Role of Insolvency and Bankruptcy Code on Distressed Mergers and Acquisitions
Tejaswani Prasadam
LL.M., NALSAR-IICA
Abstract
Insolvency and Bankruptcy Code, 2016 revolutionized the management of distressed assets in India, by providing a structured, time-bound framework for corporate resolution of the distressed company. As the preamble of the code states, the code aims to preserve the value of the assets while protecting the creditors’ interests. Which boosted merger and acquisitions transactions, especially with the increase of distressed assets, it boosted the distressed M&A to help the company come out of the financial distress.
The enactment of IBC has marked a paradigm shift by prioritizing the continuation of the distressed company as a going concern. For this purpose, the code encourages the debtor to resolve through M&A during the CIRP, therefore it has created various opportunities for the investors while also providing a hope of recovery for the creditors. However, there are various challenges such as delays in the resolution process, prolonged litigation, ambiguity of laws that usually hinder full potential of distressed M&A, which is why it is necessary to study the role and the challenges of IBC in distressed M&A transactions.
Introduction
The rise in distressed assets became one of the major concerns in the Indian economy, which is why there was immense need of new laws and regulations to control these distressed assets. With the enactment of Insolvency and Bankruptcy Code India, 2016 (hereinafter referred as IBC), marked the significant reform with respect to country’s approach towards the companies that are facing insolvency and bankruptcy. Through IBC, the laws provide various efficient and effective mechanisms for resolving distressed companies. IBC is a unified code. The code provides a time-bound resolution process for the distressed assets. It tries to reduce the depletion of the value of the assets and gives importance to the creditors. Thus, it can be said that IBC has a positive influence on the Indian market and that it provides mechanisms for the interested parties to deal with the distressed assets[1].
From before the birth of IBC, the distressed assets were often stuck in a lengthy and disorganised which led to depletion of the value of the assets. The laws at that time, mainly concentrated on shutting down the company to release it from its debts. With the help of IBC, it gave importance to keep the company as a going concern. IBC aims to provide a resolution and aims to revive the sick companies as much as possible, and approves liquidation only as the last option. Which is why this led to encouragement of distressed mergers and acquisitions (hereinafter referred as M&A).
When a company defaults in repayment of its debt, it becomes a corporate debtor, on the default of payment, the creditor being financial or operational, then initiates a Corporate Insolvency Resolution Process (hereinafter referred as CIRP). After which a moratorium period is declared by the Adjudicating Authority (hereinafter referred as AA), during this time any person who is eligible to be a resolution applicant can submit a resolution plan as defined under Sec 5(26) of IBC. Therefore, a resolution plan for the resolution of the corporate debtor and for maximization of value of the assets, can facilitate amalgamation, merger, acquisition or demerger.[2] The distressed M&A, have become a vital tool for reviving the failing businesses and to ensure maximum asset recovery for the creditors. This technique is showing to be beneficial for the distressed companies as it facilitates quicker transactions in a time-bound manner while trying to retain the value of the assets. As a result, with the emergence of IBC, it facilitated the increase of M&A in India. Within 2 years of IBC, 12% distressed M&A deals were done which were worth $14.3 Billion.[3]
Researching the role of IBC on distressed M&A is crucial because this unlike general M&A, the parties are going through this process due to the financial distress. Through IBC, the laws aim to ensure that the M&A is a time-bound process dine with due diligence while aiming to maximise the value of the assets. This creates a scope for both opportunities and challenges. Though IBC is known to provide effective CIRP, but then in practicality, there have been significant delays, haircuts and reduction in value of assets and involvement of other organisation while protecting the rights of the creditors in this process makes the distressed M&A a complicated procedure and a challenge. Thus, this research would analyse the influence of IBC on M&A, while also analysing the opportunities and challenges it has for the prospective buyers and IBC can be leverage to create effective outcome for the distressed companies.
Relevance of Study:
IBC has transformed the management of distressed companies. With enactment of IBC, distressed M&A is blooming in India. It paved way for the corporate debtor to merger with other corporates to deal with the financial distress. It paved way for the prospective buyer to purchase the assets at cheaper rates. Since the existence of IBC, the M&A deals have significantly increased. Some of the notable distress transactions through IBC can be seen in the steel industry which are acquisition of Essar steel by Arcelor Mittal[4] and acquisition of Bhushan Steel by Tata steel[5] which has significant impact on the Indian economy. Which is why this is a relevant area of study, as it is important to analyse and understand the relationship between IBC and M&A, as it can be seen that M&A is one of the vital tools of CIRP. Another reason for the study is to have a better insight on the effectiveness of IBC in handling distressed M&A while also trying to maximise the value of the assets and to complete the transaction or the process in a time-bound manner. This study will help us to understand the various challenges that can impact the distress M&A and to will help the researcher to address such issues.
