Issues: Whether an interim order granting substantive relief could be made without affording an effective opportunity to answer the interlocutory application and without recording reasons.

Analysis: Interim relief materially affecting parties' rights requires a reasoned prima facie assessment. Non-filing of a reply in the main proceedings or in the interlocutory application, without proof of an effective opportunity to respond, cannot by itself justify such relief. Section 424 of the Companies Act, 2013 and the principles of natural justice require an effective hearing and recorded reasons.

Conclusion: An ex parte interim order granting substantive relief without an effective opportunity of hearing and recorded reasons is vitiated.

Ratio Decidendi: A tribunal cannot grant materially rights-affecting interim relief solely because a party has not filed a reply; it must afford an effective opportunity of hearing and give reasons for the relief.

Issues: (i) Whether the Adjudicating Authority has the power and jurisdiction to recall CIRP by dismissing an admitted Section 9 petition founded on fraud and collusion?; (ii) Whether CIRP can continue after its original Section 9 application is found to have been fraudulently and collusively initiated?

Issue (i): Whether the Adjudicating Authority has the power and jurisdiction to recall CIRP by dismissing an admitted Section 9 petition founded on fraud and collusion?

Analysis: The existence of a debt and default is a jurisdictional fact for assumption of insolvency jurisdiction. A jurisdictional fact procured through fraud or collusion cannot sustain the exercise of statutory power. In public-law proceedings, deception of the adjudicatory process or a collusive presentation of facts undermines the integrity of the process and permits correction despite the ordinary finality of an admission order. The purported operational debt was conclusively found to be illusory and presented through collusion to procure CIRP and a moratorium.

Conclusion: The Adjudicating Authority has the power and jurisdiction to recall admission of CIRP by dismissing a Section 9 application founded on fraudulent and collusive jurisdictional facts.

Issue (ii): Whether CIRP can continue after its original Section 9 application is found to have been fraudulently and collusively initiated?

Analysis: Before admission, insolvency proceedings are in personam between the initiating creditor and the corporate debtor. Upon admission, CIRP becomes an in rem and collective process: the moratorium operates, management vests in the insolvency professional, claims of all creditors are collated, and the Committee of Creditors participates in resolution. The initiating creditor consequently ceases to control the process, and withdrawal is not unilateral. The original collusive applicant must be excluded and action under the Code may follow, but the continuation of CIRP depends on a reasoned assessment of the resolution professional's submissions, the commercial wisdom of the Committee of Creditors, the interests of stakeholders, and the capacity to conduct the process with integrity and transparency.

Conclusion: CIRP need not automatically terminate because the original Section 9 application was fraudulent and collusive. The Adjudicating Authority may continue it after hearing the resolution professional, the Committee of Creditors and affected stakeholders, while disallowing the original applicant from participation.

Final Conclusion: Fraudulent initiation permits recall of insolvency admission, but does not by itself extinguish a mature collective insolvency process; continuance depends on a transparent and stakeholder-informed determination directed to the statutory objects of insolvency resolution.

Ratio Decidendi: Fraud or collusion in jurisdictional facts permits recall of CIRP admission, but an admitted CIRP may continue where the Adjudicating Authority determines that collective stakeholder interests and the statutory purpose of insolvency resolution so require.

Issues: Whether personal guarantors could invoke liberty to revive appeals dismissed upon an OTS settlement when the settlement failed due to non-performance by the principal borrower and guarantors.

Analysis: The appeals had been treated as infructuous on the basis of the OTS, subject to liberty of revival if the settlement failed. The OTS required payment of the stipulated balance amounts and cooperation by the guarantors; apart from the upfront amount, no further payment was made. The liability of the principal borrower and guarantors was co-extensive. The revival liberty applied where the settlement failed because of default by the Bank, and could not be used by guarantors to benefit from their own failure to comply with the OTS.

Conclusion: The personal guarantors were not entitled to revival of the appeals.

Issues: Whether, after expiry of the CIRP period without receipt of a resolution plan and without a valid extension, liquidation under Section 33(1)(a) of the Insolvency and Bankruptcy Code, 2016 could be deferred because the Committee of Creditors had not approved liquidation by the requisite majority and subsequently sought directions.

