(Article) Bad Loans in Infrastructure Sector and Ordinance on New NPA Resolution Policy
As per the S&P Global Ratings, Indian banks’ stressed assets are likely to increase to 15% of total loans by March end, 2018. Top 50 bad loans of corporates engages in core and infrastructure sectors have been identified by Reserve Bank of India (RBI) who’s over dues are as high as ₹4.5 lakh crore forming 85 percent of the total bad loans of public sector banks. Recognizing this growing concern of the banking industry and recovery measures to be undertaken on a war footing, the Government has recently come out with an ordinance on NPA Loan Policy Resolution. The ordinance aims at amending two laws namely, the Banking Regulation (BR) Act,
1949 to tackle the menace of massive stressed assets in the banking system granting more specific powers to the RBI and the Prevention of Corruption (PCA) Act ,1988 to encourage bankers to take commercially bold decisions, especially on haircuts on toxic assets, without fear of subsequent prosecution. As follow up of the ordinance, the RBI has issued a directive bringing certain changes to the existing regulations on dealing with stressed assets, besides planning to reconstitute the over sight committees and exploring the feasibility of rating assignments being determined by itself. Many more initiatives are expected from RBI to resolve top 35-40 stressed assets. While the ordinance is far superior to earlier initiatives to resolve stressed assets in terms of its unique provisions and proposed arrangements proposed by RBI and Government, its success in implementation
depends on coordination among all stakeholders including banks, Asset Reconstruction Companies, rating agencies, Insolvency and Bankruptcy Board of India and PE firms. In this context, it is necessary to develop a fair understanding of the ordinance by all stakeholders dealing resolution of corporate stressed assets in core and infrastructure sectors. Towards this end, the present article makes an overview of the ordinance to deal with mega bad loans.
Gross Non- Performing Assets (NPAs) of just 37 listed banks were as high as ₹ 7.1 lakh crores as at March end, 2017 as against ₹5.7 lakh crores in the last year (1). About 50 top stressed corporate accounts, mostly engaged in core and infrastructure sectors, have been identified by Reserve Bank of India (RBI) as being under the watch list of the Government. The total loan amount due from these top stressed assets is around ₹4.5 lakh crore which is almost
85 percent of the total bad loans of public sector banks(PSBs). Hence, both RBI and Government have taken several measures since 2002, starting with setting up of Asset Reconstruction Companies (ARCs) for purchase of bad loans,making amendments in Corporate Debt Restructuring(CDR) mechanism after accepting recommendations of the Mahapatra Working Group, installing a framework for monitoring of Special Mention Accounts (SMAs), coming out with Flexible Restructuring of Long Term Project (5/25) scheme, introducing Special Debt Restructuring (SDR) scheme, initiating Scheme for Sustainable Structuring of Stressed Assets (s4a), enacting Insolvency Bankruptcy Code (IBC) etc. Despite these and many other measures, the level of NPAs in corporate and infrastructure sectors is now unprecedented. Appreciating this growing concern of banks, the Government has now come out with an Ordinance on NPA Policy Resolution which seems to be an effective tool by granting more powers to RBI and also building up confidence in the minds of bankers in taking decisions on huge write off/ write downs as part of resolution of mega problematic projects. Although this is considered to be a onetime exercise to resolve mega top stressed loan assets, the Ordinance is expected to create a conducive environment for further lending to other corporate and infrastructure projects. In view of the new era to begin with the introduction of Ordinance, it is necessary for bankers at this stage to develop a fair understanding of the new Ordinance by going through its historical background, initiatives taken by RBI and Government during the recent past, features and likely impact of the Ordinance. Towards the end, the present article makes an overview and offers suggestions for effective implementation of the Ordinance. To begin with, let us study the need for introduction of Ordinance.
