TITLE: MERGERS AND ACQUISITIONS IN INDIAN TELECOM SECTOR:

AN ANALYSIS

1.1 INTRODUCTION

M&A have likewise been determined by the advancement of new

telecommunication innovations. The deregulation of the business entices telecom
firms to give packaged items and administrations, particularly with the continuous
union of the telecom and cable businesses. The acquisition of extra items and
administrations has subsequently turned into a productive move for telecom suppliers.
M&A in telecom Industry are subject to various statutory guidelines and Industry
specific provisions e.g. Companies Act, 1956; Income Tax Act, 1961; Competition
Act, 2002; MRTP Act; Indian Telegraph Act; FEMA Act; FEMA regulations; SEBI
Takeover regulation; etc.1

The number of mergers and acquisitions in Telecom Sector has been

increasing fundamentally. Telecommunications industry is a standout amongst the
most profitable and quickly creating businesses on the planet and it is viewed as an
irreplaceable segment of the overall utility and services division. Telecommunication
industry manages different manifestations of correspondence mediums, for instance
mobile phones, fixed line phones, as well as Internet and broadband services.

As of now, a large number of mergers and acquisitions in Telecom Sector are

happening all through the world. The point behind such mergers is to achieve
competitive profits in the telecommunications business.

1.2 STATEMENT OF PROBLEM:

The Telecom Industry is currently providing ample lot of opportunities for

M&A. India, considered as one of the fastest growing economies have paved the way
for easier and successful M&A in Telecom Industry. Foreign investors and telecom
majors who were keenly interested in the much awaited M&A policy for Telecom
sector are disappointed by it as it has made it tougher for the bigger telco companies
to merge among themselves as stipulation is that the merged entity cannot have more
than 50% market share in terms of subscribers and revenue in any of the 22 circles,

Sanjoy Banka, ‘Mergers and Acquisitions in Telecom Sector: A Study [2006] The Chartered
1

Accountant 1, 1
while new entrants may not have too many exit options as new guidelines provide for
lock-in period of 3 years in which they have to hold the acquisitions.

1.3 OBJECTIVE

The objective of this research is to help in study of new M&A guidelines so

formulated for the telecom sector which will help in noticing the positive and negative
aspects of it. It may help in notifying the alterations needed. All the principles of the
said M&A guidelines would be explained and discussed in a very detailed way which
will help in understanding every inch of the guidelines. After such exhaustive
assessment of the same will lead to point out all the pros and cons of the said M&A
guidelines which will construct a way for formulating notions for the improvement of
the escape clause which are present in the guidelines.

1.4 HYPOTHESIS:

The new Mergers and Acquisition Guidelines formulated for the telecom
sector is favourable for Indian Telecom Industry.

1.5 RESEARCH QUESTIONS

• How the new M&A guidelines will help the telecom sector to grow?

• Whether all the guidelines formulated and approved by the government has a
positive approach towards telecom industry?

• Whether the new policy will attract the foreign investors towards Indian
telecom market?

• Is there clarity over the merger and acquisition guidelines, and in particular,
spectrum acquisitions?

• Which are the Mergers and Acquisitions of various telcos?

• What changes can prove to be useful to eliminate the loopholes in the

guidelines?

1.6 RESEARCH METHODOLOGY

The researcher has used the doctrinal method for conducting the research on the
above topic. The researcher has majorly used the secondary source for conducting the

2
research such as books, journals, acts and new articles. The data that have been used
in the research will be based on authorised websites.

