"The DoT appears to have taken the decision to impose penalty on us (Reliance Infocomm) with a predetermined mind without taking into consideration the provisions of the licence," the company said in a 10-page reply to DoT.
DoT imposed a penalty of Rs 150 crore (Rs 1.5 billion) on Reliance for violating the licence conditions by routing incoming international calls as local ones, which led to evasion of Access Deficit Charge, a levy paid by private operators to BSNL for rural telecom operations.
In its reply to DoT, Reliance said "Despite repeated requests, DoT has so far not provided particulars of the alleged violations of the licence conditions with any specificity.
"In these circumstances, we submit that the purported order levying penalty is clearly unsustainable, illegal and without any basis whatsoever," the company said.
The two telecom PSUs, BSNL and MTNL, have raised a demand of over Rs 550 crore (Rs 5.5 billion) towards ADC due on Reliance, of which the company has paid Rs 182.7 crore (Rs 1.82 billion) to BSNL on the instruction of the Supreme Court.