Mounting Bank Over dues from Corporates - Historical Background:
For better understanding of non-performing assets (NPAs) resolution of corporate and infrastructure projects in India, it is necessary to study the origin of NPA problem for which reference to Economic Survey 2016-17 report is more appropriate, sharing certain interesting piece of information.The origin of the NPA problem arose when decisions taken by corporates, mostly engaged in core (industrial and service) and infrastructure sectors, based on a set of assumptions went wrong during the mid-2000s. To elaborate, during that period, economies all over the world were maintaining high GDP growth which was around 9-10 percent per annum and, India was no exception to this. Consequently, corporate profitability in India was very much impressive. So, the corporates started hiring labour aggressively for expansion and diversification of business activities which in turn sent wages soaring. Encouraged from high GDP growth, corporates also launched new and mega projects particularly in infrastructure-related areas such as power generation & steel, and telecoms, setting off the biggest investment boom in the country’s history. In the span of just three years running from 2004-05 to 2008-09, the amount of non-food bank credit was doubled. It was also observed that corporates were highly debt burdened to take advantage of anticipated growing business opportunities. But assumptions made for forecasting higher growth did not materialize. As corporates were taking on more risk, things started to go wrong. Cost soared far above the budgeted level, as securing land and environmental clearances for infrastructure projects proved much more difficult and time consuming than expected. At the same time, budgeted revenue collapsed after the Global Financial Crisis (GFC); projects that had been built around the assumption that growth would continue at double-digit levels were suddenly confronted with growth rates half that level. As if these problems were not enough, financing costs also increased sharply. Corporates that borrowed domestically suffered when the Reserve Bank of India (RBI) increased interest rates to contain double digit inflation. Further, the corporates that had borrowed abroad when the rupee was trading around ₹40/dollar were hit hard when the rupee depreciated, forcing them to repay their debts at exchange rate closer to ₹60-70/dollar. Thus, high direct cost, low revenue and increasing financing cost squeezed corporate cash flow, quickly leading to debt servicing problems and thereby banks witnessing high level of NPAs in corporate sector(2).To resolve NPA problems relating to corporate and infrastructure projects , both Reserve Bank of India ( RBI) and Government took initiatives, calling for a review.
Initiatives taken by RBI and Government to Resolve Bad Loans from Corporates - A Review:
To start with, the RBI introduced CDR mechanism in 2002 to give corporates more time to repay. To elaborate, debt restructuring refers to reallocation of resources or change in the terms of past and future loans involving reduction in interest rates, waiver of penal charges, re-scheduling of unpaid loan installments, conversion of irregularity in cash credit into working capital term loan (WCTL), sanctioning of fresh loan etc. For infrastructure projects, additional concessions were offered in terms of reduction in provisions to be made. Thus, CDR mechanism is an adjustment made by both the debtor and the creditor to smooth out temporary difficulties in loan repayment by entering into Debtor Creditors Agreement (DCA). It is also an arrangement among the creditors to assist cash troubled corporates by entering into Inter Creditors Agreement (ICA). Appreciating relevance of CDR mechanism, the RBI made changes in it in the wake of the Mahapatra Working Group recommendations. Thus, if the CDR process is to be judged from an independent perspective, it is a beneficial process which endeavors to help viable corporates to come out of financial crisis which may be faced by them due to several external factors and also creditors to recover their dues by debt restructuring. Though the CDR mechanism is well designed and amended from time to time, the financial position of the stressed corporates continued to deteriorate despite restructuring. Hardly 15 percent of corporates came out of CDR successfully (3). Therefore, the RBI thought of other measures to resolve NPAs. In this context, in the same year, ARCs were allowed to be set up in the private sector under SARFAESI Act, hoping that they would buy up the bad loans of the commercial banks. In that way, there could be an efficient division of labour, as banks could resume focusing on their traditional deposit-and-loan operations. This strategy, however, has had only limited success. By now, as many as 16 ARCs have been created, but they have solved only a small portion of the problem, buying up only about 5 percent of total NPAs at book value (Economic Survey 2016-17). The problem is that ARCs have found it difficult to recover much from the debtors. Hence, they have only been able to offer low prices to banks. Further, it is disheartening to note that just half of the SRs issued were redeemed completely by ARCs, indicating, liquidity problems of ARCs on account mismatch in cash flows due to slow loan recovery(4). While efforts were on to resolve bad loan, the RBI paid attention to arresting slippage in loan asset quality and undertake timely preventive action by strengthening credit monitoring system in banks. In February 2014, the RBI came out with a Framework to monitor SMAs more effectively (5). Under the Framework, Standard Assets are classified into three categories : SMA-0, SMA-1 and SMA-2 based on the period of default of up to 30 days, 31-60 days and 61-90 days respectively. Under the Framework. lenders are asked to form Joint Lenders Forum (JLF) and prepare Corrective Action Plan (CAP) for SMA-2 accounts with a total debt of more than `100 crores. For restructuring of debt of more than `500 crores, Technical Evaluation Viability (TEV) study should be prepared by professional agencies identified by Indian Banks association (IBA) and approved by JLF creditors with super majority of more than 75 percent of value (total debt)and 60 percent of creditors in number. Based on reduction in slippage in the asset quality during the recent past, this Framework has come to stay and is found to be a useful tool for monitoring of SMAs. But the age old high value NPAs from corporates continued to remain in the books of banks due to difficulties in resolving them through legal measures. Therefore in July 2014, the RBI introduced 5/25 scheme which involves flexible structuring of long term project loans to infrastructure and core-sector industries (6). Under the scheme,
banks can extend a loan for a period of 20-25 years in such a way that it matches with the cash flows. The term 5/25 is used since the loan, with maturity up to 25 years, would be subject to refinancing every 5 years. However, both lenders and the borrowers have to adhere to certain conditions which were found to be difficult to fulfill. Consequently, there is hesitancy on the part of banks to associate with such long term projects due to their perception of high credit risk.
