Approved resolution plan bars revival of pre-approval tax claims through later reassessment proceedings.

Approved resolution plans under insolvency proceedings extinguish pre-approval tax liabilities and claims, so they cannot later be revived through reassessment for the prior period. Applying the clean slate principle and binding precedent, the court held that once the resolution plan was sanctioned, the tax department was bound by its treatment of earlier-period claims. Accordingly, reassessment proceedings and the connected notice under Sections 148 and 142(1) of the Income-tax Act, 1961 were quashed, and the assessee obtained relief.

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Issues: Whether reassessment and consequential notice could be sustained for a period prior to approval of the resolution plan after the plan had been approved under insolvency proceedings.

Analysis: The approved resolution plan provided for extinguishment of pre-approval tax liabilities and claims. Once the resolution plan stood approved, the tax department's claims for the earlier period were bound by the plan and could not be revived through a notice seeking reassessment of escaped income for that prior period. The issue was treated as covered by binding precedent recognising that an approved resolution plan operates on a clean slate and bars belated claims.

Conclusion: The reassessment notice under Section 148 of the Income-tax Act, 1961 and the consequential notice under Section 142(1) of the Income-tax Act, 1961 were quashed and set aside in favour of the assessee.

Final Conclusion: Pre-resolution-plan tax claims for the relevant assessment year could not be pursued after approval of the resolution plan, and the writ petition succeeded.

Ratio Decidendi: Once a resolution plan is approved, pre-approval claims and liabilities stand governed by the plan and cannot be enforced through subsequent reassessment proceedings for the earlier period.

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