Analysis: The CIRP period expired without a resolution plan being received under Section 30(6) of the Insolvency and Bankruptcy Code, 2016 or a valid extension under Section 12. Section 33(1)(a) mandates liquidation in those circumstances. This statutory consequence is distinct from liquidation initiated through a Committee of Creditors resolution under Section 33(2); consequently, failure of a separate liquidation proposal to secure the requisite voting threshold does not preclude liquidation under Section 33(1)(a). Commercial wisdom operates within, and cannot override, the statutory timelines and consequences prescribed by the Code. A post-expiry Committee of Creditors resolution seeking directions, subsequent expressions of interest, or eligibility under Section 240A cannot revive an expired CIRP.

Conclusion: No. Upon expiry of the CIRP period without a resolution plan or valid extension, liquidation under Section 33(1)(a) was mandatory, and approval of liquidation by the Committee of Creditors under Section 33(2) was not a condition precedent.

Issues: Whether the Enforcement Directorate may undertake further investigation and issue summons under Section 50 of the Prevention of Money-Laundering Act, 2002 after filing its complaint but before charges are framed, without prior leave of the Special Court.

Analysis: Explanation (ii) to Section 44(1) recognises further investigation and the bringing of additional oral or documentary evidence in respect of an offence of money laundering after a complaint has been filed. The requirement of permission under the proviso to Section 193 of the Bharatiya Nagarik Suraksha Sanhita, 2023 applies to further investigation during trial. Trial commences upon framing of charges; as charges had not been framed, the matter had not entered the trial stage. Further investigation is a continuation of the original investigation, distinct from impermissible reinvestigation, and is supported by the statutory power under Section 173(8) of the Code of Criminal Procedure, 1973.

Conclusion: The Enforcement Directorate could conduct further investigation and issue the impugned summons without obtaining prior leave of the Special Court before commencement of trial.

Issues: (i) Whether the services performed under the work orders were classifiable as goods transport agency service rather than mining of mineral, oil or gas service; (ii) Whether the appellant was entitled to small-service-provider exemption for management, maintenance and repair service and supply of tangible goods service, and the consequent tax, interest and penalties; (iii) Whether the separate service-tax demand for April 2013 to March 2014 was sustainable.

Issue (i): Whether the services performed under the work orders were classifiable as goods transport agency service rather than mining of mineral, oil or gas service.

Analysis: The work orders established that transportation of coal, slurry and related material was the predominant activity, while the remaining activities were incidental or ancillary. Applying composite service classification and the essential character test, the service was to be classified according to its principal transportation element. Where consignment notes are issued, liability for goods transport agency service is attracted on the specified corporate service recipients under the reverse charge mechanism; transportation without consignment notes falls within the negative list.

Conclusion: The services were classifiable as goods transport agency service and not mining service. The mining-service tax demand, related interest and penalty under Section 78 were set aside in favour of the assessee.

Issue (ii): Whether the appellant was entitled to small-service-provider exemption for management, maintenance and repair service and supply of tangible goods service, and the consequent tax, interest and penalties.

Analysis: The turnover from these two services remained within the exemption threshold in all relevant financial years except that it exceeded the threshold by Rs. 18,958 in 2010-11. Tax was consequently payable on the excess turnover for 2010-11 and on the taxable turnover of Rs. 8,66,678 for 2011-12, aggregating to Rs. 91,221, with interest. Suppression with intent to evade was not established. The amount already deposited was directed to be appropriated towards the confirmed tax and interest.

Conclusion: Service tax of Rs. 91,221 with interest was confirmed only for the specified taxable turnover for 2010-11 and 2011-12. No penalty under Section 76 was imposable, while the penalty under Section 77 for delayed filing of returns was upheld; the issue was partly in favour of the assessee.

Issue (iii): Whether the separate service-tax demand for April 2013 to March 2014 was sustainable.

Analysis: The adjudication order contained no finding supporting this demand. Further, if the demand concerned mining service, it failed for the same classification reason; otherwise, the turnover qualified for the small-service-provider exemption.

Conclusion: The demand for April 2013 to March 2014 was set aside in favour of the assessee.

Final Conclusion: The enforceable fiscal liability was confined to the limited non-exempt turnover under management, maintenance and repair service and supply of tangible goods service, together with interest and the return-filing penalty.

Ratio Decidendi: A composite service must be classified by its essential character, and incidental activities accompanying the predominant transportation of goods do not convert it into mining service.

Issues: (i) Whether the deputation of an expatriate employee by the overseas company constituted taxable Manpower Recruitment and Supply Service?; (ii) Whether the extended period of limitation was invocable?

