Post-winding-up tax demands cannot override winding-up priorities and must be dealt with through liquidation claims.

Tax demands arising from an assessment made after a company had already been ordered to be wound up did not acquire priority as crown debts. Such claims had to be dealt with under the winding-up framework in sections 529A and 530 of the Companies Act, 1956, and lodged with the Official Liquidator like other unsecured claims. Revenue entries based on the later assessment could not therefore be sustained and were required to be cancelled. The result was that the purchaser's title to the property in liquidation remained free from those adverse entries.

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Issues: Whether sales tax and Gram Panchayat tax demands arising from an assessment framed after the order of winding up could claim priority over the claims governed by the winding-up provisions, and whether revenue entries recording such dues as arrears of land revenue were liable to be cancelled.

Analysis: The Company had already been ordered to be wound up before the assessment was framed. In that situation, a demand raised pursuant to a later assessment could not claim priority as a crown debt. The winding-up regime under sections 529A and 530 of the Companies Act, 1956 required such claims to be lodged with the Official Liquidator in accordance with law along with other unsecured claims. As the assessment itself was subsequent to the winding-up order, the consequential revenue entries based on that assessment could not be sustained.

Conclusion: The post-winding-up tax dues could not override the winding-up priorities, and the revenue authorities were required to cancel the entries made on that basis. The relief was granted in favour of the applicant, securing a free and clear title to the purchased property.

Final Conclusion: The application succeeded because tax claims arising after the winding-up order were held not to enjoy priority and could not support the continuation of adverse revenue entries against the property in liquidation.

Ratio Decidendi: A demand arising from an assessment made after a company has been ordered to be wound up does not acquire priority as a crown debt and must be dealt with in accordance with the winding-up provisions governing claims against the company.

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