based on the fundamentals of Telephony lest the entire system can fail. With average holding time of  data calls being 12 minutes, it is only any body’s guess if huge volume of traffic 0.2 TU per line on toll free access lines can create in telecom system and network. The switch will fail due to overloaded no time and make every other system in the network to collapse due to overcrowding junction routs.

The real solution is in Telcos switching over to IP based switching making TSP & ISP rolled into one; which is going to take time.

The pragmatic way is as suggested by me earlier to convert the net neutrality issue an advantage to TSPs by deriving adequate revenue to prevent them collapse and go out of business. 

Question 11: Should the TSPs be mandated to publish various traffic management techniques used for different OTT applications? Is this a sufficient condition to ensure transparency and a fair regulatory regime?

Answer 11: For this it is necessary to define these techniques. It was the practice with DOT to make the TRC issue specifications and standards for everything related to Telecom. Every TSPs are obliged to follow these specifications, rules regulations and conditions. There is an Acceptance Testing department under Technical & Development Circle to ensure its compliance. (I worked in that unit for over 20 years.)

Question is how it can be applied to OTT players that are not licensed? Please see more on this in my noting under Question 20. 

Question 12: How should the conducive and balanced environment be created such that TSPs are able to invest in network infrastructure and CAPs are able to innovate and grow? Who should bear the network upgradation costs? Please comment with justifications?  

Answer 12. Please see my noting under question 20.  

Question 13: Should TSPs be allowed to implement non-price based discrimination of services? If so, under what circumstances are such practices acceptable? What restrictions, if any, need to be placed so that such measures are not abused? What measures should be adopted to ensure transparency to consumers? Please comment with justifications.  

Answer 13: Please see my noting under Question. 20.

Question 14: Is there a justification for allowing differential pricing for data access and OTT communication services? If so, what changes need to be brought about in the present tariff and regulatory framework for telecommunication services in the country? Please comment with justifications. 

Answer 14.

One of the advantages consumers find in OTT communication service is availability of features by which they can communicate each other at no cost or negligible cost.

Ideally net neutrality shall mean same tariff for same service irrespective of which network the consumer use for getting the service. However, it need to be discriminated based on availability, speed of access, quality of service, and flexibility users comfort such universal accessibility over mobile devices. Finally, competition in the market place shall decide pricing on each of the above.

As mentioned in earlier answers, there can be generally three methods of charging the OTT communication.

  1. Based quantum of data transacted over OTT
  2. A single unit access charge after an initial charge free duration (As success or failure of the call cannot ascertain in data calls) and Unit charges for the remaining duration of the call.
  3. Revenue is realized by revenue share from OTT player and no charge from the TSP side in the principle of ‘’Called party pays basis” treating OTT player as the Called party. If none of the above is practical, TSPs may think of increasing monthly rent of the users who all need data access to OTT players.

In order to keep cost to user low, the tariff shall be such that it do not cause heavy burden on the consumers. As considerable percent of users being from the lower social & economic strata, who may not need data access, there can be given discriminative service without Data at cheaper monthly rent as already being done. There can be lower rental for rural and village customers both on rental as well as data service.

Please see my notes in answer to question 20. 

Question 15: Should OTT communication service players be treated as Bulk User of Telecom Services (BuTS)? How should the framework be structured to prevent any discrimination and protect stakeholder interest? Please comment with justification.  

Answer 15: Please read my blog: Segregation of Service Provision from Network operation / Universal Numbering Plan.  

Question 16: What framework should be adopted to encourage India specific OTT apps? Please comment with justifications. 

Please see noting in Answer to Question 20 wherein I have explained about India Cloud and exclusive IP based OTT server.

Question 17: If the OTT communication service players are to be licensed, should they be categorized as ASP or CSP? If so, what should be the framework? Please comment with justifications.

 Answer 17. Yes. Otherwise, TSPs have no contractual obligation to provide access to and from OTTs through their network or direct to their switches. It can be contested in Courts.

