Monday, 18 February 2019

CORPORATE UPDATES 18.02.2019





TIME TAKEN TO APPOINT RESOLUTION PROFESSIONAL TO BE EXCLUDED FROM CIRP: NCLT

Now time taken from the admission of a case by the NCLT till the appointment of the Resolution Professional (RP), will also be excluded from the IBC timelines, the Mumbai Bench has held. In the case of Say India Jeweller Pvt. Ltd., the application was admitted on August 1, 2017. However, the appointment of RP was deferred to the Insolvency and Bankruptcy Board of India. The RP was appointed only 62 days after the admission order was passed on October 3, 2017. As a result, all actions that are required to be taken during the Corporate Insolvency Resolution Process (CIRP) were delayed. The 270th day from admission of the case was April 28, 2018. By this time, the corporate debtor received only one resolution plan, from the suspended directors, which was rejected by the creditors committee. In view of this, a liquidation application was moved at the NCLT on May 4, 2018. However, the order goes on to record the dates in a manner, treating the 62 day period as a buffer period which the corporate debtor earned for not having an appointed RP. From the order, it is unclear who was in charge of the corporate debtor during the 62 day period when CIRP had commenced, and no RP was appointed. Meanwhile, the suspended directors of the corporate debtor whose resolution plan was rejected filed an application with the NCLT for reconsideration of their resolution plan. The NCLT passed an order admitting the the directors application. While doing so, the NCLT noted principles laid down in cases of Bhushan Power and Steel, MBL Infrastructure and Adhunik Alloys & Power Limited. The NCLT further noted principles laid down in the Binani case by the NCLAT, which suggested preference of resolution over liquidation. Based on NCLT order dated December 5, 2018, the RP asked the suspended directors to resubmit resolution plan. After several rounds of negotiation, the plan submitted by the directors was approved by the committee of creditors and presented to the NCLT for approval. The order further lists down the provisions with which the resolution plan was compliant, and the provisions with which the plan wasn’t. To that extent, the NCLT made two suggestions it first modified certain parts of the resolution plan to make it compliant with the Regulations. In the absence of the text of the resolution plan, it is unclear what these modifications are. However, the second part to this is, the deletion of certain portions of the resolution plan. In this regard, the NCLT suggested deletion of portions such as: exemptions from dues under Income Tax Act; tax and stamp duty exemptions; writing off of investigations/ inquiry/ show cause obligations arising out of non-compliance of provisions of laws; extinguishment of rights and entitlements of the Central Government, State Government, any regulatory or local authority or body; extinguishment of rights & entitlements of Govt agencies on account of acquisition.; the resolution applicant will not be liable for Associate Companies. The NCLT further recorded that, It is clarified that only crystallised dues shall stand extinguished on approval of this plan. After having made all suggestions, the NCLT recorded that we are of the considered view that the modified resolution plan may be sent to the Resolution Professional for seeking acceptance from the Resolution Applicant. If the modified resolution plan will not be acceptable to the resolution applicant, liquidation would commence.
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BANKERS SUGGEST MEASURES FOR FAST RESOLUTION OF IBC CASES

To ensure the speedy resolution of cases under the Insolvency and Bankruptcy Code (IBC), bankers have suggested, among others, the introduction of a mechanism to reduce unwanted litigation and strict adherence to the timelines under the code. As per the FICCI-IBA Survey of Bankers (for July-December 2018 period), to reduce unwanted litigation, provisions similar to DRT (Debt Recovery Tribunal) must be introduced, where a percentage of the loan outstanding is insisted upon while filing an appeal. The survey said the time norms under the IBC for admission, appointment of valuer and forensic auditors, as well as for the resolution of the company must be strictly followed. To cater to the rising number of cases under the National Company Law Tribunal (NCLT), there is a need to improve the capacity by increasing staff and establishing more NCLT benches across the States. At present, NCLT has benches in 11 locations across the country. While respondent banks have largely had a positive experience in recoveries since the implementation of IBC, they underscored that the resolution process is being delayed owing to limited infrastructure in NCLT and rising cases of frivolous appeals. The FICCI-IBA survey said banks should be given an option to convert a part of their debt into equity proportionate to amount of haircut (receiving less than what is owed). To improve the efficiency of the resolution process, the government should come out with guidelines for NCLT to take up petitions the survey said. The FICCI-IBA Survey observed that interest from investors and potential buyers is limited only to companies that are operational as on date, and there is limited interest in smaller-sized companies. According to an analysis by ICRA, as on December 31, 2018, 898 CIRPs (corporate insolvency resolution process) were awaiting a resolution against 768 CIRPs as on September 30, 2018. The credit-rating agency assessed that the number of CIRPs outstanding are expected to only increase further at least for the next few quarters until adequate steps are taken to ensure that the CIRP does not significantly exceed the 180/270-day timeline prescribed under the IBC. Up to December 31, 2018, 79 CIRPs yielded a resolution plan, while 302 cases entered liquidation, which is a very high proportion. According to Abhishek Dafria, almost 68 per cent of the NCLT cases exceeded the 270-day timeline allowed under the IBC. Furthermore, CIRPs that concluded in the quarter ending December 2018 took an average duration of 354 days, compared to 340 days taken for CIRPs concluded in the quarter ending September 2018. The CIRPs for the pending seven corporate debtors from the RBI’s initial set of 12 large defaulter cases identified in June 2017 that are still ongoing have seen the average duration of the process now exceed 500 days which does not help the investor sentiment, said Dafria.
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MAHARASHTRA LOOKS INTO TRANSFER OF SUMS BY BUREAUCRAT TO LLPS

