Issues: Whether penalty for failure to obtain a tax audit was sustainable where the assessee's futures and options turnover, computed under the applicable method, did not cross the tax-audit threshold.

Analysis: For futures and options transactions, turnover is determined from favourable and unfavourable differences, option premium received, and differences arising on reverse trades, with each buy-and-sell transaction treated independently. The assessment had treated the aggregate value of transactions as turnover, whereas the assessee's turnover computed on this basis was below the prescribed threshold for tax audit.

Conclusion: The penalty under Section 271B was unsustainable and was directed to be deleted, in favour of the assessee.

Issues: Whether a 5% ad hoc disallowance of business expenses, including foreign-exchange loss, could be sustained without identifying any specific defect, non-genuine expenditure, or inadequate supporting documentation.

Analysis: Acceptance of 95% of the expenditure indicated that the genuineness of the expenses was not in dispute. No finding established that any expense was bogus, not incurred for business purposes, or unsupported by deficient documentation; nor was any particular expense head or substantial transaction identified for further verification. If complete verification of documents was required in faceless assessment, the assessee had to be notified and afforded sufficient opportunity, which was not evident from the record. The foreign-exchange loss arose on year-end restatement of foreign-currency liabilities, and no finding showed that it was contrary to applicable accounting standards or capital in nature. The explanations and documents furnished also supported the remaining expenditure claims.

Conclusion: The ad hoc disallowance sustained in respect of the expenses was set aside in favour of the assessee.

Issues: (i) Whether the addition for excess share premium under section 56(2)(viib) could be sustained after rejection of the assessee's valuation report; (ii) Whether disallowance of expenses could be made in a limited-scrutiny assessment without conversion into complete scrutiny.

Issue (i): Whether the addition for excess share premium under section 56(2)(viib) could be sustained after rejection of the assessee's valuation report.

Analysis: The assessee furnished a chartered accountant's valuation report, supported by detailed workings, valuing the shares above the issue price. The Assessing Officer substituted that valuation with a self-computed net asset value without referring the matter to the valuation cell. The objections to the report rested on unverified doubts and lack of examination of the supporting workings, while the appellate finding accepting the report was reasoned and supported by the material.

Conclusion: The deletion of the addition for excess share premium was upheld, in favour of the assessee.

Issue (ii): Whether disallowance of expenses could be made in a limited-scrutiny assessment without conversion into complete scrutiny.

Analysis: The scrutiny selection was confined to advances, loans and share premium; expense disallowance was outside those selected issues. No satisfaction was recorded and no prior approval was obtained to convert the limited scrutiny into complete scrutiny. An addition on an issue beyond the prescribed scope was therefore beyond the Assessing Officer's jurisdiction.

Conclusion: The deletion of the expense disallowance was upheld, in favour of the assessee.

Final Conclusion: The assessed share-premium addition and expense disallowance were not legally sustainable.

Ratio Decidendi: A supported share-valuation report cannot be displaced by an Assessing Officer's unsupported substitute valuation, and additions outside limited-scrutiny issues require valid conversion to complete scrutiny.

Issues: Whether revision under section 263 on issues unrelated to the subject matter of reassessment was barred by limitation.

Analysis: The reassessment was initiated solely for alleged bogus purchases, whereas the proposed revision concerned gifts to doctors, disallowance of expenditure relating to exempt income, and deduction for CSR expenditure. Those matters arose from and had been examined in the original assessment. Where the subject matter of revision is distinct from the subject matter of reassessment, the limitation for revision runs from the original assessment order; it cannot be extended by treating the reassessment order as the relevant order. The audit objections were available during reassessment, but the reassessment was not enlarged to cover those matters.

Conclusion: The revisionary proceedings were time-barred and the order under section 263 was quashed, in favour of the assessee.

Issues: Whether cash deposits in specified bank notes during the demonetisation period, stated to be refunds of business advances from purchase agents, could be treated as unexplained cash credits.

Analysis: The assessee maintained audited regular books containing the advances, refunds, cash deposits and supporting particulars of 57 purchase agents. The books were neither rejected nor found incorrect, and the Revenue accepted the opening cash balance recorded therein. No enquiry was made with the agents and no material established that the advances, refunds or book entries were fictitious. There was also no abnormal increase in cash deposits compared with the preceding year. Receipt of specified bank notes before 31.12.2016 in voluntary lawful commercial transactions was not statutorily prohibited merely because the notes had ceased to be legal tender. The statutory conditions for invoking the unexplained-credit provision were therefore not established by suspicion alone.