Issue (i): Whether the deputation of an expatriate employee by the overseas company constituted taxable Manpower Recruitment and Supply Service?

Analysis: The memorandum described the expatriate as an employee of the overseas company assigned to the assessee for a fixed and short duration. The statutory definitions cover temporary supply of manpower, and the relevant enquiry is the nature of the service provided by the overseas entity. Salary payments, tax deduction at source and issuance of Form 16 by the assessee did not alter the character of the arrangement. The binding principle governing seconded employees was applied.

Conclusion: The deputation constituted taxable Manpower Recruitment and Supply Service. This issue was decided against the assessee.

Issue (ii): Whether the extended period of limitation was invocable?

Analysis: The demand was issued after the normal period, and the Department relied on audit and investigation to allege suppression. The applied limitation principle requires deliberate withholding of material facts; discovery during audit, without a reasoned establishment of such deliberate suppression, cannot by itself justify the extended period.

Conclusion: The extended period of limitation was not invocable and the demand was time-barred. This issue was decided in favour of the assessee.

Final Conclusion: Although the service was found taxable on merits, the demand could not be sustained because the notice was barred by limitation.

Ratio Decidendi: Invocation of the extended period of limitation requires deliberate withholding of material facts; audit-based detection without a reasoned finding of such suppression is insufficient.

Issues: (i) Whether CENVAT credit could be denied on alleged non-receipt of inputs where the Revenue relied on unadmitted third-party statements, uncertified third-party electronic records and limited transport discrepancies; (ii) Whether the Director's personal penalty under Rule 26 could survive without admissible proof of his knowing participation or of goods liable to confiscation; and (iii) Whether the Rs. 8,00,000 deposit made during investigation constituted an admission of liability

Issue (i): Whether CENVAT credit could be denied on alleged non-receipt of inputs where the Revenue relied on unadmitted third-party statements, uncertified third-party electronic records and limited transport discrepancies

Analysis: Section 9D of the Central Excise Act, 1944 requires the maker of an investigative statement to be examined and the statement admitted in evidence in the interests of justice, unless a specified statutory exception applies. The dealers' and transporter's statements were directly relied upon without compliance with this mandatory procedure and were therefore unavailable to prove their contents. The electronic data extracted from a hard disk seized from a third party was also inadmissible because the statutory safeguards and certificate required by Section 36B of the Central Excise Act, 1944 were absent.

Analysis: No cogent financial trail established that payments made by the appellant-company had been returned in cash. Nor was there evidence of an alternative source of inputs, stock deficit, input-output mismatch, or transaction-specific non-transportation sufficient to displace the appellant-company's invoices, payment records, production records and duty-paid clearances. Sample vehicle-registration discrepancies and untested portal data could not establish non-receipt under every disputed invoice.

Conclusion: In favour of the assessee, the denial of CENVAT credit, consequential interest and the corporate penalty were unsustainable and were set aside.

Issue (ii): Whether the Director's personal penalty under Rule 26 could survive without admissible proof of his knowing participation or of goods liable to confiscation

Analysis: Rule 26 of the Central Excise Rules, 2002 requires transaction-specific proof of knowledge, active participation and conscious dealing with goods liable to confiscation. No admissible evidence established the Director's personal mens rea or overt involvement, and the foundation of the principal credit demand had failed.

Conclusion: In favour of the Director, the personal penalty under Rule 26 of the Central Excise Rules, 2002 was unsustainable and was set aside.

Issue (iii): Whether the Rs. 8,00,000 deposit made during investigation constituted an admission of liability

Analysis: A payment made during investigation, including one asserted to have been made under coercion or apprehension of coercive action, does not by itself amount to an unconditional admission of tax liability or establish fraudulent availment of credit.

Conclusion: The investigative deposit did not constitute an admission of liability.

Final Conclusion: The inadmissible and uncorroborated evidentiary material did not establish non-receipt of inputs or collusive availment of credit, leaving no sustainable basis for the related fiscal or personal penal consequences.

Ratio Decidendi: Third-party statements not admitted under Section 9D and electronic records not authenticated under Section 36B cannot sustain denial of CENVAT credit where independent, transaction-specific evidence does not establish non-receipt of inputs or the assessee's participation in fraud.

