Friday 22 February 2019

CORPORATE UPDATES 23.02.2019






IBC REIGNS SUPREME OVER OTHER CIVIL LAWS, SAYS DELHI HIGH COURT

The Delhi High Court on Friday upheld the supremacy of Insolvency and Bankruptcy Code (IBC) over other civil laws such as those of contracts and guarantees and said that only the National Company Law Tribunal (NCLT) or similar adjudicating authorities should deal with the cases falling under the code If civil courts were to pass any orders in matters pertaining to IBC, the entire corporate insolvency resolution process pending before NCLT would be put at naught as non-serious applicants would submit resolution plans for consideration before the Resolution Professional (RP) and Committee of Creditors (CoC), and then not abide with it once it is approved said a single judge bench of Justice Rajiv Sahai Endlaw. This in turn, would lead to wastage of time which could make resolution of corporate debtors unfeasible. In such cases, liquidation of the company would be the only alternative left owing to the time lapsed, the court said. The observations by the court came while delivering a judgement in a plea moved by Liberty House Group against State Bank of India (SBI) and others. Liberty House Group had moved the high court seeking to stop SBI, Barclays Bank and the Resolution Professional (RP) for Castex Technologies as well as Amtek Auto, Dinkar T. Venkatasubramanian, from invoking the bank guarantees worth close of Rs 100 crore it had submitted for the two companies. The bank guarantees were submitted by Liberty House as a pre-condition for bidding for both the companies under the corporate insolvency resolution process. The company, however, failed to proceed with the resolution process despite having been declared the successful bidder in both the cases, following which SBI invoked the bank guarantee. The bank guarantees, the high court said, was a measure to induce some fear in such unscrupulous elements, which chose to delay the corporate insolvency resolution process without any fear of consequences. Now if this court were to have jurisdiction and to hold either that the terms of the Process Memorandum or of the Bid Bond Guarantee (BBG) were not binding on the plaintiff and/or that the plaintiff is not in default thereof, the same would clearly amount to rendering findings inconsistent with the NCLT Justice Endlaw said in his judgement. The entire transaction of giving of bank guarantee by Liberty House and invocation of the same by SBI was in the ambit of IBC. A decision on the same by any other court would amount to rendering findings inconsistent with NCLT, the judge said. Earlier, the Chandigarh bench of NCLT had slammed Liberty House group for failing to go ahead with the approved resolution plans for Castex Technologies and Amtek Auto. On December 5, the NCLT had, in an order, said that the somersault taken by the Liberty House put the whole CIR Process and the machinery to quandary. Such an unsavoury stance of the Liberty House would only attract adverse comments from any fair minded person particularly when there is no justifiable reason for Liberty House to drag its feet, the NCLT had said in its order. While rejecting Liberty House’s plea, the court imposed a cost of Rs 50 lakh on the company and asked it to pay the same to SBI within four weeks from now.
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MCA WARNS PMO, FINMIN AND RBI OF CREDIT STRESS IN REAL ESTATE SECTOR

The Ministry of Corporate Affairs (MCA) has informed the Prime Minister's Office, the Finance Ministry and the Reserve Bank of India (RBI) that the credit stress in the real estate sector needs to be watched closely The MCA expressed concerns over the issue due to the sector's exposure to non-banking finance companies (NBFC) and housing finance companies (HFC), sources told. It added that the sector is going through a difficult phase and banks must be vigilant of any default in the sector, and it must be reported immediately. The ministry wants to avoid negative events in the sector, which could in turn affect the bourses.
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SHELL COMPANIES: E-FILING DETAILS MUST FOR ALL FIRMS