Conclusion: The deposits stood explained as genuine refunds of business advances; the addition under Section 68 and consequential taxation under Section 115BBE were unsustainable.

Issues: Whether an addition based on estimated gross profit could be sustained where the books of account were accepted and no defects were found.

Analysis: The cash deposits during demonetisation were accepted as explained, and the books and records were properly maintained. The gross-profit estimate was derived by averaging results of three assessment years despite differences in turnover and business progression. The subsequent year's higher turnover and higher gross-profit rate did not support the adopted estimate. No defect was identified in the books and they were not rejected before estimating profit.

Conclusion: The estimated gross-profit addition was unsustainable and was deleted in favour of the assessee.

Issues: Whether the best judgment assessment levying tax on a works-contract dealer was sustainable when the dealer had opted for composition under the applicable VAT provision and submitted the records required under that scheme.

Analysis: A dealer executing works contracts may opt for composition under Section 4(7)(b) of the Andhra Pradesh Value Added Tax Act, 2005, subject to the prescribed conditions and record-keeping requirements. The petitioner had exercised that option and submitted the available tax-collection certificates, returns and other prescribed records. The assessing authority failed to consider these materials and did not address the petitioner's specific statutory contentions. The assessment was therefore vitiated both by non-compliance with the composition scheme and by failure to give reasons.

Conclusion: The best judgment assessment was unsustainable in law and was quashed.

Issues: Whether the ex parte Order-in-Original could stand where the petitioner had earlier reported fraudulent use of his identity for obtaining a GST registration, the authorities failed to investigate the complaint, and the subsequent notices were not received by him.

Analysis: The petitioner had informed the GST authorities in 2022 that his identity had been fraudulently used to create the concerned firm and had denied any connection with it. Despite receipt of that complaint, no investigation was undertaken. The subsequent show cause notices were not received by the petitioner, and the Order-in-Original was passed without his participation. The principles of natural justice, including a meaningful opportunity of hearing, required fresh adjudication in the peculiar circumstances.

Conclusion: The Order-in-Original dated 18.03.2026 was quashed and set aside, and the matter was remanded to the competent Commissioner for fresh adjudication after giving the petitioner an opportunity of hearing.

Outcome: Special Leave Petition dismissed. The question of law was kept open.

Outcome: Delay condoned. The Special Leave Petitions were dismissed and the accompanying interlocutory applications, if any, were disposed of.

Issues: Whether delayed filing of Form 10DA, otherwise available before processing of the return or completion of assessment, rendered the deduction under Section 80JJAA inadmissible and justified revision under Section 263 of the Income-tax Act, 1961.

Analysis: The delay in filing Form 10DA or the tax audit report does not by itself defeat the deduction under Section 80JJAA where the prescribed form was available to the Assessing Officer before processing the return or framing the assessment. The Assessing Officer's allowance of the deduction therefore could not be regarded as erroneous and prejudicial to the interests of the Revenue so as to invoke revisionary jurisdiction under Section 263.

Conclusion: Delayed filing of Form 10DA did not render the deduction under Section 80JJAA inadmissible, and the revision under Section 263 was invalid.

Issues: Whether the respondents wilfully and deliberately disobeyed the Court's earlier order so as to constitute civil contempt.

Analysis: Contempt jurisdiction under the Contempt of Courts Act, 1971 is limited and requires clear proof of deliberate or wilful disobedience. The earlier order required the customs authorities to accept a baggage declaration made under Section 77 of the Customs Act, 1962, while preserving their statutory power to take appropriate action regarding baggage. The introductory reproduction of the prayer did not constitute an operative direction. The material on record did not establish non-compliance, much less intentional disobedience, and bare averments were insufficient to initiate contempt action.

Conclusion: No case of civil contempt or wilful disobedience was established against the respondents.

Ratio Decidendi: Civil contempt requires satisfactory proof of deliberate and wilful disobedience of a specific court direction; an interpretation of the order unsupported by material evidence is insufficient.

Issues: Whether late filing fee under Section 46(3) of the Customs Act, 1962 read with Regulation 4 of the Bill of Entry (Electronic Integrated Declaration and Paperless Processing) Regulations, 2018 was leviable on supplementary Bills of Entry filed for excess bulk coal arising from natural cargo variations.

