Billionaire Mukesh Ambani-led Reliance Jio has told telecom regulator TRAI that its Happy New Year Offer, which provides free voice and data services to customers, does not violate any of the existing norms that requires promotional offers to be limited to 90 days.

Replying to clarification sought by Telecom Regulatory Authority of India (TRAI) on it extending the free call and data offer till March 31 after the promotional 90-day period expired on December 4, Reliance Jio sent a detailed note explaining how its Happy New Year Offer was different from the inaugural offer and does not qualify to be termed as predatory.

Sources with direct knowledge of the development said Reliance Jio explained in detail how the new Happy New Year Offer cannot be termed as extension of the promotional offer as it was different from the inaugural Welcome Offer launched in early September.

The response was to TRAI's letter dated December 20, in which the regulator asked Jio why its Happy New Year Offer should not be seen as "violation" of regulatory guidelines, and also why the offer of free data under the promotional scheme should not be treated as "predatory."

Jio has been maintaining that the latest Happy New Year offer is substantiatively different from the Jio Welcome Offer (that commenced on September 5) as 4GB of free data per day was being provided under the initial offer, while the same was capped at 1GB (under Fair Usage Policy) in the new offer.

Jio is believed to have also emphasised that tariff plans have multiple components and if even a single component is altered, it cannot be construed as the same offer or its extension.

Also, they contend, that in the Welcome Offer there was no option of renewal or payment after the 4GB limit was exhausted, but in the new Happy New Year offer, one can recharge both data and the promised speed.

In terms of market dominance, Reliance Jio is six percent of the installations in the country, whereas the Competition Commission of India (CCI) norms specify 30 percent threshold to trigger the misuse of market dominance' clause.