The Maharashtra government is looking into several transactions by two limited liability partnerships incorporated by top bureaucrat K.P. Bakshi, whose name has cropped up in a report by the Central Vigilance Commission (CVC) on suspicious transactions worth over 2.5 crore during and after demonetisation in 2016. Bakshi, who was the Additional Chief Secretary (ACS) when some of the transactions were carried out, had transferred large sums into Oracon LLP and Crimson Park LLP, in which his sons Shivesh and Anjan, and wife Neelima Bakshi, are partners. In his explanation to the government on January 31, 2019, Mr. Bakshi had informed the government of the existence of only one (Oracon) of the two firms, while keeping the incorporation of the other off the declaration note. While Oracon was incorporated on May 28, 2016 with Shivesh and Neelima on board as designated partners, Crimson Park LLP was incorporated on January 28, 2014 with an ‘obligation of contribution’ to the tune of 1,00,000, and Bakshi Anjan and Bakshi Neelima as designated partners. The registered address of Crimson is shown in the records of the Ministry of Corporate Affairs (MCA) to be 1404, Greenwood Hiranandani Estate, Ghodbunder Road, Thane. In his explanation forwarded to the government, Mr. Bakshi said the records of the Oracon LLP have been revealed to the government, and the said company had applied for the opening of a Dmat account to buy tax-free infrastructure bonds for saving income tax. Since the process of the opening of the account was getting unduly delayed my wife and son requested me to buy the above tax-free infrastructure bonds through my Dmat account, for which the LLP Co transferred the required amount to my bank account. Once the account was opened, the ITF bonds were transferred by me to the company’s newly opened Dmat account, he said in his letter, responding to letter of Chief Secretary D.K. Jain dated December 18, 2018. The response talks of cheque or NEFT transactions but does not mention Crimson Park LLP at all.
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MALVINDER FILES COMPLAINT AGAINST SHIVINDER, SPIRITUAL LEADER; ALLEGES CHEATING, SIPHONING OF FUNDS

Former Fortis Healthcare promoter Malvinder Singh has filed a criminal complaint against his brother Shivinder Singh, spiritual head of the Radha Soami Satsang Gurinder Singh Dhillon and others alleging financial fraud and threats to kill him. Malvinder Singh, who filed the complaint before the Economic Offences Wing here, alleged that Gurinder Singh Dhillon or Baba through his lawyer Ferida Chopra has threatened to kill him. Gurinder Singh Dhillon has threatened the complainant through his lawyer Ferida Chopra that if he did not agree to the demands of Gurinder Singh Dhillon, he would be eliminated by persons from the Radha Soami Satsang, the complaint said. The complainant also charged of receiving veiled innundoes and threats from various other satsangis about listening to the demands of Dhilion. He alleged that Shivinder Mohan Singh and Sunil Godhwani in conspiracy with other co-accused have carried out and orchestrated serious financial fraud in two other companies - Religare Enterprises Ltd and Religare Finvest Ltd, which has caused substantial financial losses. He has also claimed that the accused misrepresented the financial condition of the companies and conspired with Dhillon family to inflict wrongful loss to the complainant. The accused persons have conspired criminal conspiracy and also misappropriated the property of RHC Holding Pvt Ltd.
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UFO MOVIEZ, QUBE CINEMA MERGER HITS NCLT ROADBLOCK