Analysis: The original Bills of Entry covering the manifested quantity were filed within time and the applicable customs duty was paid. The supplementary Bills of Entry were filed after the excess quantity was identified through the prescribed procedure and arose from inherent and unavoidable variations in bulk cargo, including moisture, physical weighment and draught survey differences. There was no suppression, misdeclaration, revenue loss, deliberate delay or mala fide conduct. Section 46(3), read with Regulation 4, does not require late fee to be imposed mechanically where sufficient cause for delayed filing is established and permits waiver in deserving cases. The levy was therefore inconsistent with the appellant's bona fide conduct and the circumstances of the import.

Conclusion: The late filing fee imposed on the appellant was legally unsustainable and was set aside.

Issues: (i) Whether operation microscopes, lensmeters/focimeters and chart projectors were classifiable under Heading 9018 or under Headings 9011, 9031 and 9008 respectively; (ii) whether the differential duty demand, extended limitation, confiscation, redemption fine and penalties were legally sustainable.

Issue (i): Classification of the imported operation microscopes, lensmeters/focimeters and chart projectors.

Analysis: Classification is governed by the terms of the tariff headings, the relevant Section and Chapter Notes, the General Rules for Interpretation under the Customs Tariff Act, 1975 and the HSN Explanatory Notes. Under Rule 1 and Rule 3(a), the specific description is preferred. The HSN Explanatory Notes to Heading 9011 exclude ophthalmic binocular-type microscopes and direct their classification under Heading 9018. The product catalogues and technical material established that the operation microscopes were specialised ophthalmic surgical instruments, and their possible use in other microsurgical fields did not override their essential character or the specific exclusion from Heading 9011. Lensmeters/focimeters were specialised ophthalmic diagnostic instruments and therefore fell under the specific Heading 9018 rather than the residuary Heading 9031. Chart projectors were specialised ophthalmic devices forming part of eye-testing systems and were not general-purpose projectors classifiable under Heading 9008.

Conclusion: All the imported goods were correctly classifiable under Heading 9018 of the Customs Tariff Act, 1975, and reclassification under Headings 9011, 9031 and 9008 was unsustainable.

Issue (ii): Sustainability of the differential duty demand, extended limitation, confiscation, redemption fine and penalties.

Analysis: The differential duty demand under Section 28(4) of the Customs Act, 1962 was founded on the proposed reclassification and therefore failed on merits. In any event, the importer had disclosed the nature and use of the goods, furnished product catalogues and technical material, and the goods had been examined and assessed by Customs. The dispute was interpretational, with no proof of collusion, wilful misstatement, suppression of facts or intent to evade duty, so the extended limitation and penalty requirements were not met. Misclassification without misdeclaration did not justify confiscation under Section 111(m). As the goods were unavailable for confiscation and the alleged contravention was not established, redemption fine under Section 125 and penalty under Section 114A were also unsustainable.

Conclusion: The differential duty demand, interest, confiscation, redemption fine and penalty were not legally sustainable.

Final Conclusion: The classification adopted by the importer was upheld, and the consequential fiscal and penal proceedings founded on the proposed reclassification were set aside.

Ratio Decidendi: Goods must be classified according to the tariff headings, relevant notes and HSN Explanatory Notes, giving effect to a specific inclusion or exclusion and the goods' essential character and primary intended use; a bona fide classification dispute supported by full disclosure and departmental examination does not, without proof of suppression or wilful misstatement, sustain extended limitation, confiscation or penalty.

Issues: (i) Whether duty is payable on duty-free raw materials destroyed within an Export Oriented Unit after intimation to the department; (ii) whether the 2015 amendments permitting destruction of inputs are clarificatory and retrospective; and (iii) whether the demands of duty, interest and penalties are sustainable.

Issue (i): Whether destruction of duty-free raw materials within the factory under intimation attracts Customs or Central Excise duty.

Analysis: The EOU scheme comprises the Foreign Trade Policy, the Development Commissioner's permissions and the exemption notifications issued under the Customs and Central Excise laws. Paragraph 6.15 of the Foreign Trade Policy permitted destruction of obsolete or unusable inputs within the unit after intimation to Customs authorities. The notifications were therefore required to be read harmoniously with the policy rather than in isolation. The materials were destroyed because of obsolescence, after prior intimation, without any allegation of diversion, misuse or breach of the scheme. In those circumstances, destruction did not amount to clearance for home consumption or diversion attracting duty.

Conclusion: Destruction of the duty-free raw materials within the factory under due intimation did not attract Customs or Central Excise duty.

Issue (ii): Whether the amendments introduced by Notification No. 30/2015-CE and Notification No. 34/2015-Cus permitting destruction of inputs were clarificatory and retrospective.