As a next step towards strengthening the NPA resolution, in June 2015, the RBI introduced SDR to bypass legal hurdles faced by the bank while taking over a defaulting company by converting part/ full of its debt into equity to acquire management control and finding a new buyer for equity holding within 18 months. However, if the bank does not get the new buyer during the period, the asset has to be classified as an NPA(7). After introduction of this scheme in few cases, very soon banks realized that the period of 18 months was too short to comply with the requirements. Further for resolution of large corporate accounts which are facing severe financial difficulties, it also requires coordinated deep financial restructuring which calls for a substantial write-down of debt and/or making large provisions towards bank sacrifice. Hence, banks made a representation to RBI for allowing more time to write down the debt and make the required provisions in cases of resolution of large core and infrastructure projects, which was not considered. As a result of this, while two dozen cases were entered into negotiations under SDR, only two cases have actually been concluded as of end-December 2016 (Economic Survey 2016- 17). Appreciating difficulties faced by banks in implementing in SDR with special reference to acquiring management control, in June 2016 the RBI came out with yet another measure i.e. s4a to facilitate the resolution of large accounts (8). For being eligible for resolution of large accounts under the scheme, certain conditions need to be fulfilled which include: (i) The project must have commenced commercial operations.(ii) The aggregate exposure should be more than ₹500 crores. (iii)The debt should meet the requirement of test of sustainability of debt i.e. a portion of total debt can be serviced over the same tenor as that of the existing facilities even if the future cash flows remain at their current level and, (iv) The sustainable debt should not be less than 50 percent of current funded liabilities. Under the Resolution Plan, it is not necessary to change the management. Regarding formalities, the JLF shall, after an independent TEV, bifurcate the total bank debt of the borrower into two parts: Part A debt ( subordinated debt) and Part B debt i.e. total debt minus Part A debt. For Part A debt, there will be no fresh moratorium granted on interest or principal repayment and extension of the repayment schedule or reduction in the interest rate. Part B debt shall be converted into equity/redeemable cumulative optionally convertible preference shares, the fair value needs to be calculated by following the prescribed methodologies. JLF shall engage the services of credible professional agencies to conduct the TEV and prepare the resolution plan. The resolution plan should be agreed upon by a super majority i.e. minimum of 75 percent of lenders by value and 60 percent of lenders by number. At individual bank level, the bifurcation into Part A debt and Part B debt shall be in the proportion of Part A debt to Part B debt at the aggregate level. Overseeing Committees (OCs), comprising eminent persons were also constituted by Indian Banks Association (IBA) in consultation with RBI. The resolution plan shall be submitted by the JLF to the OC which will review the processes involved in preparation of the resolution plan etc. for reasonableness and adherence to the provisions of these guidelines, and opine on it. The success of s4a , however, has been limited due to several reasons and one of them is delay in decision making by JLF due to failure to fulfill the super majority criterions for approval of Corrective Action Plan ( CAP) by lenders . Hence, the RBI subsequently reduced the minimum stake of creditors for super majority from 75 percent to 60 percent by value and from 60 percent to 50 percent by number (9). Under s4a, hardly only one case been cleared by National Company Law Tribunal (Economic Survey 2016-17). Hence to facilitate the process NPA resolution, it was felt necessary to undertake a more serious measure to enact a new law..