Mumbai-based digital cinema distribution company UFO Moviez’ planned merger with Chennai-based Qube Cinemas Technologies has hit a major roadblock in the National Company Law Tribunal (NCLT). Keeping in mind shareholders’ interest, NCLT has refused to give its nod to the proposed scheme of arrangement and amalgamation between the two companies. The whole scheme appears to be framed also for the purpose of evading the duly payable stamp-duty and to deny the shareholders at various levels their legitimate right of a proper valuation of the intrinsic share value along with goodwill, V Nallasenapathy and Bhaskara Pantula Mohan, member judges of NCLT’s Mumbai chapter said in the order released last week. However, setting an example of protecting shareholders’ interest, NCLT has rebuked UFO Moviez India dismissing its framed attempt for amalgamation as the dedicated court prioritised shareholders’ worth. Further there is something illegal definitely on the part of the Petitioners to camouflage the real intention behind the whole concept, the order pointed out. UFO Moviez is planning to challenge the order in National Company Law Appellate Tribunal (NCLAT).
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INFRASTRUCTURE COMPANIES EYE LITIGATION FUNDING TO SETTLE CLAIMS

Litigation funding, or monetisation of pending claims through a third party, is finding its feet in India. A common practice globally, the Indian version of the funding comes with a catch. As Indian infrastructure companies struggle with stressed assets and huge pending claims, there is the case of Patel Engineering, which has been successful in litigation funding. Besides, sources said, the HCC was in an advanced stage to execute a similar deal Even lenders to Era Infra Engineering are believed to be looking at it, albeit as a last option. In some cases, the upfront cash payout is securitised against a pre-decided amount and a coupon rate. While the principal is serviced by the holding company’s cash flow, the interest is dependent on the outcome of claim settlement. A further upside or downside in the event of claim resolution is also pre-decided between the two parties. The process will need regulatory approvals in India. We are seeing interest from buyers and sellers of infra assets as well as global funds who specialise in litigation funding, said Deepto Roy. Shubham Jain, expects the new arbitration laws to further help such funding Litigation funding opens up a new source of long-term funds for infrastructure companies in India, which is welcome considering their leveraged position. The funds are willing to make these investments as the new arbitration act provides some comfort on time-bound redressal of claims, Jain said. The funding entity, however, needs caution. Sometimes, there is a big mismatch between what contractors claim and what the paying agency thinks is due. For instance, National Highways Authority of India's (NHAI’s) FY17 annual report says contracts have claimed about Rs 42,000 crore, whereas the actual payout may turn out to be less than 25 per cent of the same.
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IL&FS TO FORM CREDITORS’ PANEL TO ASSESS DUES

The board of Infrastructure Leasing & Financial Services will form committees of creditors at asset levels — the special purpose vehicles (SPVs) managing its projects — to assess their outstanding payments. It is also looking to appoint a claim adviser at the group level to coordinate the activity, people familiar with the matter said. The board in its progress report has talked about asset-level resolution and in some cases, a sale of business vertical comprising a basket of companies or other entities.
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A YEAR AFTER $2-BN NIRAV MODI FRAUD, PNB ON ROAD TO ANNUAL PROFITS IN FY20

One year after being hit by a $2 billion scam, Punjab National Bank (PNB) is set to return to annual profits and strong loan growth in fiscal 2020 even as investigations continue into the country's biggest banking fraud. State-run PNB has already surprised markets with an earlier-than-expected profit for the quarter ended Dec. 31 as it completed setting aside funds to cover for the scam and its bad loan levels eased. While the lender is still likely to post a loss of Rs 59.84 billion ($837.16 million) for this fiscal year ending March 31, analysts expect PNB to return to a full-year profit in the next fiscal, according to Refinitiv data. The bank is expected to clock a net profit of Rs 22.66 billion for the year ending March 2020, which would be its highest annual profit in five years. PNB's loan growth is estimated to be 8.33 percent for fiscal 2020, its highest in 4 years, as per the mean of analysts' estimates from Refinitiv. Its total assets are projected to grow at the highest rate in three years.
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SEBI INSERTS NEW RULE ALLOWING COMPANY SECRETARIES TO DO SECRETARIAL AUDIT