 Question 18: Is there a need to regulate subscription charges for OTT communication services? Please comment with justifications.  

Answer 18. If direct access is given to OTT servers through circuit switched paths it shall treated and charged as PABX lines. 

Question 19: What steps should be taken by the Government for regulation of non-communication OTT players? Please comment with justifications.  

Answer 19. The question is why non-communication players are OTTs and whether they use TSPs network and switching system to get access in any process of delivery of service. The only way to discriminate it is by filtering it at ISP stage in case of Internet access from PLMN/PSTN. All Internet services to non-communication OTT players shall continue. That is what ISPs and Internet is meant to for.  

Question 20: Are there any other issues that have a bearing on the subject discussed?  

Please see my blogs below: With IP based switching and Networks going to be the future, the Telecom systems as of now will not last long.  Government and regulators should have kept in mind this while revising the licenses and selling out spectrum at high cost to Telecom Service providers.

Please see my blog: Who need Spectrum; How much, Where and When? 

  1. Indian air space is allowed to be crowded by various international players like Skype, Viber, WhatsApp, Chat On, Snapchat, Instagram, Kik, Google Talk, Hike, Line, WeChat, Tango, ecommerce sites (Amazon, Flipkart etc.),Ola, Facebook messenger, Black Berry Messenger, iMessage, online video games and movies (Netflix, Pandora) as mentioned in Para 2. of the TRAI’s CP on this. One of them yet have own spectrum in this country. They manage riding over TSPs systems, network and spectrum.

It is also possible that they sneak into Mobile networks using methods such as emergency access to any available network without SIM that is mandatory in Mobile telephony.  It is evident from the fact that we able to access some of these services from mobiles without SIM.

As we have seen it is not possible to reign in Internet and its openness. A long term solution is in all TSPs switching over to IP based systems and networks. Eventually it will happen but it is going to take time. Even with that consumer access to mobile systems will be over legacy and new generation networks using appropriate and adequate spectrum. Whether TSPs will be able to hold on to their business till then is to be seen.

  1. Another solution to reduce burden on TSPs by segregating Network operation from Service provision as explained in my blog in the link With most of even voice calls, messaging and data and multi-media related services are being handled external to local system the Traffic pattern is becoming totally different. Traffic is on the increase due to low user charger and higher penetration to other areas of Telephony and non-telephony related VAS needing more systems of higher capacities and networks. Technology is changing fast and life cycle of systems, H/W as well as S/W are becoming less and less. TSPs are already finding it difficult to balance between CAPEX + OPEX and Earnings.

The idea is to have few major network operators who set up and run the systems and networks on Pan India basis which are shared by various service providers on revenue share basis. This can remove the burden of huge invest cost from the TSPs. This is a far cry.

  1. Another solution to over come the current problem of OTTs is as I mentioned in my paper ‘Net Neutrality without hurting TSPs and safeguarding interest of Consumers’

The idea is to bring in some form of regulatory measure by bringing the OTTs under it. This cannot be done as far the operations remain fully through internet in the world wide web.

Please see the schematic below.


4. The way out is to create an India Cloud and provide and bring in OTTs operating in India and abroad through it. Consumers interact with OTTs and vice versa via the Internet cloud.

Each OTT shall have specific IP address for its URL.

There shall be payment gateways under the India Cloud that will enable TSPs to derive share of revenue for the traffic originated from and terminated on it. For direct access between TSPs and OTTs, there shall be enough circuit switched connectivity between TSPs and OTTs according to traffic needs.

In case of entering TSPs via its spectrum, it need be allowed in the basis of treating OTTs as a PABX.

In case of accessing OTTs via ISPs, it shall be through India Cloud with specific IP URL address.

There shall be Payment gateways in set up and serviced the model of Roaming houses for apportioning and sharing of revenue between various stake holders. All call records and statistics shall be available in these payment gateways.

Separate switching system for catering to OTT players.