1.8 LITERATURE REVIEW:

A. The first article reviewed is titled “Mergers and Acquisition in India” through
which one learns of the history of the concept of the mergers and acquisitions
in India. It has been noticed the progressive graph of the corporate world due
to the usage of the idea of the mergers and acquisitions in India. In this article,
the statistics are been provided of the progress of the concept of M&A policy.
(available at http://www.mergersandacquisitions.in/merger-and-acquisition-in-
india.htm)
B. The next piece of research is from a research based law firm’s in-depth
analysis about the concept and emergence of mergers and acquisitions, the
condition of the corporate world before and after the entrance of this idea in
India. The research paper disseminates knowledge about the types of mergers,
demergers, procedure of mergers and acquisitions, takeover code, and its
relation with the securities law. (available at
http://www.nishithdesai.com/fileadmin/user_upload/pdfs/Research%20Papers/
Mergers%20%26%20Acquisitions%20in%20India.pdf)
C. Various newspaper clippings have then been put together in this guidelines
analysis about the approval and announcement of the new M&A guidelines
for the telecom sector by Kapil Sibal which is going to prove very beneficial
for our Indian corporate world. The views of Vodafone Essar and Bharti Group
Chairman Subil Mittal are also provided with.
(http://gadgets.ndtv.com/telecom/news/telecom-mergers-and-acquisitions-
guidelines-may-be-announced-this-week-sibal-444377)
D. After which a critical analysis of the subject matter is taken up for reading
through the subsequent article- through this article has noticed the loopholes
present in the new M&A guidelines so approved by the government regarding
joint liabilities, fund constraints and no exit rules which would limit the new
entrants. In this article, justifications for the negative aspects of the guidelines
are been given very clearly. It gives one the outlook of the new M&A
guidelines for the telecom sector. In this article, the broad contours of the new
M&A policy have been defined. Views of various experts have been provided

3
 with regarding it. (http://www.business-standard.com/article/companies/m-a-
policy-fails-to-stir-telecom-sector-114030301244_1.html)
E. From the reputed international journal of management and information
technology, the next article gives a statistical review of about the 15 telecom
operators who have started their operations in India. The Indian market is
flamboyant for Indian as well as foreign investors. This article critically
examines the Merger and Acquisition scenario in the Telecom industry in India
and the current policy framework that provides policy prescriptions for the
future.

2.1 UNDERSTANDING THE CONCEPT

India has turned into a hotbed of telecom mergers and acquisitions in the most
recent decade. Foreign investors and telecom majors take a gander at India as one of
the quickest developing telecom market on the planet. Clearing changes presented by
progressive Governments throughout the most recent decade have drastically changed
the substance of the telecommunication business. The portable part has accomplished
a teledensity of 14% by July 2006 which has been supported by a bundle of elements
like aggressive foreign financing, administrative help, lower taxes and falling network
cost and handset costs.

Mergers and amalgamations as well as acquisitions and takeovers in the

corporate world has become a universal practice within nation and across borders for
securing growth, survival, achieving multitude of objectives, expansion and
globalisation of the enterprise. A business person may develop its business either by
inner extension or by outer development. These syntheses are as mergers,
acquisitions, amalgamations and takeovers and have now gotten essential peculiarities
of corporate rebuilding. They have been assuming a vital part in the outer
development of various heading organizations the world over. They have gotten main
stream due to the improved competition, breaking of exchange boundaries, free
stream of capital crosswise over nations and globalization of organizations.

The terms ‘merger’ and ‘amalgamation’ are used interchangeably to denote the
combination or fusion of two or more companies into a single company, where one
survives and the other loose its corporate entity and thus being wound up without the
process of winding up and the process is carried out through a scheme requiring

4
sanction of the court. Mergers and acquisitions (M&As) have been an exceptionally
vital business sector entrance methodology and additionally extension method. This
present time is known as competition period. In this time organizations, to dodge the
competition, try for merger, and delight in off and on again monopoly. Corporate
India is awakening the new thousand years basic of mergers and acquisitions in a
frantic quest for a panacea for confronting the worldwide competition. This is
scarcely astonishing as solid competition may be, as it were verifiable in any offered
to coordinate the national economy with the worldwide economy. The continuous
procedure of liberalization has uncovered the ineffective utilization of capital by the
Indian corporate both out in the open and private divisions. Consolidation through
mergers and acquisitions (M&As) is viewed as one of the most ideal methods for
rebuilding structure of corporate units.

The idea of mergers and acquisitions is really prominent in the current

situation, so it is essentially prevalent idea, after 1990s, where India entered into the
Liberalization, Privatization and Globalization (LPG) period. The winds of LPG are
blowing over all the areas of the Indian economy yet its greatest effect is seen in the
industrial segment. It brought about the business to become hyper-competitive. As
competition expanded in the economy, so to keep away from bad competition and to
face worldwide and multinational organizations, Indian organizations are striving for
mergers and acquisitions.

2.1.1 MERGER

Merger is characterized as mixing of two or more substance into a solitary

element. The shareholders of each one mixing substance will turn into the
significantly the shareholders in the element which is to bear on the mixed element.

