The telecom operator has sought the extension under clause 4.1 of the licence agreement under which the government can extend the period of licence by 10 years at one time if the request is made the operator during the 19th year of the licence period.
In separate letters seeking licence extension for three circles to Telecom Secretary R Chandrashekhar, Vodafone said, "the 19th year of licence has commenced on November 29, 2012 for Mumbai circle and Novermber 30, 2012 for Delhi and Kolkata circles we request you to extend the period of our licence on terms to be mutually agreed."
The clause 4.1 says "the licensor may extend, if deemed expedient, the period of licencee by 10 years at one time, upon request of the licencee, if made during 19th year of the licence period on terms mutually agreed."
"The decision of the licensor shall be final in regard to the grant of extension."
The government is working on conducting auction of spectrum in 900 MHz band for Delhi, Mumbai and Kolkata circles during this financial year, but it is yet to decide on the final date for auction.
The existing GSM operators will be allowed to retain 2.5 Mhz in each circle in the same band even after expiry of their licences after a paying a market-determined price.
Vodafone has around 24 MHz spectrum in 900 MHz band in these three circles.
"We respectfully submit that in our view, extension of licence period is continuation of the already set up network, including continuation of existing spectrum, which is intrinsic to our licence and is being used for providing service to the customers under the licence," Vodafone said.
It added that for the purposes of licence extension, "there can be no change in the fundamental structure of the license."