Analysis: The Foreign Trade Policy already permitted destruction of obsolete inputs before the amendments. The amendments expressly aligned the exemption notifications with that existing policy framework, removed an ambiguity and did not create a new substantive right or impose a new condition. They were consequently clarificatory in character.

Conclusion: The 2015 amendments were clarificatory and operated retrospectively.

Issue (iii): Whether the demands of duty, interest and penalties were sustainable.

Analysis: Since no duty was payable on the destruction, the consequential interest demand also failed. The appellant had acted transparently after intimating the department and there was no suppression, wilful misstatement, intent to evade duty or other material establishing mens rea. The penalties therefore lacked a sustainable legal basis.

Conclusion: The demands of duty, interest and penalties were not sustainable.

Final Conclusion: The benefit of the EOU scheme could not be denied where obsolete inputs were destroyed in accordance with the Foreign Trade Policy and after due intimation, and the 2015 amendments confirmed the pre-existing position.

Ratio Decidendi: In an EOU scheme, exemption notifications must be harmoniously construed with the governing Foreign Trade Policy; destruction of obsolete duty-free inputs within the unit after due intimation does not attract duty where there is no diversion or misuse, and amendments aligning the notifications with that policy are clarificatory and retrospective.

Issues: Whether the Revenue's rectification application was maintainable on the ground that the Tribunal had not decided the justification for invoking the extended period under Section 28(4) of the Customs Act, 1962.

Analysis: The dispute in the original proceedings was one of tariff classification. The show cause notice proposed rejection of the importer's declared classification, but the adjudicating authority accepted that very classification, thereby negating the allegation of misdeclaration or misclassification. Since invocation of Section 28(4) of the Customs Act, 1962 depends upon non-levy, short levy or similar consequences arising by reason of collusion, wilful misstatement or suppression of facts, the factual basis for extended limitation did not survive once the declared classification stood accepted. The issue on classification was also treated as interpretational and debatable. In that background, the omission to separately decide the limitation ground was not a mistake apparent from the record rectifiable under Section 129B of the Customs Act, 1962 read with Rule 31A of the CESTAT (Procedure) Rules, 1982. The question of extended limitation was further held to be merely academic because the decision on merits was in favour of the taxpayer and no duty demand survived.

Conclusion: The rectification application was not maintainable; no error apparent on record was made out, and the Revenue failed to justify invocation of Section 28(4) of the Customs Act, 1962. The issue was decided in favour of the assessee.

Ratio Decidendi: Rectification jurisdiction under Section 129B of the Customs Act, 1962 cannot be used to reopen or seek a fresh determination on a debatable issue, and where the assessee succeeds on the substantive classification issue eliminating the duty demand, a separate challenge to invocation of the extended period under Section 28(4) becomes academic in the absence of any surviving basis of misdeclaration or suppression.

Issues: (i) Whether RBI prudential norms applicable to banks extinguish a borrower's obligation to recognise interest on NPA-classified borrowings, and whether expected OTS cash flows may replace contractual cash flows under Ind AS 109; (ii) whether the engagement partner violated applicable auditing standards, the Companies Act, 2013 and the Chartered Accountants Act, 1949; (iii) whether an unaccepted and undocumented OTS proposal justified non-recognition of a financial liability and an unmodified audit opinion; (iv) whether EQCR was mandatory for the audit of a listed entity; (v) whether Standards on Auditing are mandatory; (vi) whether the sanctions against the engagement partner were proportionate; and (vii) whether the audit firm had independent quality-control liability, whether proceedings against it constituted double jeopardy, and whether its penalty was proportionate.

Issue (i): Whether RBI prudential norms applicable to banks extinguish a borrower's obligation to recognise interest on NPA-classified borrowings, and whether expected OTS cash flows may replace contractual cash flows under Ind AS 109.

Analysis: RBI's IRACP norms regulate lender-side income recognition and do not alter the borrower's contractual liability or obligations under the Companies Act, 2013 and applicable accounting standards. Under Ind AS 109, financial liabilities remain recognised until discharged, cancelled, expired or legally modified. The effective interest method requires contractual cash flows and does not permit expected credit losses or an anticipated OTS to be substituted for those cash flows. An unaccepted proposal, without a binding waiver or concluded modification, cannot extinguish the liability.

Conclusion: RBI prudential norms do not extinguish the borrower's obligation to accrue interest, and expected OTS cash flows cannot replace contractual cash flows under Ind AS 109.