The Securities Exchange Board of India, last week inserted ‘Regulation 24 A’ providing for Secretarial Audit in SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 allowing the practicing company secretaries to do Secretarial Audit. The Market regulator also came out with the format for listed entities for preparing their annual secretarial audit and compliance reports. This would also be applicable for the material unlisted subsidiaries of the listed entities, the regulator said in a circular. The annual secretarial audit reports are meant to keep a tab on entities regarding compliance with applicable laws. The listed entities and their material subsidiaries would have to provide relevant documents and information to the practicing company secretary in order to obtain the certification. The Circular provides for the format for the annual secretarial compliance report covering a broad check on compliance with all laws applicable to the entity, listed entities shall additionally, on an annual basis, require a check by the PCS on compliance of all applicable SEBI Regulations and circulars/ guidelines issued thereunder, consequent to which, the PCS shall submit a report in the manner and format specified in the circular. The Institute of Company Secretaries of India (ICSI) expressed sincere thanks and gratitude to SEBI for acceding to its request and reposing confidence in the profession. This is a significant recognition to ICSI professional fraternity and endorsement to Secretarial Audit/ Compliance Reporting Mechanism and the Institute assure that members of ICSI shall continue to serve as an extended arm of SEBI, said CS Ranjeet Pandey.
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FORTIS CASE: SC REFUSES TO VACATE ORDER ON IHH’S RS 4,000 CRORE OPEN OFFER

The Supreme Court on Friday refused to vacate its earlier order that restrained Malaysia’s IHH Healthcare Berhad from going ahead with its open offer for Fortis Healthcare (FHL). The Malaysian firm had in July won the bid with its Rs 4,000-crore offer. The apex court had on December 14 put on hold the sale of controlling stake (31%) in FHL to the Malaysian firm on a contempt plea filed by Japanese pharma major Daiichi Sankyo against the former promoters of the hospital chain — Malvinder Singh and Shivinder Singh. The order for maintaining status quo till further orders of the apex court meant that IHH Healthcare had to wait and could not go ahead with its open offer which was scheduled to commence from December 18. A Bench led by Chief Justice Ranjan Gogoi without going into the issue posted the matter for final hearing on February 26 after Daiichi’s senior counsel Fali Nariman requested it to dispose of the case at the earliest. Singh brothers and their entities have no interest in RHT or its assets nor any money has being transferred to them, FHL said. The number of shares in respect of which the contempt is alleged is 12.25 lakh shares which constitute a minuscule percentage which has no impact on the controlling interests, it added.
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WHISTLE-BLOWER MAKES FRESH CHARGES IN FORTIS MATTER

The Fortis Hospitals matter, in which the Securities and Exchange Board of India (SEBI) ordered the company to refund over 400 crore in December 2018, has taken a new turn with the regulator receiving a complaint alleging that the real beneficiaries of the money were some of the top officials managing different businesses of the Religare Group. Initially, the money was believed to have moved from the listed entity to a subsidiary and thereafter to three borrower entities. In a letter submitted to SEBI on January 17, a whistle-blower has named brothers Gurpreet Singh Dhillon and Gurkirat Singh Dhillon, along with Sunil Godhwani and Sanjay Godhwani, among others, as the main beneficiaries of the fund transfer. This assumes significance as the SEBI probe that was initiated in February 2018 was based on reports that the promoters of Fortis Healthcare took out 500 crore from the company. The SEBI probe further found that Fortis Hospitals had given loans to three borrower entities – Best Healthcare, Fern Healthcare and Modland Wears. The ultimate beneficiaries of the three entities, as per the SEBI probe, were RHC Holding and Religare Finvest, with the former being controlled by Malvinder Singh and Shivinder Singh, the original promoters of Fortis Healthcare. The whistle-blower, in the letter, alleged that an advance of 155 crore that Best Healthcare received was disbursed to the Dhillon brothers. Further, Modland Wears is also alleged to have transferred 133.36 crore to a few people, including the Dhillon brothers. Meanwhile, Fern Healthcare, which received 114 crore from Fortis, transferred the money to the Godhwani brothers and Dhillon brothers, among others. While one cannot deny sensationalism through anonymous or whistle-blower complaints route, in some cases, SEBI in the past was able to identify possible fraud and other violations only because of information submitted by third parties, said Sumit Agrawal, founder, RegStreet Law, who had earlier served as a law officer with SEBI. SEBI usually wants these complaints to run it past by audit committees of listed companies as a first-check, added Mr. Agrawal. Unfortunately, SEBI investigation has conveniently forgotten and overlooked to collect and put out information about the dealings of well-connected Satsang Beas and moneys flowing from the Singh Brothers to the Dhillon family via an assortment of mysterious financial instruments, the whistle-blower’s letter stated. To the best of my information, around 488 crore has been extended to the Dhillon family as loans whereas around 70 crore has been extended to the Godhwani family, the letter stated.
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SEBI MAY ALLOW MUTUAL FUNDS & PMS IN COMMODITIES AT MARCH BOARD MEET; INDICES TOO ON CARDS