The survivor acquires the assets as well as the liabilities of the merged
company or companies and stock of one company stands transferred to transferee
company in consideration of payment in the form of equity shares of transferee
company or debentures or cash or a mix of the two or three modes. The Income Tax
Act, 1961 [Section 2(1A)] defines amalgamation as2

2
the merger of one or more companies with another or the merger of two or more companies to form a
new company, in such a way that all assets and liabilities of the amalgamating companies become
assets and liabilities of the amalgamated company and shareholders not less than nine-tenths in value of

5
Supreme Court observed in the case of Saraswati Industrial Syndicate Ltd. v. CIT 3
that “amalgamation or reconstruction has no precise meaning. In amalgamation two or
more companies are fused into one by merger or by taking over by another, when two
companies are merged and so joined as to form a third company or one is absorbed
into one or blended with another, the amalgamating company loses its identity”.

Andhra Pradesh High Court held in S.S. Somayajulu v. Hopc Prudhomme &
Co.4 that the word ‘amalgamation’ has no definite legal meaning. “It contemplates a
state of things under which two companies are so joined as to form a third entity, or
one company is absorbed into and blended with another company. Amalgamation
does not involve a formation of a new company to carry on the business of the old
company”.

It is mainly of 3 types:

a) Horizontal merger

Take place when two merging companies manufacture similar goods and
belong to the same industry.5 For example, the combination of two book publishers or
two luggage manufacturing companies to gain dominant market share.

b) Vertical Merger

It is a combination of two or more firms involved in different stages of

production or distribution of the same product. For example, the joining of a TV
manufacturing company and a TV marketing company or joining of a spinning
company and a weaving company.6 Vertical merger may take the form of forward or
backward merger. When a company combines with the supplier of material, it is
called backward merger and when it combines with the customer, it is known as
forward merger.

c) Conglomerate merger

the shares in the amalgamating company or companies become shareholders of the amalgamated
company.
3
Saraswati Industrial Syndicate Ltd. v. CIT [1991] 70 Comp Cas 184 (S.C.)
4
S.S. Somayajulu v. Hopc Prudhomme & Co., [1963] 2 Comp LJ 61 (AP)
5
R Jha, ‘A Study on Acquisition, Control, Merger and Amalgamation under Section 5 & 6 of
Competition Act, 2002 A critical analysis’ [2012] Competition Commission of India 11, 18
6
Ibid

6
 It occurs when the two merging companies belong to two different industrial
sectors. For example, the merging of different businesses like for instance,
manufacturing of cement products, fertilizer products, electronic products, insurance
investment and advertising agencies.7

2.1.2 ACQUISITION

Acquisition, in general sense, is acquiring the ownership in the property. In the

context of business combinations, an acquisition is the purchase by one company of a
controlling interest in the share capital of another existing company. An acquisition
may be influenced by the following factors, for example, concurrence with the
persons holding greater part enthusiasm toward the organization administration like
parts of the board or significant shareholders ordering lion's share of voting force, buy
of shares in open business, making takeover offer to the general body of shareholders,
buy of new shares by private settlement, acquisition of offer capital of one
organization may be by either all or any of the accompanying type of considerations
viz. method for money, issuance of credit capital, or issuance of offer capital.
Acquisition might additionally be pointed basically to combination of shareholding or
voting rights in an organization without proposing to takeover the control and
administration of the organization. Acquisition might additionally be effected by
getting possessions. Acquirer may buy just stakes or some particular holdings and not
all the assets and liabilities of the organization.

The Five Rules of Successful Acquisition8:-

By: Peter F. Drucker is as under

i) Think what you can contribute to the business it is buying not what the acquirer
company will contribute to the acquirer.

ii) Common core of unity: The two business must have a common either markets or
technology.

iii) Temperamental fit: No acquisition works unless people in the acquiring company
respect the product, the markets and the customers of the company they acquire.

7
Ibid
8
Frank T. Paine and Daniel J. Power, ‘Merger strategy: An examination of Drucker's five rules for
successful acquisitions’ [2006] Strategic Management Journal 2, 15

7
iv) Within a year or so the acquiring company must be able to provide top
management for the company it acquires.

v) Within the first year of a merger, it is important that a large number of people in
management groups of both companies receive substantial promotion across the line
that is from one of the former companies to the other.

2.1.3 TAKEOVER

A takeover for the most part includes the acquisition of a certain piece of value
capital of an organization which empowers the acquirer to practice control over the
undertakings of the organization. Regularly merger, amalgamation, acquisition,
takeover are utilized conversely.