Issues: (i) Whether a statutory demand notice under proviso (b) to Section 138 of the Negotiable Instruments Act, 1881 is validly served when it is sent by registered post to the drawer's correct address and received by the drawer's mother; (ii) Whether the decision treating service upon a drawer's spouse as insufficient without examining the correctness of the address or shared residence is binding precedent.

Issue (i): Whether a statutory demand notice under proviso (b) to Section 138 of the Negotiable Instruments Act, 1881 is validly served when it is sent by registered post to the drawer's correct address and received by the drawer's mother.

Analysis: Proviso (b) to Section 138 requires the payee to give written notice to the drawer. Section 27 of the General Clauses Act, 1897 and Section 114 of the Indian Evidence Act, 1872 raise a rebuttable presumption of service where notice is properly addressed and dispatched by registered post. The statutory requirement concerns giving notice, not proof of its personal receipt by the drawer. Once dispatch to the correct address is established, the burden lies on the drawer to show that the address was incorrect, that the notice was not tendered, or that the drawer had no knowledge of its delivery at that address. Receipt by a family member at the shared residential address does not, by itself, rebut that presumption.

Conclusion: Dispatch of the notice by registered post to the drawer's correct address satisfied the statutory requirement of giving notice; the unrebutted presumption of valid service applied notwithstanding receipt by the drawer's mother.

Issue (ii): Whether the decision treating service upon a drawer's spouse as insufficient without examining the correctness of the address or shared residence is binding precedent.

Analysis: The earlier decision had disregarded binding larger-Bench authority establishing deemed service upon correct dispatch and had treated a spouse as equivalent to an unrelated third party without addressing whether the notice was sent to the correct address or whether the spouse resided with the drawer. Such an approach conflicts with the presumption under Section 27 of the General Clauses Act, 1897 and the settled rule that the drawer must rebut it.

Conclusion: The earlier decision was per incuriam and cannot operate as binding precedent under Article 141 of the Constitution of India.

Final Conclusion: A correctly addressed statutory notice sent by registered post attracts a rebuttable presumption of service, and the drawer cannot defeat that presumption merely because a co-residing family member received the notice.

Ratio Decidendi: For purposes of proviso (b) to Section 138 of the Negotiable Instruments Act, 1881, dispatch of a correctly addressed notice by registered post constitutes giving notice and raises a rebuttable presumption of service, which the drawer must displace by credible proof of non-service or lack of knowledge not attributable to the drawer.

Issues: Whether a merits order quashing the issuance of process warranted recall because the complainant was unrepresented when the matter was finally heard.

Analysis: The order sought to be recalled had adjudicated the complaint on merits after considering the pleadings and record and applying Sections 138 and 141 of the Negotiable Instruments Act, 1881. Although the complainant had remained absent when the matter was heard, the record reflected prior adjournments sought on its behalf and no cogent ground or infirmity was established to justify reopening the merits determination.

Conclusion: Recall of the merits order was unwarranted.

Issues: Whether refund of unutilised input tax credit under the inverted duty structure is available where bulk sulphur and packaged sulphur attract the same GST rate but packing materials attract a higher rate, notwithstanding the CBIC circulars concerning identical input and output supplies.

Analysis: Clause (ii) of the proviso to Section 54(3) of the Central Goods and Services Tax Act, 2017 permits refund where input tax credit accumulates because the tax rate on inputs exceeds that on output supplies. Packing materials used to make bulk sulphur marketable in customised packets qualify as inputs under Section 2(59), and the higher tax paid on such materials resulted in accumulated credit. Circular No. 135/05/2020-GST concerned accumulation arising from a reduction in the rate on the same goods and did not govern the stated facts. Further, instructions issued under Section 168(1) may secure uniform implementation but cannot curtail a statutory refund entitlement.

Conclusion: The taxpayer is entitled to refund of accumulated input tax credit under the inverted duty structure; the restriction urged by Revenue on the basis that input and output supplies are the same is not applicable.

Issues: (i) Whether accumulated input tax credit on higher-taxed packing materials used to package bulk sulphur is refundable under Section 54(3)(ii) of the Central Goods and Services Tax Act, 2017 notwithstanding that the principal input and output sulphur attract GST at the same rate.

Issue (i): Whether accumulated input tax credit on higher-taxed packing materials used to package bulk sulphur is refundable under Section 54(3)(ii) of the Central Goods and Services Tax Act, 2017 notwithstanding that the principal input and output sulphur attract GST at the same rate.