Issue (ii): Whether the engagement partner violated applicable auditing standards, the Companies Act, 2013 and the Chartered Accountants Act, 1949.

Analysis: The substantial unexplained reduction in finance cost required professional scepticism, risk assessment, sufficient appropriate audit evidence and adequate documentation. The audit file did not demonstrate examination of the NPA interest issue, challenge to management's treatment, bank confirmations, loan agreements or documented discussions. The resulting non-recognition of interest materially misstated liabilities and profit and established failures concerning disclosure, reporting of material misstatements, due diligence, audit evidence and departure from accepted audit procedures.

Conclusion: The engagement partner violated the applicable Standards on Auditing, the Companies Act, 2013 and the professional-misconduct provisions of the Chartered Accountants Act, 1949.

Issue (iii): Whether an unaccepted and undocumented OTS proposal justified non-recognition of a financial liability and an unmodified audit opinion.

Analysis: An OTS proposal is not a concluded contract or legal release. The omission of interest affected finance costs, current liabilities, profit, retained earnings and net worth and was material and pervasive. The defective management representation letter could not provide a sufficient basis for accepting the treatment. The circumstances required a modified opinion, including a qualified or adverse opinion as appropriate, rather than an unmodified opinion.

Conclusion: The OTS proposal did not justify non-recognition of the liability or an unmodified audit opinion; the audit opinion issued was incorrect.

Issue (iv): Whether EQCR was mandatory for the audit of a listed entity.

Analysis: SA 220 expressly requires completion of an engagement quality control review before the engagement partner signs the audit report for a listed entity. The requirement is mandatory and contains no applicable discretion or exception.

Conclusion: EQCR was mandatory for the audit of the listed entity.

Issue (v): Whether Standards on Auditing are mandatory.

Analysis: Section 143(9) of the Companies Act, 2013 requires every auditor to comply with auditing standards, and SA 200 similarly requires compliance with all relevant SAs. Professional judgment operates within, and not instead of, those mandatory requirements.

Conclusion: Standards on Auditing are binding and mandatory on every statutory auditor.

Issue (vi): Whether the sanctions against the engagement partner were proportionate.

Analysis: The misconduct concerned a listed entity, a material and pervasive misstatement, failure of audit safeguards and an unmodified opinion that overstated reported profit. The monetary penalty and debarment were within the statutory range and proportionate to the gravity and public-interest impact of the misconduct.

Conclusion: The sanctions against the engagement partner were proportionate.

Issue (vii): Whether the audit firm had independent quality-control liability, whether proceedings against it constituted double jeopardy, and whether its penalty was proportionate.

Analysis: SQC 1 requires an audit firm not merely to formulate quality-control policies but also to establish, maintain, implement and monitor them so as to provide reasonable assurance of compliance and appropriate audit reports. The firm's responsibility is distinct from the engagement partner's engagement-level responsibility, and deficiencies concerning EQCR, documentation, communication and risk assessment may attract liability under SQC 1. Proceedings against the firm and the engagement partner enforce separate obligations and therefore do not constitute double jeopardy. The later proceeding caused no prejudice and the firm's higher penalty reflected its institutional and systemic responsibility.

Conclusion: The audit firm was independently and primarily liable for quality-control failures, the proceedings against it were not barred by double jeopardy, and its penalty was proportionate.

Final Conclusion: The findings of professional misconduct and the sanctions imposed on both the engagement partner and the audit firm were sustained on all substantively decided issues.

Ratio Decidendi: RBI prudential norms and anticipated OTS arrangements do not extinguish a borrower's contractual interest liability; listed-entity auditors must comply with mandatory auditing standards and obtain EQCR; and an audit firm bears independent quality-control responsibility distinct from that of its engagement partner.

Issues: (i) Whether the subject land formed part of the composite real estate project and could be dealt with in the corporate insolvency resolution process; (ii) whether the landowners' unilateral termination of the development agreement was legally effective against the corporate debtor and the rights of homebuyers; (iii) whether the approved resolution plan could proceed consistently with the statutory protection of homebuyers and the insolvency framework.

Issue (i): Whether the subject land formed part of the composite real estate project and could be dealt with in the corporate insolvency resolution process.

Analysis: The development agreement, the sanctioned layout approved by the competent planning and regulatory authorities, the contiguous nature of the land parcels, and the parties' conduct over more than a decade established that the subject land was incorporated into the integrated project. The agreement placed responsibility for obtaining approvals on the corporate debtor and required the landowners to cooperate. The absence of the landowners' signatures on particular approval documents did not invalidate the approvals, particularly when no timely objection had been raised. The project's development rights and integrated structure could not be dismembered after statutory approvals and third-party rights had crystallised.