Insolvency and Bankruptcy Code was enacted in 2016 since there was no single law that deals with insolvency and bankruptcy in India for individuals and corporates. A timeline of 180 days which can be extended by another 90 days, in all 270 days, by the adjudicating authority in exceptional cases, for dealing with applications of insolvency resolution. The IBC envisages a competitive industry of insolvency professionals, insolvency professional agencies and information utilities. These will be regulated by an insolvency regulator namely, Insolvency and Bankruptcy Board of India (IBBI), to regulate insolvency professionals and agencies (9). Regarding the process is concerned, during the insolvency resolution period of 180/270 days, the management control will be passed on to a resolution professional who will come up with an insolvency resolution plan which has to be approved by lenders with super majority and also by the adjudicating authority. If rejected, the adjudicating authority will order for liquidation. Under the OBC , Debt Recovery Tribunal (DRT) and National Company Law Tribunal (NCLT) are deployed as the adjudicating authority. While NCLT will deal with rehabilitation and restructuring matters, DRT will look after loan recovery if not found feasible for rehabilitation and restructuring. About the process to be adopted during the period of 180/270 days, the regulatory authority appoints the administrator to take the control of the assets and management of the firm and prepare a resolution proposal about information asymmetry between creditors and debtors about the financial status of the company, it is proposed to set up an industry of information utilities so that decision on turnaround strategy or bankruptcy shall be taken up quickly. It is also proposed to strengthen DRTs since they are already overburdened with insolvency cases by increasing their number. Further, secured creditors with more than 75 percent share in total debt will be allowed to file an application for the rescue of the company at a sufficiently early stage, rather than wait for the same to have defaulted on 50 per cent of its outstanding debt, as currently provided for in the Companies Act, 2013. Even unsecured creditors representing 25 per cent of the total debt shall be allowed to initiate rescue proceedings against the debtor company. Further, workers will get last one year’s salary first and then payments shall be made to secured lenders, followed by others. Lastly, all existing laws that deal with insolvency of registered entities will be removed and replaced by this single Code. Since the regulatory authority has just begun its functioning, NPA resolution of projects in core and infrastructure sectors under IBC can not be expected in a big way in the near future. Hence, the Government thought it to appropriate to amend existing Debt Recovery Laws, while execution under IBC will continue.
Debt Recovery Laws requiring amendments include: Securitization and Reconstruction of Financial Assets and Enforcement of Security Interest ( SARFAESI) Act 2002, Recovery of Debts Due to Banks and Financial Institutions (RDDBFI) Act- 1993, Indian Stamp Duty Act- 1899 and Depositories Act- 1996. In May 2016, the Enforcement of Security Interest and Recovery of Debt Laws and Miscellaneous Provisions (Amendment) Bill, 2016 was cleared by the Parliament to amend Debt Recovery Laws (11) Under SARFAESI Act, RBI will conduct inspection of the ARCs annually. Central Registry will record details of all secured assets to avoid multiple finance against the same property. More importantly, priority will be given to bank dues over all other debts and claims
Lastly, foreign investor shall sponsor an ARC after observing ‘fit and proper’ norms of RBI. All these amendments are expected to ensure more recovery under the Act. Under RDDBFI Act, time for filing an appeal to the Appellate Debt Recovery Tribunal (DRAT) is cut from 45 days to 30 days. Similarly for appeal, the deposit amount of 50% of bank dues by the aggrieved borrower is cut down to 25%. These would reduce the time involved in disposal of DRT cases. Regarding Indian Stamp Act, sale of assets to ARCs is exempted for payment of stamp duties which was one of major constraints in promoting business of ARCs.. Regarding miscellaneous amendments , banks shall provide further time to the borrowers to pay dues if 25% of the same is paid. Protection will be provided to any officer of banks , RBI, Central Registry etc. for action taken in good faith.
To sum up, despite various initiatives taken , banks have continued to witness a very high level of stressed assets particularly in core and infrastructure sectors .The problem is simply that initiatives like SDR, s4a and IBC are new, and financial restructuring negotiations under these mechanisms inevitably take some time. But the country cannot wait till then since over dues from the corporates are mounting. Hence, the Government thought it inevitable to come out with an Ordinance on New NPA Resolution Policy in May 2017 to resolve the age old high value corporate NPAs once for all.