Analysis: Section 54(3)(ii) permits refund where input tax credit accumulates because the tax rate on inputs exceeds that on output supplies. Packing materials used for marketing sulphur in customised packets are inputs used in the course or furtherance of business; their GST rate of 18% exceeded the 5% rate on the outward supply. The restriction in the departmental circulars concerning identical input and output supplies could not curtail the statutory refund entitlement, since the power to issue directions for uniform implementation does not permit addition of restrictions absent from the statute.

Conclusion: The accumulated input tax credit attributable to the higher-taxed packing materials is refundable under Section 54(3)(ii), and the sanctioned refund remains valid.

Issues: Whether the cancellation of GST registration should be reconsidered upon the petitioner filing a reply and explaining the factual position regarding exempt supplies.

Analysis: The assertion that the petitioner was supplying exempt goods and regularly filing returns raised a factual matter requiring consideration upon a reply to the show-cause notice and an opportunity of hearing.

Outcome: The cancellation order was quashed and the matter was remitted for a fresh order on merits.

Issues: Whether the petitioner could be permitted to submit an application for revocation of cancellation of GST registration where the online portal did not accept the application.

Analysis: The registration had been cancelled for non-filing of returns, the statutory appeal against cancellation had been rejected as time-barred, and the portal did not permit filing of an application for revocation beyond the prescribed period. No final adjudication on the merits of revocation was made.

Outcome: The petitioner was granted liberty to submit the revocation application online within two weeks or physically if prevented by technical reasons; the competent authority was directed to entertain and decide it in accordance with law within three weeks thereafter.

Issues: Whether absence of express irrevocability and dissolution clauses in a charitable trust deed justifies rejection of registration under Section 12AB and consequential approval under Section 80G.

Analysis: A public charitable trust is deemed irrevocable unless its trust instrument expressly confers a power of revocation. The absence of an express irrevocability clause is therefore not a statutory ground to reject registration under Section 12AB. Further, absence of a dissolution clause or specification of the destination of net assets upon dissolution cannot independently justify denial of registration, since concerns regarding transfer of such assets are addressed under Section 115TD. The trust's charitable activities and unchanged objects supported grant of registration.

Conclusion: Absence of irrevocability and dissolution clauses does not justify rejection of registration under Section 12AB or consequential denial of approval under Section 80G; registration and approval are to be granted.

Issues: Whether cognizance of an offence on an Enforcement Directorate complaint filed after commencement of the Bharatiya Nagarik Suraksha Sanhita, 2023 could be taken without first giving the accused an opportunity of being heard.

Analysis: A complaint under Section 44(1)(b) of the Prevention of Money Laundering Act, 2002, filed after 1 July 2024, is governed by the complaint procedure under the Bharatiya Nagarik Suraksha Sanhita, 2023. The proviso to Section 223(1) creates a mandatory audi alteram partem safeguard by barring cognizance unless the accused is afforded an opportunity of hearing. The earlier registration of the ECIR does not displace this requirement for a subsequently filed complaint.

Conclusion: Cognizance taken without first hearing the accused on such a post-commencement complaint is illegal and impermissible.

Issues: (i) Whether the holding period of the allotted flat must be reckoned from the allotment letter rather than the registered conveyance deed, making the resultant gain long-term capital gain and allowing indexation and deduction under section 54; (ii) Whether the allotment letter constituted an agreement for applying the first and second provisos to section 56(2)(vii)(b), thereby requiring use of the stamp-duty value on the allotment date.

Issue (i): Whether the holding period of the allotted flat must be reckoned from the allotment letter rather than the registered conveyance deed, making the resultant gain long-term capital gain and allowing indexation and deduction under section 54.

Analysis: Sections 2(29A) and 2(42A) classify an asset by the period for which it is held, rather than by the date on which formal conveyance is registered. The allotment of an identified flat conferred enforceable rights in the property, and payments were made under the allotment arrangement. Subsequent registration of the conveyance deed did not determine the commencement of the holding period.

Conclusion: The holding period commenced from the date of allotment. The property was a long-term capital asset when sold, and the assessee is entitled to indexation and deduction under section 54 in accordance with law. This issue is decided in favour of the assessee.

Issue (ii): Whether the allotment letter constituted an agreement for applying the first and second provisos to section 56(2)(vii)(b), thereby requiring use of the stamp-duty value on the allotment date.