Continuing with its crackdown on fly by night and dummy entities through stringent KYC regulations the government has made it mandatory for over 12 lakh active registered companies in India to upload all their particulars including details of registered offices in an e-filing to the government. The Ministry of Corporate Affairs has notified the Companies (Incorporation) Amendment Rules, 2019, under which all companies registered before December 31, 2017, are required to file eForm ACTIVE (Active Company Tagging Identities and Verification)-INC22A on or before April 25, 2019 Failure to file e-Form ACTIVE will lead to a penalty of Rs 10,000 with companies in default being declared ACTIVE non-compliant. Once a company is marked as ACTIVE non-compliant it would not be able to make changes to its capital structure or go ahead with merger or amalgamation deals. Such non-compliant companies would also not be able to rotate their directors or make changes in their registered office The rule makes it amply clear that companies have to e-file all their details so that a proper check is maintained on their operations and creation of shell companies is prevented, said a government official not wanting to be identified. According to the new notification for filing of Form INC22A or ACTIVE, a company must have filed its annual return for the FY18. However, if a company is struck off or is in process of being struck off or is under liquidation, Form ACTIVE need not be filed. If ACTIVE is filed on or after April 20, it can only be done after paying a penalty of Rs 10,000. Only after this, will the company be declared ACTIVE-compliant. The e-Form will get all details of a company - its directors, annual filings and a photo (internal and external) showing one of the directors in its registered office.
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PLEDGED SHARE SALE: MUMBAI HC GIVES A MOUTHFUL TO ANIL AMBANI FIRM, SAYS PETITION 'SMACKS OF DECEIT'

The Bombay High Court has rapped the Anil Ambani group company Reliance Power and its management for attempting to mislead the court by a petition that's smacked of deceit. The sharp words came from judge KR Shriram of the Bombay High Court while hearing a Rs 2,700-crore defamation suit filed by Reliance Power against financial services company Edelweiss group for selling its pledged shares earlier this month after a massive plunge in share value. At the hearing on Thursday, the judge observed that the entire plea made by Reliance Power smacked of deceit and is an attempt by them to mislead the court. The Reliance group had argued that the sale of its pledged shares by Edelweiss' ECL Finance was illegal and must be stopped as the sale is illegal and void, and sought a compensation of over Rs 2,700 crore for the fiscal and reputational losses. As per the plea, Reliance and its sister company Reliance Communications had pledged some shares of various promoter companies with the Edelweiss group in lieu of a loan. Interestingly, even though the group had named L&T Finance also for selling pledged shares in a public statement on February 12, it did not take the company to the court. Judge Shriram, however, took a strong exception to the above arguments on reasonable notice both during the hearing and in his detailed order. It is strange that such an argument is made by the plaintiff. When the contract was entered into, the plaintiff found one-day notice to be reasonable. Therefore, the stand taken by plaintiff smacks of deceit and an attempt to mislead the court, he said. At no point after the occurrence of events of default, did the plaintiff ask for increasing the notice period or pay the default interest. They didn't even top up the security ratio, or even tell the defendants (Edelweiss) how they are going to make good or even reply to the letters from them. And now you take a mendacious stand that notice period in the contract was not reasonable, the judge said. The judge also noted that Reliance Power wasn't an illiterate or a small party when the contract was signed and since it was a settled principle of law that when a person signs a document s/he is assumed to have read the terms of such document. Given this, the plaintiff's arguments on the notice period could not be accepted. I find nothing wrong in what the defendants (Edelweiss) have done, the judge said and directed Edelweiss to file its reply and fixed the next hearing on March 22. Edelweiss is being represented by its counsel Janak Dwarkadas, while Reliance is represented by Aspi Chinoy.
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RELIGARE FINVEST FILES INSOLVENCY PETITION

The new management of Religare Finvest has filed an insolvency petition alleging diversion of funds by erstwhile promoters Malvinder and Shivinder Singh. The National Company Law Tribunal (NCLT) will hear the petition against a cluster of 19 companies that are allegedly linked to the brothers said two people with the direct knowledge of the matter. The companies were used to siphon off loans, they said. Religare Finvest has claimed Rs 2,257 crore from the former promoters. This comes as the Singhs appear to be at war with each other. More recently, Malvinder accused Shivinder, the spiritual head of the Radha Soami Satsang Beas and Godhwani of criminal conspiracy, cheating and fraud for allegedly siphoning off thousands of crores from RHC Holdings. Under new management, financials seem to be improving. Religare Enterprises posted a loss of Rs 10.33 in the December quarter, down from Rs 45.14 crore a year ago. Total income rose to Rs 12.23 crore from Rs 11.85 crore, it said in a regulatory filing on Tuesday.
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SEBI LEVIES RS 13 LAKH PENALTY FOR FRAUDULENT TRADE AGAINST 2 ENTITIES ON BSE