The Securities and Exchange Board of India (SEBI) may allow mutual funds and portfolio management services (PMS) in the commodities market at its upcoming board meet scheduled for the second week of March. The markets regulator has almost finalised regulations for their entry as a new participant A source close to development told that SEBI has already amended its custodian regulation so that they can hold warehouse receipt as collateral. But even after that regulator tried to allay all concerns raised by custodians, they remained unconvinced and refused to take responsibility of underlying assets, which is lying at warehouses, especially keeping in mind the National Spot Exchange fiasco, the source added. According to an exchange official, Allowing mutual funds and PMS will give a huge boost to the commodities market in terms of participation, which has been a major issue. SEBI may also give its consent to indices in the commodities market. SEBI is in the finalisation stage for allowing indices and whatever inputs they sought from exchanges have been provided, another source close to the development said, adding that initially the regulator may allow one agriculture and non-agri indices to start operations. Going forward, the source added that indices may be given more options to hedge their positions effectively, especially in a basket form.
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IRDAI PANEL WANTS 'SANDBOX COMMITTEE' FOR DIGITAL INNOVATION IN INSURANCE

An expert panel has suggested to insurance regulator IRDAI to set up a core 'Sandbox Committee' to promote digital innovation in the sector while safeguarding the interest of policyholders. Loosely defined, a sandbox approach means experimenting and learning before finally adopting a technology or system. This approach helps in containing the impact of failures The Insurance Regulatory and Development Authority of India (IRDAI) had set up the 10-member expert panel to come out with a consultation paper on regulatory sandbox approach to enable testing of products in a controlled environment so that the industry could keep pace with the fast-evolving financial technology (fintech). IRDAI should create a core Sandbox Committee having dedicated personnel to monitor and supervise the digital innovation activities, and provide support and advisory to the applicants as envisaged in the draft guidelines, said the report of the expert panel. The core sandbox committee would facilitate rollout of the experiments and seek to provide the ecosystem required for the experimentation. The purpose of the regulatory sandbox is to foster growth and increase the pace of the most innovative companies, in a way that provides InsurTech (technology-led insurance firms) in particular and the fintech sector as a whole with flexibility in dealing with regulatory requirements and at the same time focussing on policyholder protection, the report said. Regulatory sandboxing will be instrumental in providing a safe environment for fintech solutions to experiment and flourish in, given the fact that they would have enough time to lay down the necessary groundwork, said Rohan Kumar. Further, it will assist new technologies to emerge and ease into the highly regulated Indian market, he added. IRDAI has sought comments on the consultation paper till February 26.
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FPIS TURN NET BUYERS IN FEBRUARY, POUR RS 5,300 CRORE INTO EQUITIES SO FAR

Foreign investors have put in over Rs 5,300 crore into the Indian equity market in the first half of this month, primarily on account of positive view on the Interim Budget 2019-20. The infusion into the equity market comes following a pull-out of Rs 5,264 crore by foreign portfolio investors (FPI) in January. According to the latest data available with depositories, a net sum of Rs 5,322 crore has been pumped into equities during February 1-15. However, FPIs pulled out a net amount of Rs 248 crore from the bond market during the period. This has translated into a net investment of Rs 5,074 crore in the country's capital markets (equity and debt together).
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GOLD IMPORTS DIP 5 PER CENT DURING APRIL-JANUARY TO $26.93 BILLION