Justification of Study:
Due to a greater number of distressed assets, M&A has become a vital tool deal with financial distress. IBC is known to offer effective framework for providing resolution of distressed assets.[6] It has introduced a paradigm shift in how the distress assets are managed, however despite having a framework, the challenges are very much attached to the positive impact of distressed M&A. it very much crucial that deals of distressed M&A must be done while also protecting the right of the creditors and its impact on market competition. Which is why it is important to analyse the positive and negative to understand its effectiveness in dealing with distressed M&A. The main reason the researcher is keen on this study is provide insights in regards to it and provide possible suggestions to the challenges.
Literature Review:
- Arjun Khanna, The Relationship Between Mergers and Acquisitions and the Insolvency and Bankruptcy Code (IBC) in India: A Critical Analysis, 5 Indian J. Law & Legal Research 1 (2023).
The paper studies on the relationship between M&A and IBC. As in India this particular area has been gaining attention since the implementation of IBC. The researcher has highlighted the role of IBC in managing the distressed assets and how it facilitates faster and effective M&A transactions. The paper focuses on both the positive and negative aspects, as in how IBC has enhanced the M&A, process whereas also speaking about the challenges such as delays in CIRP which leads to depletion of the value of the assets.
- P. Ram Mohan & Vishakha Raj, Merger Control for IRPs: Do Acquisitions of Distressed Firms Warrant Competition Scrutiny, IBBI (2020).
The paper examines the proposal to give automatic approval to resolution plans in which the mergers meet the threshold as per Competition laws. The paper studies the intersection of distressed M&A from Competition law aspect. While it is agreed that distressed M&A have various opportunities but it also raises concerns regarding the competition, it raises concerns whether such step would lead to anti-competitive outcomes as it may lead to reduced market competition. Overall, the paper explores the challenges that arises during the process of distress M&A as per IBC and the complexities while promoting competition while also facilitating the restructuring of distressed companies.
- Binoy J. Kattadiyil, Phoenix from Ashes: The Impact of IBC on The Distressed Mergers and Acquisitions Market, 9 Int’l J. Multidisciplinary Educ. Res. 7(8) (July 2020).
The paper explores the effects of IBC on distressed M&A in India, it highlights the role of IBC in providing a structured framework for resolving financial distress, thereby providing a quicker time-bound process and more efficient M&A transactions. The author highlights how IBC has sparked interest among the investors to invest in distressed assets. Thus, promoting corporate structuring. The study also reveals about the various issues especially due to delays, potential anti-competitive behaviour and ambiguities in the values of the assets that can make M&A less effective. The study stress on the need for balance approach in dealing with distress M&A.
- Corporate Finance & Restructuring, India’s M&A and Distressed Opportunity Landscape (2023).
The report provides a comprehensive analysis regarding M&A in the context of distressed assets in India. The report studies how the Indian market has faced significant increase if distressed M&A activities over the years. Mainly because of the changes brought through IBC. The emphasizes how IBC has created opportunities for inorganic growth process through M&A. The report also discusses lucrative opportunities that is mostly attached with risks associated especially due to asset quality and its financial viability. Overall, the report studies the complexities of the distressed M&A.
- Saloni Khaitan, The Case of Asset Acquisition: Are IBC-Led M&A Activities the Way Forward? SSRN (Mar. 25, 2023).
The paper examines the implication of IBC on asset acquisition strategies in India. The paper suggests that IBC has significantly changed the landscape of M&A and that it provides a structured framework ensuring effective asset acquisitions. The paper also does analyses of the effectives based on the past cases and its intersection with other laws prevailing in the time.