Sebi Thursday slapped a total penalty of Rs 13 lakh on two entities for non-genuine trades in illiquid stock options on the BSE. The regulator observed that the entities deliberately adopted strategy to enter into reversal trades with same counterparties and that too at price incurring losses to them. Facts shows that these trades were executed with precision to match with the same counterparty to create artificial volume in these contracts, and create misleading appearance of trading, Securities and Exchange Board of India (Sebi) said. The act of creating artificial volume, violates the PFUTP (Prohibition of Fraudulent and Unfair Trade Practices) norms, the regulator said. Accordingly, Sebi imposed a fine of Rs 8 lakh on Blue Bird Mercantiles and Rs 5 lakh on Bhiragacha Finance.
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SEBI IMPOSES RS 10-LAKH FINE ON LINKHOUSE INDUSTRIES

Sebi on Friday levied a fine of Rs 10 lakh on real estate firm Linkhouse Industries for failing to provide relevant information sought by the regulator regarding the change in promoters' shareholding. During an investigation between June 2004 and December 2008, the regulator observed that the promoters' shareholding in the company had increased from 70.52 per cent in March 2004 to 77.47 per cent in June 2004. Following the change in holding pattern, Sebi sought documents from the firm regarding time, mode and number of shares bought by the acquirers. However, the noticee failed to submit the information/documents sought by investigating authority which hampered the investigation, Sebi said in an order. Non-furnishing of the details hampers the investigation and creates hurdle which is detrimental to the interest of investors in securities market, which needs to be dealt strictly, the regulator added.
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NATIONAL OILWELL VARCO PAYS RS 6.8 LAKH TO SETTLE CASE WITH SEBI

US-based National Oilwell Varco Inc Friday settled with Sebi a probe for alleged delay in complying with minimum public shareholding norms in GMM Pfaudler by paying Rs 6.8 lakh as settlement charges Due to open offer in 2013, the total promoter shareholding (including National Oilwell) changed to 76.66 per cent in GMM Pfaudler, which indicated that public holding was not at least 25 per cent as mandated under minimum public shareholding norms, the regulator said. To bring down the shareholding to 75 per cent, offer of sale for 1.66 per cent (2,42,472 shares) was made which was completed in December 2014. It was alleged that shareholding was not brought down within the stipulated time, hence it was in violation of SAST (Substantial Acquisition of shares and Takeovers) norms. Following which the regulator initiated adjudication proceedings against National Oilwell.
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SEBI FINES RS 6 LAKH ON TANEJA AEROSPACE, 2 OTHERS FOR DISCLOSURE LAPSES

Markets regulator Sebi Thursday imposed a total fine of Rs 6 lakh on Taneja Aerospace and Aviation Ltd (TAAL) and two senior company officials for disclosure lapses regarding acquisition of a wholly-owned subsidiary. Sebi initiated investigation after it received complaint alleging irregularities in the amalgamation of TAAL with its wholly owned subsidiary TAAL Technologies Pvt Ltd (TTPL). During the investigation, the regulator observed that with respect to investment in TTPL, Taneja Aerospace only disclosed on July 30, 2009 that TTPL has become its wholly owned subsidiary even when it had acquired 50 per cent shares on two occasions, March 19 and July 15, 2009. Besides, it also did not disclosed about its advancement of Rs 9.7 crore in installments to TTPL.
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RBI TO MERGE THREE CATEGORIES OF NBFCS TO CREATE NEW CATEGORY

The Reserve Bank of India (RBI) on February 22 announced that it will merge three categories of Non Banking Financial Companies (NBFCs) into a new one. According to a release, NBFCs categorized as Asset Finance Companies (AFC), Loan Companies (LCs) and Investment Companies (ICs), will be merged into a new category called NBFC - Investment and Credit Company (NBFC-ICC). On a review, it has been decided that in order to provide NBFCs with greater operational flexibility, harmonisation of different categories of NBFCs into fewer ones shall be carried out based on the principle of regulation by activity rather than regulation by entity, RBI said in a statement. The release also mentioned that a deposit taking NBFC-ICC shall invest in unquoted shares of another company which is not a subsidiary company or a company in the same group of the NBFC, not exceeding twenty percent of its owned fund.
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BANKS' CONSORTIUM CONSIDERING RS 500 CRORE INTERIM FUNDING TO JET AIRWAYS, SAYS PNB CHIEF