As there is enough scope of business that can be done over net, it need to be examined whether there can be a separate switching system can be set up under India cloud that can be legally accessed by licensed OTT players in India via any TSPs network. It is possible by opening out regional roaming feature and option to login to any available network. Access to the system from consumer will be identical to current mobile access to any other TSP system.

Such common switching system will function as switch + ISP + Payment gateway.

Conclusion. Internet is great. Everyone including me would like to continue it the same way. However, as Telecom professional with over 60 years of outstanding experience in the field I consider it my duty to point out the above discriminations and disparities related to the topic under discussion. I understand it is a very complex issue and it will open out lot of unsolvable problems due to the nature of Internet being what it is, good, bad & ugly.

The most scary issue is the security aspect. World over everything is slowly becoming dependant on digitals systems and digital communication of sorts. It is powerful and provides comfort to human kind in many forms and also can become equally disastrous. As mentioned in the first part, controlling Internet is impossible. What I have been propagating for many years is that India should have its own umbrella network set up by GPS linked with exclusive Govt. owned GSM and systems country wide.  Good to know that ISRO is already on about it. Hope, the commotion about Net neutrality will get settled and India will march forward as a fore runner in the field of Information Communication Technology.  

Yours faithfully.

Abraham Paul. P.

69. Kakkanadu Lane, Kesavadasapuram,

Pattom P.O. Thiruvananthapuram. Kerala. 695004.

Ph: +91 471 2446644, +91 9446322644.

Currently in Dubai. Ph. +971563244867 & +971 44425577




Posted in Uncategorized | Leave a comment

Net Neutrality without hurting Telcos and End users.

Net Neutrality without hurting Telcos and End users.

Author. P. Abraham Paul. 13 April 2015

Introduction: No one can stop advancement of Technology; and then Technology changes too quickly too.  However, most Technology advancements disrupt the paths it go through and grow. Same is truer in Information Communication Technology of sorts. Advancement in ICT brought in convergence of Systems & Networks, mode connectivity, the end links and User end devices. INTERNET is the best thing happened in Communication technology in past few decades.

From the technology and business perspective, the differentiation between Mobile Networks and Fixed phone network is slowly vanishing making Voice, Data / Multimedia and  INTERNET  characteristics in Mobile systems  similar to these in Fixed Networks.  Differences are the end link, type of access, bandwidth limitations and user devices. Thus advance in Technology converged various forms of ICT based transactions that helped to provide Universal mode of Telecommunication offering Net Neutrality for all. Strangling Net neutrality will be a horrendous mistake. However, it is suicidal for Telcos to allow Over the top (OTT) service providers poach all sorts of Telephony related products and services and its revenue along with it.

From DOT days Government neglected Telecom and it is the Public Telecom Service Providers by licensed Private PLMN operators made the Telecom in India what it is now. But then it is to be seen that how long Telecom Technology, systems, network and transport continues in the present form as IP based ICT is the order of the future. Access to ISPs and to INTERNET is no more monopoly of Telcos. ISP access is now available through Cable TV network any many other sources. Devices that can penetrate any TSPs network and to ISPs without SIMs are already there. Future systems and networks will be handling  Telecom, TV, Internet all rolled in one.

1. Basic fundamentals of Public Switched Telephone Networks.

At the outset, while analysing the part OTT players  in the area of   conventional Telecommunication, there seems to be an urgent need to revisit the basic fundamentals of Telephony and also about the need to keep these principles in tact. By definition, Public Switched Telephone systems, both PSTN and PLMN are obliged to give access and connectivity to and between subscribers of own and of other PLMNs & PSTNs anywhere across the word.  All other Private telephone systems like PABXs etc., have to be basically subscribers of one or other PSTN or PLMN and function within stipulated rules of their connectivity and operational limits. (Any PABX or any other Private communication system or else that do not have enough junction lines according to expected busy hour traffic over the junction can clog the Public telecom system it is connected to.)  It means PSTN/PLMN are not obliged to provide access and connectivity to any unlicensed communication players of any sort that are not legally or rightfully the subscribers of a PSTN or PLMN. Same is true with ISPs.