Features of Ordinance :
The Ordinance aims at amending two laws namely, the Banking Regulation (BR) Act, 1949 to tackle the menace of massive stressed assets in the banking system granting more specific powers to the RBI and the Prevention of Corruption (PCA) Act ,1988 to encourage bankers to take commercially bold decisions, especially on haircuts on toxic assets, without fear of subsequent prosecution(12). To state specific amendments to BR Act, a new Section i.e.
35AAis inserted to empower the government to authorize the RBI to issue directions to banks as it deems fit to initiate insolvency process in case of a default under the provisions of the IBC . Further, another section i.e. Section 35AB is included in the Act to grant power to the RBI to specify one or more authorities or committees (called as Oversight Committees- OCs) to advise banks on resolution of stressed assets. These OCs will be able to help banks in decision-making and also to monitor the progress in resolving stressed assets (gross non-performing assets and restructured standard advances).Thus, the central bank could monitor specific cases, especially the more difficult ones in core and infrastructure sectors , even when the resolution process through the IBC is under way. Bankers could also pursue the IBC mechanism more vigorously if other mechanisms to deal with the NPA issue does not succeed. Immediately upon the promulgation of the Ordinance on May 22, 2017, the Reserve Bank issued a directive bringing certain changes to the existing regulations on dealing with stressed assets. It was clarified that CAP also includes flexible restructuring, SDR and s4a. With a view to facilitate decision making in the JLF, the consent required for approval of a proposal is now changed to 60 percent by value instead of 75 percent earlier, while keeping that number at 50 percent. Banks who were in the minority on the proposal approved by the JLF are required to either exit by complying with the substitution rules within the stipulated time or adhere to the decision of the JLF. Participating banks have been mandated to implement the decision of JLF without any additional conditionality. Lastly, the Boards of banks were advised to empower their executives to implement JLF decisions without further reference to them. The RBI has made clear to the banks that non-adherence would invite enforcement actions. It has also been decided to reconstitute the OC under the aegis of the RBI and enlarge it to include more members so that the OC can constitute requisite benches to deal with the volume of cases referred to it. While the current members will continue in the reconstituted OC, names of a few more will be announced soon. The RBI is planning to expand the scope of cases to be referred to the OC beyond those under s4a as required currently. It is also working on a framework to facilitate an objective and consistent decision making process with regard to cases that may be determined for reference for resolution under the IBC. The RBI has already sought information on the current status of the large stressed assets from the banks. It would also be constituting a Committee comprising majorly of its independent Board Members to advise it in this matter. The current guidelines on restructuring are under examination for such modifications as may be necessary to resolve the large stressed assets in the banking system in a value optimizing manner. This envisages an important role for the credit rating agencies in the scheme of things and, with a view to preventing rating-shopping or any conflict of interest, is exploring the feasibility of rating assignments being determined by the RBI itself and paid for from a fund to be created out of contribution from the banks and the central bank. More importantly, this calls for coordination with and cooperation from several stakeholders including banks, ARCs, rating agencies, IBBI and PE firms. In this regard, the RBI will make further arrangements.
Likely Impact of Ordinance:
With the introduction of the Ordinance, banks would be able to identify NPAs early and initiate loan recovery proceedings without waiting for an account to be formally classified as non-performing. Under the present RBI prudential guidelines on asset classification, an advance becomes non- performing when interest or installment of principal remains overdue for more than 9o days. But under the Ordinance, the default will be considered as per bankruptcy law, which means if the payment is missed, it turns into a default the next day itself.
Further, it would enhance transparency in NPA resolution of high value NPAs since RBI and OCs will be directly engaged in NPA resolution and monitoring the performance of JLF. This would also improve the quality of NPA resolution which will be performed the guidance of RBI and OCs by ensuring collective and coordinated efforts. In view of the long drawn process involved in NPA resolution particularly in core and infrastructure sectors, it is unlikely that the recovery mechanism will improve substantially this year only, but credit growth will certainly pick up due to better quality NPA resolution. Similarly, this pick up in credit growth would bring down the share of bad loans as a percentage of total advances. Further, it is quite likely that the next fiscal i.e. 2018 would be much better in terms of asset quality than the current fiscal 2017. It seems that the government is all out war against NPAs in core and infrastructure sectors which will help in cleaning the balance sheet of state- owned banks and expedite fund raising via markets to meet the global Basel III capital adequacy norms. As part of NPA resolution plan, the RBI proposes to involve rating agencies to rate assets charged and assess viability of the project. It is also exploring the feasibility of rating assignments being determined by the itself and these rating agencies would be paid from a fund to be created out of contributions from the banks and the RBI. With the central bank paying for the rating engagement, it would give space for independent opinion to avoid problems in information disclosure by the company. Thus, the Ordinance would produce many more benefits being a very effective mechanism for NPA resolution in core and infrastructure sectors. .