A consortium of banks is considering an interim funding of Rs 500 crore for debt-laden Jet Airways but a final decision is yet to be taken, Sunil Mehta said on Friday. PNB is part of the lenders' consortium, led by State Bank of India (SBI), that has extended loans to the airline. The full service carrier is looking to raise funds and restructure its debt. Regarding Jet Airways, Mehta said the consortium is looking at the entire process and something is being worked out. Of course, (the) consortium is in favour (of interim funding). It is a going concern and we would like to preserve its (airline's) value, he said. About interim funding for the carrier, Mehta said, it is too premature to tell you about that plan and the bankers are already working on it. The SBI has taken a lead on it, and let the entire plan be worked out, he said, adding that it would be too early to announce the timings.
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BANKS NEED TO USE MORE TECHNOLOGY IN LENDING: CEA

Banks need to use more technology to screen borrowers and monitor them, a top Finance Ministry official has said. There is certainly compelling reason for significantly greater use of technology to strengthen the quality of lending, K. V. Subramanian, said. Subramanian noted that banks have not been leveraging the power of technology for enhancing the quality of lending Kumar said there was need for discussions on how Indian banking sector could be integrated with the world without losing regulatory control. One also needs to look at the composition of equity and see if we could go higher in terms of allowing more foreign ownership. He underscored the need to proceed with the P J Nayak Committee report recommendations on aspects of governance reforms. Kumar also stressed the need for steps to bring down the cost of capital which he described as very high in the country.
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RBI TRANSFERS ARE CRUCIAL FOR FISCAL MANAGEMENT

The payment of an interim dividend by the Reserve Bank of India (RBI) to the government is significant because it is the second time that this has been done, and that too in successive years. The surpluses of RBI have hence come to occupy a very important position in managing the Centre’s fiscal balances. Interestingly, the surpluses of RBI in the past were not really considered to be important as most of the so-called profit is notional. But, today, the contribution to the exchequer is quite critical and the interim dividend manifests this phenomenon. RBI earns money by virtue of being the custodian of forex reserves and conducting monetary policy operations. As forex reserves finally reside with the central bank, they are invested in safe avenues and earn an income. Similarly, the Government Securities (G-Sec) held by RBI that are used to draw liquidity out of the system when required for OMOs (sale) earn revenue for the central bank. Further, when RBI conducts the repo and term repo operations when liquidity conditions are tight, banks pay them interest at the repo-related rate. Hence, the central bank runs a very profitable balance sheet as the liabilities do not quite exist and can be created by a fiat. In the five-year period 2009-10 to 2013-14, the average surplus was 21,560 crore, with a maximum of 33,010 crore in FY14. In the period 2014-15 to 2018-19, the average surplus was 58,622 crore, with the peak being 68,000 crore for FY19. In fact, in three of the last four years, the surplus was above 60,000 crore, with FY18 being the exception, when demonetisation came in the way as both income was lower (surpluses wit.h banks had to be paid the reverse repo rate) and the expenses were higher. The accompanying graphic gives the ratio of RBI surplus transferred to the government to gross fiscal deficit. Around 35,000 crore came in 2017-18 from investments of forex assets; and as interest rates increase in the West, the Fed bonds and others would provide higher revenue for RBI. The average return here is still very low at 1.09% for 2017-18, as per the RBI Annual Report, given the safe investment avenues chosen. Doubling this return would provide higher revenue, which can be further used to manage the budget deficit. A thought here is whether or not RBI should get involved in treasury operations to earn more income on deployment of forex reserves. The dividend is hence paid in July after the results are out and, therefore, the 2017-18 outcomes get into the Budget of 2018-19. The interim dividend paid for fiscal 2018-19 would get reflected in the 2018-19 accounts of RBI, which is for the previous year being a lagged payment. This can be a useful way of rolling in the transfers too.
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FOREX RESERVES UP $150 MN; HIT $398.3 BN ON RISE IN CURRENCY, GOLD HOLDINGS

Forex reserves increased by $150 million to $398.272 billion for the week to February 15 on a rise currency assets and gold holdings the Reserve Bank said Friday. In the previous reporting week, the overall reserves had surged by $2.11 billion to $398.122 billion. The foreign currency assets, a major component of the overall reserves, increased $88.9 million to $371.07 billion for the reporting week, the RBI said. The value of the gold reserves increased $78.2 million to 22.764 billion, the apex bank said. The special drawing rights with the International Monetary Fund also came down by $7.8 million to $1.455 billion. Similarly, the country's reserve position with the Fund also declined by $9.1 million to $2.982 billion, it said.
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REAL ESTATE MARKET TO GROW FIVE TIMES TO $650 BILLION BY 2040