Statement of the Problem:
Research on “Role of IBC on distressed M&A” is crucial area due to the increasing distress M&A deals. Though IBC opened a pathway of opportunities, the primary problem lies is that it is important to understand the effectiveness of IBC in facilitation M&A of distressed assets. Though IBC provides a structured framework, there are have been challenges with respect to its effective implementation. IBC despite being a time-bound resolution process, is infamously known for its delays, haircuts and adequate value of assets that has impacted the distressed M&A transactions. Like in the case of Essar Steel and Jet Airways, the lack of clarity on the laws due to creditors rights, ambiguity regarding cross-border insolvency had led delays that had impacted the distressed M&A. Moreover, it also important to note that M&A is a very common approach in IBC which is why it is crucial to examine that the distressed M&A facilitated through IBC is not anti-competitive and that it does lead to concentration in the hands of few. The problem therefore, lies to determine how successfully IBC is managing the distressed assets while maintaining balance between the creditors’ rights and preserving market competition while also tackling the legal barriers.
Distressed Merger and Acquisitions:
The reason for the study is to understand the role of IBC in distressed M&A, for which it is important to understand the distressed assets, because IBC was mainly enacted to deal with such assets. It is the core of corporate resolution. The primary function of IBC is to resolve the distress assets of the company which is unable to meet its financial obligation. For this purpose, distress M&A transaction takes place. Distress assets are those assets which are under financial stress which includes non-performing assets (NPA), restructured assets etc. It means that the company is having difficulty dealing with its liabilities.[7] These are the financial instruments that is below the market value due to the financial instability or operational reasons. These assets are mostly the subject of insolvency, and are usually associated with high risks which is typically in default and also be considered as distressed debts.[8] However, IBC has given these distressed assets resolutions a legal structure[9] by allowing the distressed companies to be merged or acquired as going concern, this transaction can be called as distressed M&A. This form of M&A refers to the process of merging or acquiring the company with financial difficulties or distress such as insolvency. According to the Harvard Law School Forum on Corporate Governance[10] distressed acquisition is the acquisition of a company that is in financial distress or is facing operational challenges, that can also involve significant reduction of the price of assets that is below the market value. Therefore, such transactions are done mainly for restructuring purpose so that the assets could restore or regain its value.
From the meaning of the distressed M&A, we can understand that this form of transaction is different from the regular or general M&A transactions, mainly due to the financial condition of the assets and the circumstances involved. In general M&A, the companies undergo this process mainly for strategic goals such as market expansion, entry into new markets, globalisation or to grow its business, in this transaction both companies are willing undergo this process for their own benefits. Whereas, in distressed M&A, the sole reason is mainly to overcome the financial distress, and to avoid bankruptcy. For this the assets are often sold at a discounted price. Unlike regular M&A, the corporate debtor may be left with no option but to sell the assets in a time-bound due diligence manner. Such transactions are not initiated proactively but rather due to forced circumstances.[11] Therefore, distressed M&A can be said as a subset of M&A, having its own set of challenges and issues.[12]
Encouragement of IBC in Facilitating Distressed M&A:
It is a well-established fact that IBC was mainly to enacted to resolve the distressed assets, it can be said that IBC is mostly a method of merging and acquiring the distressed assets. As per Regulation 37, the resolution plan allows the corporate debtor to merge or acquire for the purpose of resolution process.[13] Previously, before IBC many investors were sceptical, in investing the distressed assets due to extreme risks involved. But due to IBC, the investors are now having confidence in investing these assets. It is because IBC, provides chance to the distressed companies to resolve instead of simply liquidating. Therefore, with a proper resolution plan, these distress assets can become profitable and become highly valuable in the market. M&A is one of the feasible CIRP and most of the corporate debtors go through such transactions in the hope of ending difficulties.
Like in the case of Bhushan Steel Case, now called as Tata Steel Bhushan Limited was acquired by Tata Steel Limited through IBC. Bhushan Steels was under distress and was unable to pay the debt to its creditors. After which the bankers filed before the NCLT, after which 72.65% of shares were acquired through Bamnipal Steel Limited, and the fund received was of INR 35,152.28 crores with a haircut of 37%.[14] This is how distressed M&A takes place through IBC where the distressed assets are usually acquired by the company. This case is considered to be one of the successful distress acquisitions through IBC.
Why to facilitate Distressed M&A as a Resolution Plan under IBC?
The enactment of IBC was to reduce the NPAs and to resolve the claims of creditors from the corporate debtor, who has defaulted the repayment of debt amount. One of the reasons why the corporate debtor is unable to repay the amount is because, the assets of the company are under financial distress, probably because the value of the assets have gone down to repay the loan amount. And in such cases liquidation of the corporate debtor can be detrimental and result in even more lower values of assets, which is why IBC encourages resolution plans in a manner through which there is maximum possible recovery for the creditors. Thus, one of the goals of CIRP is maximization of value of assets. For which M&A, can be considered to be one of viable options as such transaction would facilitate transfer of distressed assets to the efficient owners who with its resources and potential will preserve and increase the value of such assets. Thus, by acquiring the company, the buyer may also continue the operations of the assets and prevent the depletion of value of the assets.