2.3 RATIONALE9 BEHIND MERGERS IN THE

TELECOMMUNICATIONS INDUSTRY

a) Acquisition of brand value

b) Acquisition of customer base

c) Acquisition of customer base to achieve an economic base

d) Acquisition of licenses or geographical territories

e) Acquisition of spectrum

f) Acquisition of telecom infrastructure and network

g) Higher operating profit (EBITDA) margin

2.4 ADVANTAGES OF MERGERS AND ACQUISITIONS

Shareholders in the buying company gain in the long run with the growth of
the company not only due to synergy but also due to “boots trapping earnings”.10

The precise first focal point of M&A is synergy that offers a surplus power
that empowers upgraded execution and expense effectiveness. At the point when two
or more companies get together and are underpinned by one another, the ensuing

9
N Sinha, ‘Economic Analysis of Competition and Merger Issues in the Indian Telecom Sector’ [2011]
Competition Commission of India
10
J.C. Van Horne, Fundamentals of Financial Management (5th) 530

8
business is certain to addition huge benefit as far as money related increases and work
execution.

Cost productivity is an alternate helpful part of merger and acquisition. This is

on account of any sort of merger really enhances the purchasing power as there is
more arrangement with mass requests. Separated from that staff decrease additionally
helps an incredible arrangement in cutting cost and expanding overall revenues of the
organization. Separated from this build in volume of creation brings about decreased
expense of generation for every unit that inevitably prompts raised economies of
scale.

With a merger it is not difficult to keep up the competitive edge on the

grounds that there are numerous issues and methods that might be well comprehended
and obtained by joining together the assets and abilities of two or more companies.

A blending of two companies or two organizations positively improves and

reinforces the business arrange by enhancing business arrive at. This offers new deals
open doors and new regions to investigate the likelihood of their business.

With all these profits, a merger and acquisition arrangement builds the
business sector power of the organization which thus restrains the seriousness of the
extreme business rivalry. This enables the merged firm to take advantage of hi-tech
technological advancement against obsolescence and price wars.

Mergers and takeovers are permanent form of combination which vest in

management complete control and provide centralised administration which are not
available in combination of holding company and its partly owned subsidiary11.
Shareholders in the selling company gain from the merger and takeover as the
premium offered to induce acceptance of the merger or takeover offers much more
price than the book value of shares.

3.1 M&A PROVISIONS UNDER COMPANIES ACT, 1956

There are different ways by which a company may be reorganised. Generally a

company may be reorganised in 3 ways:

11
Heavy Head and Co. v. Roprer Holdings Ltd [1952] Ch 15

9
1. By a scheme of compromise and arrangement

2. By a scheme of reconstruction and amalgamation

3. By a takeover bid

The Companies Act, 1956 is a voluminous piece of legislation on the statute

book with 658 sections and 14 schedules. However, there are only seven sections here
on corporate restructuring including mergers, de mergers etc. Although corporate re-
engineering physically occupies a small portion of the Companies Act comprising
barely seven sections from 390 to 396A therein, yet its impact on industry and
commerce has been far reaching. These provisions have been borrowed from the
English Companies Act and have withstood the test of times.3D

The directors of the company and the managing agent under express authority
are also competent to make application to the court for sanction of a scheme. So far as
the liquidator is concerned, he has no exclusive right to make application when the
company is being wound up. In that state of affairs, even the company itself or a
member or a creditor is also competent to apply just as they are empowered to apply
when the company is a going concern12. A worker of a company unless he is a creditor
has no locus standi to intervene in a proceeding under sec 391 dealing with a
compromise or arrangement between a company and its members.13 On an application
made by the company, the court may request that a meeting of the creditors or parts of
any class of them be called, held and led in the way regulated by the court. The court
will give the bearings for holding the gathering just on the off chance that it is
fulfilled that the plan is sensible and workable.

3.2 M&A PROVISIONS UNDER COMPANIES ACT, 2013

The Companies Act, 2013 has seen the light of day and supplanted the 1956
Act with some clearing progressions counting those in connection to mergers and
acquisitions (M&A). The new Act has been commended by corporate associations
what's more attorneys for its business-accommodating corporate regulations,
upgraded divulgence standards and giving assurance to investors and minorities, in
addition to different components, in this way making M&A smooth and productive.