Hence one of the issues is  whether the OTT players are legally subscribers of a PSTN/PLMN or not? If yes, the issue is reduced to method of connectivity and commercial understanding between the TSPs and OTT players. Of course, in the case of accessing OTTs via Internet, how this can be ensured is a question to ponder. 

1.1. Internet also need to grow continuously to meet the needs of the day.

Now Internet is being used to access and acquire every form of information & knowledge, personal and business communication, applications for services, e-commerce and mobile banking needs by individuals as well as small, medium and large enterprises, organisations and various arms of Governments across the world, which is growing exponentially every day.

Unless there are enough access pipes and bandwidths are made available between the end users and the millions of Servers in the mighty net, entire system will become slower and slower. Those who often complain of delays in getting connected and slow through put need to know that Internet work over a mesh of shared network of pure chance routing and through put depends on availability of access paths with enough bandwidth in these pure chance alternate paths in every access points from the origination up to the destination. Any bottle neck in between anywhere will make the transport slow.  A user contracted for 1 mbps data may not get same through put when connected to a user having only 256 kbps connectivity. This is more true in case of real time applications and products.

2. Impact of transition from basic Voice and Data to Multimedia and IP based products.

Please see what I wrote many years back: Impact of transition from Voice to Data & Multimedia.  Major shift of Voice based and other high speed Data and multi-media services over to INTERNET based usage will inevitably take away the business from Telecom Service providers to external digital, multimedia and various e-commerce and mobile banking service providers, and along with it goes out a major chunk of their revenue.

2.1.  A major chunk of CAPEX of Telcos Systems and Network and the revenue earned are related to basic Voice and Data Services.  Same is true with Non-telephony related Value added services.   In a given Eco system, Telephony related usage and revenue remain more or less constant. Non-telephony related value added products and services such as pay by phone and many other e-commerce services offer an excellent way to enhance Telephone usage and thereby enhance revenue.

However, providing uncontrolled free access to external systems on circuit switched paths for long duration of real time applications, will cause congestion due to heavy traffic that will not only make the telecom system to fail due to overload but also make other systems in the network to collapse due to congestion  in the  junction circuits. It will also clog the Internet.

2.2. With the advent of 3G / 4G and new generation digital services, the transition from Voice call business to Direct and IP based Data and Multimedia already moved out substantial amount of business revenue from Telecom Industry to external service providers such as banks, content providers, and other multimedia companies. Allowing external service providers to use the access through Telecom network and systems and Telecom SPs Customer base that are set up and run incurring huge amount of  CAPEX / OPEX and cost of License and Spectrum and are compelled to meet the need to expand it further in order to cater for these ever growing non-telephony service related services. That is why I have been pointing out the folly of Government policies of Telecom such as  delinking Spectrum from License and selling it by auction at high cost.  See my post “Who need Spectrum; How much, Where and When? 

2.3.  Revenue sharing is the way out. Telecom Industry will find it difficult to survive unless they ensure adequate share of revenue from these external Service providers and industries that by default use their customer base, systems and network. Telecom Industry,  therefore, has all the right to get adequate share of revenue from both Telephony related and non-telephony related  services and it is suicidal for them to remain as mere onlookers while other industries hijack their revenue potentials.

2.4. Whether Net neutrality shall be applicable both ways?

Many are of the opinion that tariffing should left to competition and the market place to decide. But how it can happen for a zero-valued product or service that are provided by some OTT players. Here is the importance to have relook at the term “Net Neutrality”

In normal telephony environment, there is call charging based local call, national call or international calls depends on the destination and time of the day and day of the year. Due to various reasons there can be different tariff for calls over different mode of connectivity, fixed mobile etc. Of course, with IP technology, it can become cheaper, still unfair to ask for it at zero cost as the calls involve systems and networks of different stake holders.