The country's gold imports dipped about 5 per cent in value terms to $26.93 billion during April-January 2018-19, which is expected to keep a lid on the current account deficit. According to commerce ministry data, total imports of the precious metal in the corresponding period of 2017-18 stood at $28.23 billion. Industry experts said softening prices of the precious metal in the world markets could be the reason for the contraction in imports. After recording negative growth for three consecutive months - October, November and December 2018, the imports grew by 38.16 per cent to $2.31 billion in January this year. India is one of the largest gold importers in the world and the imports mainly take care of demand from the jewellery industry. Gems and jewellery exports too dipped by 4 per cent to $32.9 billion during the 10 months of the current fiscal. India's current account deficit (CAD), or the difference between outflow and inflow of foreign exchange in the current account, widened to 2.9 per cent of the GDP in the second quarter of the fiscal, against 1.1 per cent in the year-ago period, mainly due to a large trade deficit. In volume terms, the country's total gold imports increased by 22.43 per cent to 955.16 tonnes in 2017-18. It stood at 780.14 tonnes in 2016-17.
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THE UNEXAMINED ASPECTS OF TREATING HOMEBUYERS AS FINANCIAL CREDITORS UNDER THE IBC

In the recent past, there were delays in giving possessions to home buyers who had booked flats/homes in real estate projects. There were also instances of Developers/Builders borrowing money from homebuyers in one project and investing them into another project or even siphoning funds, and then becoming incapable of completing projects in which homebuyers had invested their hard earned savings. Homebuyers who had taken loans ended up paying EMI’s for flats whose possession they never actually got. Cases like Jaypee Infratech Case, Supertech Case, Amrapali Case, etc had projected Homebuyers as the worst sufferers. All of these factors propelled the government to bring in an amendment to the Insolvency and Bankruptcy Code, 2016 and recognise homebuyers as financial creditors. The resultant amendment is as follows: Section 3 of the Insolvency and Bankruptcy Code (Second Amendment) Act, 2018 (second amendment Act) has inserted two explanations in Clause (8) (f) of Section 5 of the Code. Pursuant to the first explanation, any amount raised from an ‘allottee’ of a ‘real estate project’ i.e a homebuyer shall be deemed to be an amount having the commercial effect of borrowing, and resultantly he is a financial creditor under the section 7 of the IBC. (Which allows financial creditor(s) to file an application in NCLT for initiating corporate insolvency resolution process against a defaulting company). The amendment has further allowed the homebuyers being financial creditors to have representation in the Committee of Creditors through an authorised representative and also have voting rights.

Dilemma about the ‘default’?
Though the amendment has classified the homebuyer as a financial creditor, the definition of the term ‘default’ vis-à-vis a homebuyer has not been amended When is the ‘default’ said to have been committed by the developer and when ‘debt’ becomes due remains a grey area. As per Section 6 of the Code, financial creditors can initiate the insolvency proceedings against a corporate debtor upon the corporate debtor ‘committing a default’. The default referred to is default in payment of monies by the corporate debtor to the financial creditor. Generally, terms of allotment letters and agreements for purchase of under construction flats provide for repayment of the monies by the developer only upon termination of the allotment. But in the cases of delay, builders don’t actually terminate the allotment agreements. Relying on the definition of ‘default’ [Section 3 (12)], only once the refund is demanded by the homebuyer, it can be said that the amount of debt has become due. However, in the situations of delay in the delivery of possession which is largely the substratum of the dispute between the homebuyer and the developer, in the absence of termination of the agreement, there remains lack of clarity as to when the ‘debt’ has become due and the ‘default’ has been committed.

Disputed debt
The Amendment is based on a premise that the developer/builder is always a defaulter and presupposes a situation in which the projects are not completed on time. However, that is not really the situation in all the cases At times, the default can also be committed by the flat buyers due to delay in paying the instalments or final consideration amount. This amendment has actually conferred such status to the homebuyers that they are entitled to sustain their claim irrespective of a disputed debt. It is pertinent to note that Insolvency application under section 7 will be admitted notwithstanding whether debt is disputed or not, as long as it is ‘due’ [M/s Innoventive Industries Ltd. vs. ICICI Bank]. The question that arise is whether the insolvency forum being a forum of summary adjudication is an apt forum to adjudicate upon a disputed debt which involves a mixed question of fact and law. Whilst it true that the avoid of IBC has resultant into an enormous pressure being created on the developers for the timely delivery of flats but at the same time if the developer/builder is not at default and the claim is disputed, IBC proceedings turn into an abuse of process of law. For instance, in a matter before the Principal bench NCLT New Delhi, there was no delay in the grant of possession by the builder, however, the allottee defaulted in paying the instalments on time. After asking for the remaining consideration from the buyer several times, the builder eventually terminated the agreement, the flat buyer approached the NCLT under section 7. Before the arguments on the insolvency application could be completed, the builder entered into a hefty settlement with the flat-buyer in order to save his financially solvent company from the insolvency resolution process. It is argued that the resolution which is a process to rescue a failing business can also become recovery tool and merely an instance of dispute with one out of hundreds of allottees could result into driving a financially solvent and healthy real estate developer/business into insolvency. Many builders have asserted that homebuyers have an apt remedy to claim before the Consumer fora and RERA, and IBC amendment has only resultant into an additional encumbrance upon them.