12
Rajendra Prasad Aggarwal v. Official Liquidator [1978] 48 Comp Cas 476
13
River Steam Navigation Co. Ltd. 71 CWN 854

10
Its distinguishment of inter-se shareholder rights makes the law one stride forward to
a business-friendly administration. The 2013 Act holds various procurements which
have suggestions on Mergers and Restructurings. In this announcement we investigate
some of the key procurements and additionally distinguished certain movement steps
and difficulties connected with the execution of these procurements for organizations
to consider. In the old act, mergers and acquisitions is been explained under sec-390
to sec-396A and in the new act, mergers and acquisitions is been explained in sec-230
to sec-240.

There are some down to business changes, for example, fast-track schemes,
which being cost and time powerful will empower corporate restructurings for little
and gathering organizations; merger of an Indian company into a foreign company
ought to offer force to cross-border M&A action; presenting the edge for raising
complaints to a plan would stop frivolous protests and postal ballot endorsement
would guarantee a more extensive support of the stakeholders. Nonetheless, multi-
power evaluation of the rebuilding plan in the 2013 Act may be a dampener,
considering that the present system conceives a solitary window freedom. Under Sec-
230 to sec-240 of the Companies Act, 2013, various changes have come into force and
some of the provisions are similar to the provisions provided in Companies Act, 1956.

4.1 THE NEW M&A GUIDELINES FOR THE TELECOM SECTOR

The mergers and acquisitions in Telecom Sector are viewed as horizontal

mergers basically as a result of the reason that the substances striving for merger or
acquisition are operating in the same business, which is telecommunications industry.
In most of the created and creating nations far and wide, mergers and acquisitions in
the telecommunications division have turned into a need. This sort of mergers
additionally assists in production of occupations.

The basic models14 of M&A in telecom sector are:

1) In the first model, the investor gets a controlling stake in the acquired
company also holds it as a different entity. This is the most straightforward
model with the plan to stay away from the legal obstacle for merging the
company into the parent company. This course likewise gives the acquirer an

14
Rajesh Kumar, Mergers and Acquisitions: Texts and Cases (1st) 338

11
 adaptability to auction the operation on a stand alone basis later on, on the off
chance that the merger is not effective. This model has been trailed by
Hutchison, which has held the greater part of the acquired companies as
particular legal elements.

2) In the second model, the acquirer consolidates the acquired company with the
parent after securing controlling stake. This model obliges fulfilment of
merger customs with due approbation of High courts and likewise from Dot. It
has the focal point of staying away from statutory consistence for a few
substances furthermore coordinate all operations flawlessly into a solitary
legal entity. This model has been emulated by Bharti, which has united most of
the acquired substances with the parent in proper method of time.

3) The third model involves buy of benefits of the target company on stand alone
basis without buying the company as an entirety. In a few cases, where the
licenses were wiped out by DoT because of default, such organizations sold
the telecom holdings also client database to the acquirer, who could without
much of a stretch incorporate the same into his current permit and reinforced
his system and client base at an ostensible cost. The dealer company which
was stripped of permit and in addition telecom system was eventually wound
off.

Both transnational and local telecommunications services suppliers are quick to

attempt merger and acquisition choices in light of the fact that this will help them
from various perspectives. They can eliminate their costs, accomplish more prominent
piece of the pie and achieve business sector control.

Mergers and acquisitions in the telecommunications area have been demonstrating a

prosperous pattern in the later past and the economists are upholding that they will
keep on doing so. The dominant part of telecommunication services suppliers have
comprehended that keeping in mind the end goal to develop comprehensively, vital
unions and mergers and acquisitions are the central gadgets.

Private part speculation and FDI have likewise helped the development of mergers
and acquisitions in the telecommunications segment. Throughout the last few years, a
marvellous development has been seen in the amount of mergers and acquisitions

12
occurring in the telecommunications business. The reasons behind this advancement
incorporate the accompanying:

• Deregulation

• Presentation of refined innovations

• Imaginative items and services

Economics changes have impelled the development in the mergers and acquisitions
industry of the telecommunications segment to a satisfactory level. Mergers and
acquisitions in Telecom Sector can likewise have some negative impacts, which
incorporate syndication of the telecommunication items and services, unemployment
and others. In any case, the governments of different nations make proper moves to
check these issues.

In nations like India, mergers and acquisitions have increased to a respectable level
from the mid-1990s. In the United States, the mergers and acquisitions in the
telecommunications segment are going ahead in an undeniable way.