Indian real estate market is expected to jump over fivefold to USD 650 billion by 2040 and its share in the country’s gross domestic product (GDP) is set to double from the current seven per cent, Rajiv Kumar said Friday. The government is committed not only to real estate sector but all aspects of it. The government is very conscious and cognisant of what happening in the sector and how it contributes to the economy, he said. Kumar said the recent Interim Budget has demonstrated that the government would take steps to make sure that the real estate sector grow and develop further so that this industry contributes even more to the economy. The Centre has offered a lot of tax incentives to developers building affordable houses and also tax sops to homebuyers looking to purchase second homes. Highlighting the importance of this sector, the Niti Aayog vice-chairman said the real estate sector is contributing seven per cent to the country’s GDP and its share is expected to double by 2040. The current size of the real estate market is already USD 120 billion dollar and this will grow to USD 650 billion by 2040, he said, adding that the industry employs 55 million people now and this number will rise to 66 million as it grows. This sector is heart of the economy. It has backward linkages with 200 other industries, Kumar said. He also said the real estate sector would contribute more with rapid urbanisation. Kumar said the two legislations — the goods and services tax and the RERA — implemented by the government would help in organised growth of this sector. He asked real estate companies to blend best of Indian culture and best of global facility and technologies in their future development of properties. Speaking on the sidelines of the event, Embassy group President (Residential Business) Reeza Sebastian said there is a good demand for completed housing units in all categories including luxury homes.
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TRAI MEETS PLAYERS, SAYS NEAR ALL CABLE TV CONSUMERS EITHER PICK CHANNELS OR PUT ON 'BEST FIT PLAN'

Sector regulator Trai on Friday said it has been informed by players that almost all cable TV consumers have either made their channel preferences or been moved to 'best fit plan' under the new tariff regime. S K Gupta told that according to inputs received by the regulator from players, in the case of DTH services, about 43 per cent customers have made their channel preferences known When combined with statistics for 'best fit plan', this number rises to 57 per cent, Gupta said. As per inputs provided by DPOs, near 100 per cent consumers of cable TV homes have been migrated to the new framework either based on options of subscribers or as per 'best fit plan'. Among DTH service homes, over 43 per cent consumers have already been migrated, Gupta said. The DTH service providers have submitted to the Telecom Regulatory Authority of India (Trai), which is also the regulator for broadcasting, that all subscribers of this pre-paid platform will be migrated to new framework in the next 2-3 weeks.
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TELECOM FIRMS CAN EARN $15 BILLION ADDITIONAL REVENUE IF THEY BRIDGE ‘GENDER GAP’

Indian women are less likely to own a mobile phone than their male counterparts revealed a recent survey by GSMA. While 80% of the Indian male population possess a phone, only 59% of the female population own it. The same echoes in the internet usage gap as a meagre 16% of the female population is likely to have access to mobile internet as opposed to 36% of males. For those with the view that the talks about gender gap are far-fetched, the survey could be an eye-opener. In low and middle-income countries, the divide translates to 184 million fewer women who own a mobile phone. Topping that, over 1.2 billion women do not have access to mobile internet. According to the findings of the survey, if the mobile telecom companies were to bridge the gap in both the mobile ownership and internet usage in low and middle-income countries, an additional $15 billion revenue (approximately) in 12 months could be generated. Among southern Asian countries, China has set an example as it has zero mobile ownership gender gap. While India has a considerable 26% ownership divide, Pakistan and Bangladesh have performed worse than India with 37% and 33% gap respectively. However, it is intriguing to note that Mozambique and Myanmar performed better in this survey. The survey also shed some light on the mobile internet user gender gap. While China has only 1% rift between male users and female users, in India, the rift is wide at 56%. Pakistan, Mozambique, Bangladesh performed worse than India, however, countries such as Cote d’Ivoire ranked better.
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VIDEO CONSUMPTION PUSHES DATA TRAFFIC BY 109% IN 2018