Homebuyers Secured or Unsecured
The amendment raises ambiguity about the priority in which homebuyers would be repaid their loans Under IBC, the difference between secured financial creditors and unsecured financial creditors mostly has an implication on the priority of payments upon liquidation. The amended law grants homebuyers the status of financial creditors but stops short of stating whether they are secured or unsecured creditors. The homebuyer will have to prove which category of creditor he is qualified to be as per the agreement with the real estate company. If the developer company gets into liquidation, and the homebuyer is an unsecured creditor as per the agreement, he is actually even worse off. A plea by Jaypee Infratech homebuyers seeking secured financial creditors status is pending before the Supreme Court.

Third Party Interests
Many homebuyers have booked flats by taking loans from the banks. The general practice these banks follow while giving loans is that they enter into a tripartite agreement with both the homebuyer and the developer. By entering into such loan -cum -tripartite agreements with the banks, the homebuyers are actually creating third party interests in favour of the banks and are actually subrogating his rights in favour of the banks. In one such case with similar situation, NCLT Allahabad [Ajay Walia V. M/s. Sunworld Residency Private Limited, CP (IB) 11/ALD/2018] held that the homebuyers who has subrogated his rights in favour of banks cannot be treated as a financial creditor. The homebuyers need to be wary of the fact that if they will enter into such tripartite loan agreements while booking a flat, they no longer will be treated as financial creditors and it would adversely affect their rights to initiate a corporate insolvency process against the developer. Many homebuyers are continuing to pay EMIs for the loans they took from the bank for their flat. This aspect of creating third-party interests in favour of the bank and continuing to pay EMI’s for the flats whose possession they have not really gotten requires a further scrutiny in the Courts of law in the background of the amended Code. Furthermore, it has yet to be seen how effective the participation of the homebuyers in the committee of creditors would be and their contribution in assessing and approving resolution plans.

Key Observations and Suggestions
The Hon’ble Supreme Court [In Swiss ribbons Pvt. Ltd. & Anr. v. UOI] has held that the Insolvency and Bankruptcy Code is constitutional in entirety However, Justice Nariman has also sought response from the ministries of corporate affairs, law and justice and housing, and others on a petition by (PULIL), which challenged the constitutional validity of the Homebuyers amendment. IBC might have empowered homebuyers but its extent is still questionable. Furthermore, the homebuyer amendment also has the ingredients of being used as a tool to recover money from the developer/builder who hasn’t actually committed any default.
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SBI SHELVES RS. 15,431-CRORE ESSAR STEEL LOAN AUCTION

State Bank of India (SBI), which had put its Rs. 15,431-crore exposure to Essar Steel on the block to sell it to asset reconstruction companies and other financial institutions, is not likely to pursue the proposal further The auction received lukewarm response because a resolution on the issue is expected soon through the bankruptcy proceedings. In January, SBI decided to sell the exposure to Essar Steel and the e-auction was scheduled for January 30. However, the auction process received response only from one prospective buyer. The Essar account was referred to the National Company Law Tribunal for resolution and the committee of creditors had selected the Rs. 42,200 crore bid by ArcelorMittal India Pvt. Ltd. Then, Essar Steel submitted a bid which was about Rs. 12,000 crore more than ArcelorMittal’s offer. However, the National Company Law Appellate Tribunal (NCLAT) has now asked the NCLT to complete the hearing by February 19 and decide thereafter. The matter has been listed for hearing on February 28 at the NCLAT.
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ALLAHABAD BANK DRAWS A ROAD MAP TO COME OUT OF PCA LIST BY JUNE