The mergers and acquisitions in the telecommunications area are administered or

managed by the regulatory power of the telecommunication business of a specific
nation, case in point the Telecom Regulatory Authority of India or TRAI. The
regulatory powers dependably keep a tab on the telecommunications business so that
no syndication is structured.

5.1 CONCLUDING REMARKS

1) After the rigorous and in-depth analysis of this topic, it can be easily said that
from the above study that mergers and acquisitions in the telecommunications
sector has been triggered from the 19th century and due to the remunerative
results in the growth of this sector, this notion has taken pace in Indian
corporate world and every industry is enthusiastic about the adoption of the
conception.
2) The administrative environment for telecom sector of India is quick changing
to the advancement of different stakeholders. Foreign organizations have been
demanding a liberal telecom arrangement before they put resources into India.
Indian government began welcoming these demands one by one.

13
 3) Indian government has enacted a simplified provisions for mergers and
acquisitions for the telecom service which is been expressly laid down in
National Telecom Policy, 2012 whose main objective is to enhance the
practice of mergers and acquisitions in the telecom industry on one hand and
maintain the competition in that sector on the other hand.
4) The Telecom Dispute Settlement and the Appellate Tribunal would play a
greater role in solving disputes in an effective and efficient way.
5) The permit period of the resultant company will be legitimate for the more
extended period held by any of the merging company. In any case, there will
be no change in the legitimacy period of spectrum distributed to each of the
substances.
6) Considering the research findings, subject to the limitations, the hypothesis of
this study stands to be proved that the new mergers and acquisition guidelines
so framed for the telecom sector is favourable for the telecommunications
industry.

BIBLIOGRAPHY

BOOKS REFFERED:

1) Frank T. Paine and Daniel J. Power, ‘Merger strategy: An examination of

Drucker's five rules for successful acquisitions’ [2006] Strategic Management
Journal 2, 15

2) J.C. Van Horne, Fundamentals of Financial Management (5th) 530

3) Kamalpreet Kaur, 'India: Merger Regime Under The Companies Act, 2013'
(http://www.mondaq.com 2014)
<http://www.mondaq.com/india/x/289180/Corporate+Commercial+Law/Merg
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June,2014Manjit Kumar Pandey, Parul, Shailendra Sharma, Utsav A. Saboo,
K.V.S.S. Narayana

4) Rao, ‘Acquisition of Hutchinson Essar by Vodafone - Case Study’ (http://nrao-

m-a-handbook.blogspot.in 2007) <http://nrao-m-a-
handbook.blogspot.in/2007/10/acquisition-of-hutchinson-essar-by.html>
accessed 4th July, 2014

14
 5) N Sinha, ‘Economic Analysis of Competition and Merger Issues in the Indian
Telecom Sector’ [2011] Competition Commission of India

6) R Jha, ‘A Study on Acquisition, Control, Merger and Amalgamation under

Section 5 & 6 of Competition Act, 2002 A critical analysis’ [2012]
Competition Commission of India 11, 18

7) Rajesh Kumar, Mergers and Acquisitions: Texts and Cases (1st) 338 ‘Report
on Activities’ [2013] TRAI ‘Department of Telecommunications’
(http://www.dot.gov.in 2014) <www.dot.gov.in/sites/default/files/DOC300414
(1)_0_3.pdf> accessed 3rd July, 2014

ARTICLES REFFERED:

a) ‘History of merger and acquisition in India’ (mergersandacquisitions.in)

<http://www.mergersandacquisitions.in/history-of-merger-and-acquisition-in-
india.htm> accessed 24th May, 2014

b) ‘Sterling Infotech buys RPG Cellular’ (http://www.thehindubusinessline.in

2003)
<http://www.thehindubusinessline.in/2003/12/20/stories/2003122002650100.h
tm> accessed 4th July, 2014

c) ‘Tatas acquire VSNL through Panatone’ (www.moneycontrol.com 2005)

<http://www.moneycontrol.com/news/business/tatas-acquire-vsnl-through-
panatone_193911.html> accessed 22nd June, 2014

d) ‘The Story of the Cellular Phone Brand Orange’ (http://www.icmrindia.org )

<www.icmrindia.org/casestudies/catalogue/Business Strategy1/The Story of
the Cellular Phone Brand Orange.htm> accessed 6th July, 2014

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