Analysis: The first proviso permits adoption of stamp-duty value as on the date of an agreement where that date differs from registration, and the second proviso requires whole or part consideration to have been paid by a non-cash mode on or before the agreement date. The allotment letter, containing the material terms of acquisition, was an agreement for this purpose; part consideration had also been paid through banking channels before its issue.

Conclusion: The stamp-duty value as on the allotment date must be adopted for section 56(2)(vii)(b), not the value as on registration. The valuation-based addition requires recomputation by the Assessing Officer. This issue is decided in favour of the assessee.

Final Conclusion: The sale must receive long-term capital-gain treatment, and the valuation-based income determination must be recomputed by reference to the stamp-duty value prevailing on the date of the agreement/allotment.

Ratio Decidendi: For immovable property acquired under an allotment arrangement, the relevant property rights are held from the date of allotment; where consideration is paid by non-cash modes before that agreement, the statutory stamp-duty comparison is made with the value on the agreement date rather than the registration date.

Issues: (i) Whether a separate 4% profit addition could be made on subcontract expenditure where the related original contract receipts and profit were recorded in the books; (ii) Whether the donation disallowance was sustainable in the absence of supporting receipts; and (iii) Whether PF late-payment charges representing interest and damages were respectively deductible.

Issue (i): Whether a separate 4% profit addition could be made on subcontract expenditure where the related original contract receipts and profit were recorded in the books.

Analysis: The subcontracted work formed part of the original civil-contract work, whose receipts had already been recorded and subjected to tax. Payments to subcontractors were made through banking channels with tax deducted at source. Estimating a further profit on the same subcontract expenditure would result in double taxation of income already reflected in the books.

Conclusion: The separate estimated-profit addition on subcontract expenditure was unwarranted and was deleted, in favour of the assessee.

Issue (ii): Whether the donation disallowance was sustainable in the absence of supporting receipts.

Analysis: Deduction under Section 80G of the Income-tax Act, 1961 requires supporting receipts and evidence from an eligible institution. Although banking entries were produced, receipts for a substantial part of the claimed donation were unavailable; the deduction had already been allowed to the extent supported by receipts.

Conclusion: The disallowance of Rs. 79,000 was sustained, against the assessee.

Issue (iii): Whether PF late-payment charges representing interest and damages were respectively deductible.

Analysis: The payment challans showed that the disputed amount comprised both interest and damages. Compensatory interest under Section 7Q of the Employees' Provident Funds and Miscellaneous Provisions Act, 1952 is allowable expenditure, whereas damages under Section 14B of that Act are penal in character and are not deductible under Section 37(1) of the Income-tax Act, 1961. The available record did not provide the necessary bifurcation.

Conclusion: The interest component is allowable and the damages component is disallowable; determination of their respective amounts was remitted for verification, partly in favour of the assessee.

Final Conclusion: The assessed income must be reduced by the deleted subcontract-profit addition, while the donation disallowance remains intact and the PF claim is to be recomputed according to its interest and damages components.

Issues: Whether reassessment for an assessment year falling beyond six years from the search could be sustained where additions for unexplained cash receipts and cash expenditure were not shown to represent income in the form of a qualifying asset.

Analysis: The transitional bar in the first proviso to Section 149 required examination of whether a notice could validly have been issued under the pre-Finance Act 2021 search-assessment regime. For a year beyond the six-year period, the extended period under Section 153A/153C was available only where material in the Assessing Officer's possession revealed escaped income represented in the form of an asset of the prescribed value. The additions under Sections 69A and 69C were founded on alleged cash receipts and cash expenditure, but no undisclosed land, building, shares, securities, loans, advances, bank deposits, financial interest, or other qualifying asset for the relevant year was found or evidenced. A statement recorded during search did not establish the separate statutory asset condition.

Conclusion: The extended limitation was unavailable and the reassessment for the year beyond six years was invalid; the relief granted against the additions was sustained.

Issues: Whether the revenue's and assessee's cross-appeals for the relevant assessment years survived after giving-effect orders, applying an approved resolution plan, recomputed taxable income at nil and eliminated the tax demands.

Analysis: The giving-effect orders issued pursuant to the approved resolution plan in the Corporate Insolvency Resolution Process treated revenue claims not included in that plan as extinguished. The binding effect of an approved resolution plan on statutory authorities resulted in nil income and no demand for each assessment year.

Conclusion: The cross-appeals did not survive for adjudication and were infructuous.