Conclusion: The subject land formed part of the larger composite project and could not be isolated from the insolvency resolution process.

Issue (ii): Whether the landowners' unilateral termination of the development agreement was legally effective against the corporate debtor and the rights of homebuyers.

Analysis: The agreement contained both a completion period with a termination stipulation and an express non-termination clause. The landowners did not invoke termination upon expiry of the stipulated period, while approvals, construction activity, and homebuyers' rights developed over time. The delayed termination, issued shortly before commencement of CIRP, was inconsistent with the landowners' prior conduct and attracted waiver by acquiescence and the doctrine of approbation and reprobation. The crystallised rights of homebuyers could not be defeated by a unilateral communication. Following approval of the resolution plan, disputes and liabilities not preserved under the plan stood extinguished in accordance with the clean slate principle.

Conclusion: The alleged unilateral termination was not valid in law and could not defeat the CIRP or the rights of homebuyers.

Issue (iii): Whether the approved resolution plan could proceed consistently with the statutory protection of homebuyers and the insolvency framework.

Analysis: Landowners contributing land to the development arrangement were treated as promoters under the real estate regulatory framework and could not seek relief inconsistent with obligations owed to allottees. The integrated layout, common infrastructure, statutory approvals, and investments made by homebuyers made segregation of the subject land impracticable and prejudicial. The rights of homebuyers as a protected class were required to be preserved, and the resolution process could not be derailed by an inter se dispute between landowners and the corporate debtor.

Conclusion: The approved resolution plan could proceed on the basis that the subject land remained part of the integrated project, subject to protection of the rights of homebuyers and other stakeholders.

Final Conclusion: The landowners failed to establish any legal basis for excluding the subject land or invalidating the resolution process, and their challenge to the approved resolution plan was rejected.

Ratio Decidendi: Where land is contributed to and incorporated in an integrated real estate project, statutory approvals have been obtained on that basis, and third-party homebuyer rights have crystallised, the landowner cannot subsequently isolate the land or unilaterally terminate the development arrangement to defeat the corporate insolvency resolution process.

Issues: (i) Whether the insolvency proceedings initiated under Section 7 of the Insolvency and Bankruptcy Code, 2016 were rendered non-est by the invalidated RBI circular dated 12.02.2018. (ii) Whether the existence of alleged dues from the Uttar Pradesh Government and the principle in Vidharbha Industries Power Ltd. justified refusal to admit the Corporate Debtor into CIRP despite established debt and default.

Issue (i): Whether the insolvency proceedings initiated under Section 7 of the Insolvency and Bankruptcy Code, 2016 were rendered non-est by the invalidated RBI circular dated 12.02.2018.

Analysis: Proceedings initiated solely because of the RBI circular dated 12.02.2018 would be non-est in view of its invalidation. However, the financial creditor had recalled the loan, issued a legal notice and commenced recovery proceedings before the circular was issued. The Section 7 application was not based on the circular, the debt was below the circular's specified threshold, and no approved restructuring or one-time settlement existed. The insolvency proceedings were therefore independent of the circular.

Conclusion: The proceedings under Section 7 were not rendered non-est and the challenge based on the RBI circular fails.

Issue (ii): Whether the existence of alleged dues from the Uttar Pradesh Government and the principle in Vidharbha Industries Power Ltd. justified refusal to admit the Corporate Debtor into CIRP despite established debt and default.

Analysis: The alleged governmental dues did not constitute an adjudicated and realisable claim exceeding the debt owed. The exception recognised in Vidharbha Industries Power Ltd. is narrow and does not dilute the rule that admission under Section 7 follows once debt and default are established. In the absence of an approved settlement proposal, the Adjudicating Authority was justified in admitting the Corporate Debtor into CIRP.

Conclusion: The existence of alleged governmental dues did not justify refusal of admission, and the admission of the Corporate Debtor into CIRP was upheld.

Final Conclusion: The challenge to the CIRP admission failed, while the connected farmers' appeal was disposed of with the Resolution Professional directed to consider the farmers' claims in accordance with law.

Ratio Decidendi: Once debt and default are established, admission under Section 7 of the Insolvency and Bankruptcy Code, 2016 is mandatory unless the narrow exception based on an adjudicated and realisable claim exceeding the debt owed is satisfied; proceedings are not rendered non-est where they were initiated independently of an invalidated regulatory circular.