Allahabad Bank hopes to come out of the Prompt Corrective Action (PCA) list by June after returning to profitability said S S Mallikarjuna Rao. Allahabad Bank expects fresh capital infusion from the government by the end of this month or early next month, which will help it come out of PCA framework in terms of two parameters — capital to risk-weighted assets ratio (CRAR) and common equity tier-1 (CET1). But, with the government shareholding in the bank currently at about 83 per cent, it will need to raise in excess of Rs 3,000 crore through markets to meet Securities and Exchange Board (Sebi) norms. The norms stipulate the government shareholding to be brought down to 75 per cent, and the bank has time till October 2020 to do it. After March we would not like to seek any fresh capital from the government. The requirement to reduce capital is around Rs 3,800 crore, which we cannot raise in one tranche. After PCA is over, we need plan and strategies to take it forward. That is why the work has started. We are utilising the opportunity of PCA in advantageous manner and correct whatever is required, said Mallikarjuna Rao. As of December 2018, the CRAR of the bank was 10.42 per cent, against the regulatory requirement of 10.875 per cent, while the CET1 was 7.06 per cent, against the requirement of 7.375 per cent. We have already reduced about Rs 5,600 crore advances. The average risk weight was around 33 per cent. Even if we rebalance it at 20 per cent, the opportunity to lend at a higher level is more. Also, by closing the Hong Kong branch, we will have the advantage to increase our operating profit. NIM in Hong Kong is less than 1 per cent. Whereas in India it runs at 2.65 per cent, said Mallikarjuna Rao. To come out of PCA list, the bank needs to qualify on the parameters of CRAR, CET 1, net non-performing assets (NNPA), leverage ratio and return on assets (ROA).
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COGNIZANT TO SETTLE TAMIL NADU GRAFT CASE IN US WITH $28 MILLION

Cognizant Technology said on Friday it has agreed to pay $28 million (about Rs 200 crore) to the US stock market regulator Securities Exchange Commission (SEC) and its justice department to settle a graft case. It relates to alleged bribing of Tamil Nadu government officials with $3.6 million in 2014 to build development centres. Cognizant said in a statement that it had resolved all disputes with US regulators pertaining to violations of Foreign Corrupt Practices Act as its top management allegedly facilitating bribes to government officials The tech company, incubated in Chennai, and with nearly a third of its global workforce in India, told the regulator that it was seeking permanent injunctions against its former president Gordon Coburn and former chief legal officer Steven E Schwartz for directing a building contractor to conceal the bribe by doctoring orders. While Cognizant settled all US government proceedings against it, the TN government on Friday announced actions against the two former executives. These cases are a matter between the government and these individuals and the charges against them will be addressed by the court system, said Francisco D’Souza, vice-chairman and CEO of Cognizant. Both the officials have since quit the company.
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A YEAR AFTER ANDROID DEBUT, 'WHATSAPP BUSINESS' IS ALL SET FOR IOS LAUNCH

The beta version of WhatsApp Business -- a free-to-download communication tool specifically designed for small businesses -- has been made available for iOS users. After the launch of the official WhatsApp Business for Android, which is a compatible version for iOS and a lot of users had asked, it is finally available in beta, WABetaInfo, a fan site that tests new WhatsApp features reported on Friday. Launched in January 2018, WhatsApp Business had only been made available on Android devices until now. In a tint colour of darker blue, the beta app for iOS includes Messaging Tools for businesses like automated greeting and away messages, quick replies and the Recipients feature was also set to allow users to choose specific recipients for a particular message. Along with the option allowing users to migrate their existing WhatsApp accounts and contacts to a WhatsApp Business account, the app also enables users to customise their business profiles and configure business hours with options in the Edit menu.
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EMAILS, HASHED PASSWORDS OF 18 MILLION IXIGO USERS STOLEN

User data of 18 million, largely email IDs and hashed passwords, were allegedly stolen from online travel aggregation platform Ixigo. This is part of a broader data steal that saw user information being leaked from seven other global sites including home improvement website Houzz. Ixigo founder and CEO Aloke Bajpai told the company will issue a notification to its users to reset their passwords as a safety measure. British news platform The Register first reported the data leak. Backed by China’s Fosun, Ixigo had over 20 million monthly active users in November last year. A company spokesperson said it had nearly 100 million users in total. Ixigo is currently investigating this alleged security breach. We are a travel marketplace and we take our users’ data and privacy seriously. We do not store payment, cards or financial information for any of our users. We encrypt and hash our passwords with a one-way hashing algorithm. While we have already taken pre-emptive security measures, such as two-factor authentication, we will also, as a precaution, reset passwords and security tokens of our users, Bajpai said in a statement. Earlier, online food delivery platforms like Zomato and FreshMenu faced similar incidents of data leaks in the country. Zomato, too, had issued notifications to affected users to change their passwords.




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Thanks & Regards,
CS Meetesh Shiroya

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