With the RBI directly is coming into the picture in NPA resolution besides being a regulator, it will also have to play a role of a banker to take decisions on commercial considerations. Similarly, the success of NPA resolution will depend on the selection of the members of the OCs, based on professional expertise and sufficient experience in commercial banking with special reference to sanction and loan recovery of mega and infrastructure projects. In the wake of resolving high value NPAs, it is necessary for banks and also for RBI to set a target for loan recovery from mega NPA borrowers for each of the next 3-5 years so that it is possible to review achievements periodically. Further, the time consumed in making NPA resolution decisions relating to IBC is critical because if it is done in a piecemeal fashion the measures considered for resolution may not produce desired results. Hence, timelines need to be fixed for processes under the bankruptcy law to be competed timely, besides ensuring coordinated efforts. It is also important that the back-end infrastructure should be in place. In this regard, RBI should have enough manpower to handle matters concerning NPA resolution under the Ordinance. Similarly, the legal system should be well equipped to take on this challenge by ensuring early disposal of cases. If we are targeting only the top 35-40 defaulters in core and infrastructure sectors , then the job may be easier. But if all mega NPAs to be addressed, a planned approach is called for and, implementation should be done in a true spirit by involving all stakeholders.
For RBI, the Ordinance is an additional tool available to take a targeted approach and deal with the top 35-40 non-performing assets in core and infrastructure projects that can be resolved quickly. It can break the deadlock and get the banking system to gain further by resolving bad loans. The OC can use its powers to restart the process of NPA resolution more professionally with due respect to compliance and get rid of the old problem when bankers were afraid of investigations against them in deciding huge debt write off / write down. The government’s approach towards resolving the issue of NPAs has been remarkable and the various schemes brought out are part of the fine-tuning mechanism where lessons of the failure of the existing mechanisms have been improvised. The present dispensation appears to have reached the so-called last mile and definitely looks superior to the other attempts. But the execution would have to be planned meticulously to move towards a successful conclusion. The RBI is also working on a framework to facilitate an objective and consistent decision making process for cases that may be determined for reference for resolution under the IBC. As per news reports, the Reserve Bank has already sought information on the current status of the large stressed assets from the banks. It would also be constituting a committee comprised majorly of its independent board members to advise on the subject(13). The success in implementation of the Ordinance would require coordination among all stakeholders including banks, ARCs, rating agencies, IBBI and PE firms. Thus, the challenge is to effectively implement the Ordinance . Quite likely, we have a long way to go in this regard.
1. Economic Times, May 30, 2017.
2. Address by Dr K C Chakrabarty, Deputy Governor, Reserve Bank of India, titled “Corporate Debt Restructuring- Issues and Way Forward” at the Corporate Debt Restructuring Conference 2012, Mumbai, dated 11 August 2012
3. CDR Web-site.
4. Report on Trend and Progress of Banking in India 2013-14, Reserve Bank of India.
5. Framework for Revitalizing Distressed Assets in the Economy, RBI Circular February 26, 2015.
6. Flexible Structuring of Long Term Project Loans to Infrastructure and Core industries, RBI Circular, July 15, 2014.
7. Strategic Debt Restructuring Scheme, RBI Circular, June 08, 2015.
8. Scheme for Sustainable Structuring of Stressed Assets, RBI Circular, June 13, 2016.
9. Timelines for Stressed Assets Resolution, RBI Circular, May 05, 2017.
10. Insolvency and bankruptcy Bill, Tabled in Parliament on December 15, 2015
11. The Enforcement of Security Interest and Recovery of Debts Laws and Miscellaneous Provisions (Amendment) Bill, Tabled in Parliament on May 11,2016.
12. Financial Express, May 05, 2017.
13. Financial Express, May 31, 2017.