Role of IBC in Distressed M&A
IBC plays an important role by facilitating distressed M&A by CIRP, distressed companies are sold to financially stronger entities through M&A, instead of just liquidating the company. This keeps the distressed company as a going concern, and keeps the operations in continuation, which helps in retaining the value of the assets, its reputation, enabling higher chances of recovery for the creditors. Like in the case of Essar Steel, ArcelorMittal acquired the Essar Steel as a part of CIRP, instead of letting the distress company go through liquidation which could have reduced the value of the assets, therefore preserving the value of the assets.
IBC provides a structural framework for distressed M&A a resolution plan, it provides a strict time-limit[15], within which M&A deals must be done, this is mainly for the purpose of maximization of the value of assets. The process also allows due diligence, which is considered be one of essential aspect in the M&A. Since M&A is a very big step, it important for the acquiring company or the investor to see the potential future after acquiring the company. By doing this, it boosts the confidence in the investors to invest in the distressed assets as they have already analysed the risks involved in this. Another role of IBC is that it also frees the acquirer from the liabilities, that is once the resolution plan is approved by the NCLT, the company will be discharged from its previous liabilities, providing clean slate to the acquirer. Therefore, reducing the risks involved for the acquirer to acquire the distressed company which would encourage the investors to invest in the distress assets. Moreover, the moratorium period that is passed through an order by AA also helps the in preserving and maintaining the value of the assets thus protecting assets for the purpose of M&A, so that the assets are not sold at a reduced value thus, protecting the interests of the potential acquires from acquiring reduced value assets during CIRP.
Further, since the assets are distressed in nature, the prices of this assets will be lower and would be available to the buyers at a discounted rate, which would attract several investors that would create a competitive environment, as there are several prospective buyers who would wish to acquire these assets, which would lead to competitive bidding, as the buyer can purchase at a relevantly lower price that it is, if it were a non-distressed asset. This would also increase the value of the assets, while also allowing the acquirer to acquire the assets at a reduced price. Thus, facilitating M&A activity in the distressed sector.
Challenges faced due to IBC
IBC, was enacted in the year 2016, and due to its recent enactment, it is still evolving, which has led to various uncertainties, that could affect M&A. Though IBC provides a structured framework, there are challenges regarding the implementation of IBC, in the practical world. One of the practical problems, is that IBC is a time-bound process, the statutory limit under IBC is 330 days, but then as per the data it showed that the average time taken for the approval of resolution plan is average of 761 days that is surpassing 2-years, thus causing significant delays[16]. These delays are mainly caused due to various reasons, such as prolonged litigation, challenges in asset valuation, disputes between creditors and debtors and mainly due to over burdening of NCLT. Further, the uncertainty due to the exceeding of the timeline affects the success of the distressed M&A.
As mentioned earlier, due diligence is one of the important aspects in M&A. The Supreme Court, even pointed out that it is the duty of investor to conduct due diligence before investing in the distressed company.[17] Which means the investor cannot accuse in case of the failure of the distress M&A. But the statutory time limit and due to restrain of time due to limited time for due diligence can pose as a challenge for the acquirers, as they may not be able to focus on all of the issues and may have to only focus on critical issues of M&A transactions.
Another challenge is that to proceed with distressed M&A, unlike general M&A, there are no warranties and indemnities, which means while investing in the distressed assets the buyers have no back-up plans which increases the risks entering into M&A.
As stated earlier, in IBC, there are open-ending, unsolved questions, and uncertainty. The legal challenges currently faced is the ambiguity in judicial interpretations of the provisions of the IBC. Since the law is new there are various aspects that is still being tested which has also led to prolonged litigation creates an uncertainty for the buyers involved in distressed M&A transactions. These challenges have made it less attractive for the acquirers to take interest in acquiring the distressed value, especially for those who are looking for faster returns in their investments.