Backed by rising video data consumption on over the top (OTT) players, mobile data traffic in India grew by 109% in 2018, with 4G alone contributing 92%. Average data usage grew by 69 % in 2018 to touch 10GB a user per month in December, as per Nokia's annual mobile broadband India traffic (MBiT) index released on Thursday. OTT players have gained significantly due to operator tie-ups and aggressive 4G network expansion, with high consumption on their platforms. WhatsApp and Instagram are the leading social networking app among subscribers, the report said. The total number of 4G mobile user stands at 432 million, a jump of 147 % compared to 2017, as lower data tariffs and affordable devices continued to boost usage. However, the current broadband penetration in India is around 45%, which is at a much lower level compared to China at 72%, and other European nations at around 85-95%. The surge in broadband consumption is likely to continue in the next few years since the current broadband penetration is just 45% in the country, said Sanjay Malik, said. Video streaming continues to remain a major contributor to mobile data traffic constituting 70-80% of the total traffic. Over a 90% fall in 4G data prices over the last five years has fueled video streaming in the country and the emergence of short format videos in several social networking apps like Instagram and TikTok has led to deeper engagement levels. 4G has taken off with dirt cheap data tariffs and free voice calls offer from Reliance Jio in late 2016, which was matched by competitors. The disruption shook the market which led to a consolidation phase where three players – Reliance Jio, Vodafone Idea and Airtel have been left along with a telecom PSU BSNL/MTNL. Out of the 1 billion mobile users, around 450-500 million are connected to the internet, so the opportunity for players is huge.
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MAKING PROFIT ALONE IS NOT ENOUGH IN TODAY’S WORLD: DELOITTE GLOBAL CEO PUNIT RENJEN

The digital revolution is going to be more profound than all the other earlier revolutions and companies will have to think beyond profitability said Punit Renjen. He went on to say that the world is changing rapidly modeled by four forces One of them is populism, and you see this from Britain all the way to Brazil and from Indonesia to Italy. It is introverted, it is regressive, asserted Renjen. The other aspects include global regulations which tend to have influence across jurisdictions. Third is competition, primarily tech enabled. But this competition is fundamentally disrupting industries and disrupting the way we do business, he said. Also, he said expectations from a company are now way beyond making money. Client ad customer expectations are more outcome based, especially millennial expectations. They expect you to do more than just generate profit which is consistent with the theme of this conference, he said. He said that whenever he goes to campuses for hiring one of the first question that students ask is what does Deloitte does beyond profit. The takeway is that you have to think beyond your core competency. We have been taught that you have to stick to your knitting, stick to your core competency. But in Industry 4.0 that is not going to be enough to sustain competitive advantage, said Renjen, who hails from Rohtak near New Delhi. Going ahead companies will have to define their purpose. And I am not talking about Corporate Social Responsibility. I am talking about fundamental defining for your own business, as what is our reason to exist. Why do you exist as an enterprise? asked Renjen. He concluded by saying that execution of a strategy is going to be key for businesses globally. It is a great opportunity for us to do right, to do good because if we don’t unleash it appropriately some of the issues that plague us today like income inequality will probably process, he said.
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CRYPTOCURRENCY COMPANIES USE 'BACKDOOR' LISTINGS TO EASE INTO MAINSTREAM

Several cryptocurrency exchanges have moved closer to mainstream markets by buying listed companies looking to raise funds and present themselves as embedded in the traditional financial services world they once spurned. In the most recent deal, US crypto broker-dealer Voyager Digital on February 11 achieved a backdoor listing on Toronto's Venture Exchange after it bought control of mineral exploration firm UC Resources. Such purchases, also known as reverse mergers, allow companies to offer shares to the public without the rigours and regulatory scrutiny of a full initial public offering (IPO). Many (cryptocurrency) exchanges have put a lot of strategic effort into trying to legitimise their operations and their reputations, and for some, there's an assumption that having some exposure to the traditional public market will help said Fei Ding'an. Japan's Financial Services Agency (FSA) is the only major national regulator so far to have drawn up a definitive framework to govern digital assets and the platforms where they are traded. In January, OKC Holdings, a company controlled by Star Xu, the founder of crypto-exchange OK Coin, bought 60.5 per cent of LEAP Holdings, a Hong Kong-listed construction firm, for HK$484 million ($61.69 million). Voyager said its listed shares could help fund growth. Being a public company enables Voyager to operate with the transparency that the crypto market deserves from its institutions, Steve Ehrlich said.





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CS Meetesh Shiroya

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