Or is it better to make tariff also Net Neutral and leave it to the competition in the market place to decide it?

Important aspect to be kept in mind is that means and ways of revenue sharing shall be such that it will not unduly increase cost of service and burden end users.  Government and Telcos should know that success of Telecom Industry as in every other Industry thrives on its business volume and the volume comes from its availability and affordability to general mass of country’s population. Cost of Super hyped handsets and other user end devises etc., and passing on the effect of high cost on License and Spectrum, to users will increase cost of usage and will push the common people out of the system and the Industry goes down the drain.   Please see my blog: Make Telecom Systems, network, Phones, product and services for the common man.

3. Compromise solution to upkeep Telcos Interest with Net neutrality.

Openness is the prime strength of INTERNET. Everyone agree that strangling #NetNeutrality will be a horrendous mistake. Therefore, is the need to ensure Net neutrality according to principles of  telephony without hurting Telcos while safe guarding end user’s interest keeping the basic fundamental of Telephony in tact.  

As mentioned above Telcos are slowly losing their monoploy on Telecom service delivery.  Increasing data usage charges as being proposed by COAI is not a wise solution.

Every business volume of user brings in growth and volume can happen when the products and services are accessible and affordable to general mass. Increase of data charges will make it un affordable to a large portion of subscribers and many would fall off. On the other side many more who currently use the communication service through TSP channel may will mover to OTP based services causing further  reduction in revenue.   

To get over the current stalemate what is needed is a compromise solution to turn OTT service as an advantage and continue to ensure Net neutrality without hurting Telcos and of course, also safe guarding interest of the end users.

The end users are real beneficiaries of Net Neutrality as far as Telcos tow the line using compromise solutions and Government wake up and do away the policies of milking Telcos with heavy cost on License and Spectrum.  Please see my blog: The never ending Telecom muddle in India.

3.1. Such being the situation Government had pushed the Telecom business into; they would not dare to indulge in higher and higher investment needed for the high-tech data networks and access pipes to support other’s e-business needs with no means of adequate return on their investment.

The Network Operators /ISPs therefore, need to find strategies and methods to get adequate share of the revenue collected by e-business units that use their customer base, their network and resources. Many are of the opinion that market competition will take care of the issue; but how market competition can happen in zero cost service?

3.2. With further advance in technology with fully IP based systems replacing current mode of telephone exchanges it is possible that TSPs and ISPs will be rolled into one. This can happen only if the present form of licensing based on areas co-terminus to  Telecom Circles  replaced with giving license on Pan India basis.

Need of Payment Gateways in PDN for apportioning and sharing of revenue. 

It is to be reconciled that the e-business and e-services related to 2.5G, 3G /4G and Data services over INTERNET  involve ‘High Volume’ of  ‘Low Value’ payments and these cannot be done by direct payments or through banks, regular credit card companies etc. Also these payments can neither be handled by the Network operators/ISPs nor by the Service provider/e-business units as the value of each transaction is known only to the e-Business/Service provider who finally sells or provide the service.

This is the most critical issue and the high tech Telecom and IP related e-Business cannot take off and the Network Operators/ISPs cannot hold on to  sustainable business plans until it is addressed and resolved.

Micro-payment Gateways in PDN is one such idea to get back part of the revenue generated from e-business based on data services.  This need coordinated efforts by all stakeholders and the regulators.

4.1. Concept of Payment Brokers middle way systems.

To be in line with technology advancements, the network operators have no choice but to induct the new technology systems related to telephony and non-telephony value added systems in their networks and find means and ways to ensure sensibly viable business propositions. As mentioned earlier, the data related services gaining predominance, and the revenue potential moves from Network Operators/ISPs to Service Providers and e-Business units, Network operators/ISPs have to look for methods to grab their share of revenue generated in the PDN to survive.  Here lies the emphasis of the Payment Broker systems, which can manage the accounting of payments, apportioning of it and sharing the revenue generated between the stakeholders.