Distressed M&A and Competition in the Market
As the IBC enables the acquisition of the distressed companies it is also important to ensure that such M&A does not result in anti-competitive practices. Usually, when a company is undergoing insolvency, the competitor firm often tries to buy the debtor, as a part of CIRP, which means if a financially stable company acquires a failing competitor, it can reduce competition in the market, which can lead to monopolistic control. But the question lies in what if the firm is failing? Usually, when the firm is in crisis it can also cause economic crisis. In such cases, saving the failing firm is given the importance over the competition of the market.
One of the challenges that are often faced is that the permission of CCI must be taken before initiating the distress M&A. Sec 31(4) of IBC, mandates that the such proposed M&A must be reviewed by the CCI, to check whether such acquisition would impact the market competition and change in control. But then this process can be time-consuming by the time CCI reviews the proposed plan, it can cause delay and may exceed timeline. Which is why the green-channeling must be extended to CIRP, where there would be automatic approval if the M&A meets the requirements of as per CCI. By doing so, it would reduce the burden on the applicants and that it would reduce the need to file multiple applications to be filed for the same distressed M&A transaction.
Suggestions
There are several suggestions that can be provided with regards, the Role of IBC in distressed M&A, to enhance the effectiveness of IBC in facilitating such transactions.
Firstly, as mentioned earlier the key challenges is the delay in the resolution process that affects the asset value and then distressed M&A, despite the provisions mentioning the strict timelines, the sector is lagging behind with regards to implementation. And to achieve this, the government should increase the resources and manpower to the NCLT, and introduced stricter penalties for the parties causing unnecessary delays. Since the main aim is to increase the value of the assets, so it is necessary to have valuation framework should be developed to create accurate assessments of distressed companies’ assets. To create proper cross-border insolvency framework, though IBC talks about cross-border insolvency, it lacks proper framework. This makes it difficult for international acquires to confidently acquire Indian distressed assets. The lack of proper framework can complicate the distressed M&A transactions where international companies are involved. Since the assets in the M&A are distressed in nature, due to which it becomes difficult to find acquirers to invest in these assets due to the involvement of high risks. Which is why the investors must be encouraged to participate in distressed M&A transactions through IBC which would improve the recovery rates. this can be done by providing tax incentives, subsidies for the investors in the cases of distressed acquisitions. And with the digitalised world, there can be digital performing where the distressed assets can be put for the sale for the purpose of M&A on that website. These are some of the suggestions that will help in facilitating distressed M&A transactions in a more effective and in efficient manner, thus, improving the overall process of M&A transactions.
Conclusion
Role of IBC in distressed M&A has provided various opportunities, with IBC enabling M&A has improved the condition of distress M&A in the market. One of the noticeable impacts of distressed M&A through IBC is market consolidation, because the distressed M&A are acquired by the strong players, which results to more dominant firms in the market. Despite the fact that it can reduce the competition it can lead to better operational efficiency. Which can also facilitate better allocation of the resources of the inefficient company by the more efficient acquirer. As the acquirer will ensure that the distressed assets are put to better use by which the value of the assets improve and therefore preventing unnecessary liquidation. And this helps in reviving the distressed company which will help in maintaining the market stability and prevent negative impact on the economy. The distressed M&A will help stabilize the market by ensuring the continuation of the operations, restoring the value of the assets, recovery for the creditors and an investment at discount for the acquirer. By doing this will also save numerous jobs of the employees who would have rather lost their jobs if the company was to get liquidated. With the role of IBC in distressed M&A, has helped in increasing and boosting the confidence of the investors to invest in such assets. And moreover, the creditors can also have reassurance that their credit will be recovered, further it will also attract foreign investments to the country as the prices of the assets will be relatively cheaper.
Therefore, it can be noticed that distressed M&A through IBC has a favourable potential in the market and can create various opportunities for the acquirers. Where one side the debtor is able to recover from its financial liabilities, on the other hand it will also provide various opportunities such as market entry, expansion of business, reduced tax liabilities for the acquirers.
With the increase of competition, where there are many businesses can come under distress, with increase in distress assets, it can be anticipated that the distressed M&A shall increase more in the future. And that such M&A transaction shall become a crucial tool for dealing the financially distressed assets. Which is why it is recommended to the court and the government to address and overcome the challenges to have effective framework and mechanism so that the transaction could be certain and predictable making the process easier and simpler.
