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Issues: Whether the provisions governing voluntary liquidation under the Insolvency and Bankruptcy Code, 2016 apply to a company placed in voluntary liquidation under the earlier company law regime, and whether an appeal against rejection of a claim by the liquidator is maintainable before the Adjudicating Authority.
Analysis: Section 59 of the Insolvency and Bankruptcy Code, 2016 governs voluntary liquidation of corporate persons and, by sub-section (6), attracts the provisions relating to liquidation and claims handling with necessary modifications. The statutory scheme makes the liquidator's admission or rejection of claims subject to challenge before the Adjudicating Authority. The Code also applies to companies incorporated under previous company law and has overriding effect by virtue of Section 238. The transitional order concerning pending voluntary winding-up proceedings under the Companies Act, 1956 operates in a different field and does not govern the present voluntary liquidation process.
Conclusion: The Code applies to the voluntary liquidation process in question, the Adjudicating Authority had jurisdiction, and the appeal against the liquidator's rejection of the claim was maintainable.
Final Conclusion: The challenge to the impugned order fails, and the dismissal of the appeal follows from the applicability of the Code's voluntary liquidation framework and the availability of the statutory appellate remedy.
Ratio Decidendi: In voluntary liquidation proceedings governed by the Insolvency and Bankruptcy Code, 2016, the liquidator's decision on claims is subject to statutory appeal before the Adjudicating Authority, and the Code prevails over inconsistent earlier company law provisions.