4.2. Security is also a major concern. Volumes can be written on the hazards a fully open system can cause to various areas of security.  One method to ensure security is to provide a two level access to Internet.

This can be done by having  Exclusive Govt. owned GSM Systems & Networks for administration and Crisis /Disaster management. Please see my blog in the link:

Another way is to have an INTRANET layer as INDIA_CLOUD below World Wide Web for all such purposes.

Please see schematic by clicking the caption below:

Net Neutrality

Net Neutrality

4.3. INDIA CLOUD and Cloud computing.

Obviously, such payment broker system mentioned above cannot be managed by individual Network operators/ISPs as the Service Providers and e-business units are common platforms shared by customers of many different Networks/ ISPs. For obvious reasons, such system shall reside in exclusive India- Cloud below the World Wide Web (WWW) and managed by Cloud Computing.

India-Cloud as proposed, need to be fully firewalled to ward off unlicensed service providers poaching products and services from existing licensed service providers or else, using their technology systems, Network and Spectrum.

This can be realized by routing out all non telephony related data access to Internet direct through the ISPs and all Telephony related service requests (such as IP based call connecting) routed over circuit switched toll free access to licenced OTT players   associating the payment Gateways for apportioning and sharing of revenue between the Telcos and OTTs. As all non-telephony related services will be routed out to Internet as happens now there shall be no complaints from the end users of Internet.


Typical example may be seen in what I had been propagating for long:  “Money through Mobile” (MTM), a system that supports all sorts of money transactions and e-commerce by phone users transparent to Banks and banking systems setup and owned by a consortium of service providers is an option for telecom service providers to look into. Please see article on Universal Money Management by phone.

5. Coming back to the Net neutrality issue, please see my reply to TRAIs consultancy paper on the Pandora’s Box on Regulatory Framework for Over-the-top (OTT) with some short term work around ideas till entire systems comprise of IP based switching and transport, end to end.

6. Response to the questions in TRAI consultancy paper on Regulatory Framework for Over-the-top (OTT) services  is in the link

Or click on the caption to open the PDF file.  Reply to CP on TRAI_OTT (Q&A) (5)

Knowing fully well that the ideas and opinions in my answers   being against general view of many millions on this; it is most likely to end up a wasted effort by TRAI, I did not spent more time on it to fully refine it.  Of course, like everyone,  I also would like to have everything free, but that doesn’t change facts. Fact is that I had tested out most of these OTT applications a decade back (Money through Mobile mTm for instance) but did not to push it forward exactly for these reasons.

As mentioned earlier, the final solution is in changing over to IP based systems, network and transport, the earlier it happens the better for all, the TSPs as well as for the consumers.

7. Counter comments on TRAI CP on Regulatory Framework for Over-the-top (OTT) services.


Abraham Paul. P.

Posted in IT based services, Life science technologies, Social and Community affairs, Telecom Technology | Leave a comment

2G scam – ‘Much-a-do-about-nothing’.

Originally posted on papaulsblog:

2G scam  – ‘Much-a-do-about-nothing’.

Introduction: Having been actively associated in the implementation of one of the early
GSM systems in India in 1995, I choose to remain stead fast in my opinion I had on this
subject from the inception of GSM for the following reasons:-

1. Ownership of Spectrum shall remain with government.  Wireless Spectrum is a nonrenewable national resource and as such need to be handled scrupulously and judiciously by Government and Regulatory authorities. The ownership of the spectrum shall remain with Government by allowing only its ‘right of use’ so that spectrum can be withdrawn and reallocated where it is no more required or not being put to intended use by any Agency or Operator.

2. Need to move with fast changing Technology. Technology is changing very fast. What is best today would become obsolete tomorrow. Different technologies would need different frequency layer, band…

View original 910 more words

Posted in Uncategorized | Leave a comment