Bibilography
Statutes
- Insolvency and Bankruptcy Code, 2016
- IBBI (Insolvency Resolution Process for Corporate Persons) Regulations, 2016
Internet Sources
- Spotlight Asia: Kroll M&A Newsletter (Oct 2018) https://www.kroll.com/-/media/kroll/pdfs/publications/spotlight-asia-kroll-ma-ocotber-2018.ashx
- IBC Resolution Approval Time Surpasses two years, Bus Line (New Delhi) (15 Aug 2024) (9:25) https://www.thehindubusinessline.com/economy/ibc-resolution-approval-time-surpasses-two-years/article68529455.ece
- Surya Sarathi Ray, ‘NCLAT rejects Edelweiss pleas challenging Synergy resolution plan’ Financial express (India, 15 December 2018)
- Ricky Mason& Amy Wolf, Distressed M&A Rules of the Road (23 May,2019) https://corpgov.law.harvard.edu/2019/05/23/distressed-ma-the-rules-of-the-road/
- Distressed asset investments in India you should invest, July 2018 https://www.avendus.com/india/avendus-eye/distressed-asset-investments-in-india-should-you-invest
Journals
- Arjun Khanna, The Relationship Between Mergers and Acquisitions and the Insolvency and Bankruptcy Code (IBC) in India: A Critical Analysis, 5 Indian J. Law & Legal Research 1 (2023).
- P. Ram Mohan & Vishakha Raj, Merger Control for IRPs: Do Acquisitions of Distressed Firms Warrant Competition Scrutiny, IBBI (2020).
- Corporate Finance & Restructuring, India’s M&A and Distressed Opportunity Landscape (2023).
References:
[1] Spotlight Asia: Kroll M&A Newsletter (Oct 2018) https://www.kroll.com/-/media/kroll/pdfs/publications/spotlight-asia-kroll-ma-ocotber-2018.ashx
[2] Regulation 37 of IBBI (Insolvency Resolution Process for Corporate Persons) Regulations, 2016
[3] Spotlight Asia: Kroll M&A Newsletter (Oct 2018) https://www.kroll.com/-/media/kroll/pdfs/publications/spotlight-asia-kroll-ma-ocotber-2018.ashx
[4] ArcelorMittal and Nippon Steel Complete Joint Acquisition of Essar Steel in India (Dec 16, 2019), https://www.nipponsteel.com/common/secure/en/news/20191216_400.pdf
[5] Pritam Sangwan, Tata Steel acquires Bhushan through IBC route, (10 June, 2019) https://mnacritique.mergersindia.com/tata-steel-acquires-bhushan-through-ibc-route/
[6] Arjun Khanna, The Relationship Between Mergers and Acquisitions and the Insolvency and Bankruptcy Code (IBC) in India: A Critical Analysis, 5 Indian J. Law & Legal Research 1 (2023).
[7] Ricky Mason& Amy Wolf, Distressed M&A Rules of the Road (23 May,2019) https://corpgov.law.harvard.edu/2019/05/23/distressed-ma-the-rules-of-the-road/
[8] Distressed Asset Definition, https://www.lawinsider.com/dictionary/distressed-asset
[9]Distressed asset investments in India you should invest, July 2018 https://www.avendus.com/india/avendus-eye/distressed-asset-investments-in-india-should-you-invest
[10] Ricky Mason& Amy Wolf, Distressed M&A Rules of the Road (23 May,2019) https://corpgov.law.harvard.edu/2019/05/23/distressed-ma-the-rules-of-the-road/
[11] Martin Tasma & Henning Block, Distressed M&A: Same same but different, (2nd Dec 2021). https://hengeler-news.com/en/articles/distressed-m-and-a-same-same-but-different
[12] Lane Neave, The what, how and why of distressed M&A https://www.lexology.com/library/detail.aspx?g=1b7f5d1a-ad2a-4ead-aa98-9e800d035544
[13] Regulation 37 of IBBI (Insolvency Resolution Process for Corporate Persons) Regulations, 2016
[14] Pritam Sangwan, Tata Steel acquires Bhushan through IBC route, (10 June, 2019) https://mnacritique.mergersindia.com/tata-steel-acquires-bhushan-through-ibc-route/
[16] IBC Resolution Approval Time Surpasses two years, Bus Line (New Delhi) (15 Aug 2024) (9:25) https://www.thehindubusinessline.com/economy/ibc-resolution-approval-time-surpasses-two-years/article68529455.ece
[17] Surya Sarathi Ray, ‘NCLAT rejects Edelweiss pleas challenging Synergy resolution plan’ Financial express (India, 15 December 2018)
