Insolvency jurisdiction supports sale deed execution where land had already vested in the corporate debtor and the resolution plan required title perfection.

Delay in filing the appeal was condoned under the proviso to Section 61(2) of the Insolvency and Bankruptcy Code because the appeal was filed within the condonable period, the appellant had later knowledge of the order, and no deliberate delay was shown. The transaction over the subject land was treated as concluded in favour of the corporate debtor because contemporaneous documents, possession, payment treatment, and asset records showed that the sellers had divested their interest. The Adjudicating Authority also had jurisdiction under Section 60(5) to direct execution of the sale deed, as the relief was directly connected with implementation of the approved resolution plan and perfecting title to a corporate debtor asset.

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Issues: (i) Whether the delay in filing the appeal could be condoned under the proviso to Section 61(2) of the Insolvency and Bankruptcy Code, 2016. (ii) Whether the transaction concerning the subject land was a concluded transaction in favour of the corporate debtor so as to justify direction for execution of the sale deed. (iii) Whether the Adjudicating Authority had jurisdiction under Section 60(5) of the Insolvency and Bankruptcy Code, 2016 to direct execution of the sale deed in aid of the resolution plan.

Issue (i): Whether the delay in filing the appeal could be condoned under the proviso to Section 61(2) of the Insolvency and Bankruptcy Code, 2016.

Analysis: The appeal was filed beyond the initial limitation period but within the further condonable period. The explanation offered was that the appellant was not a party before the Adjudicating Authority and acquired knowledge of the impugned order later. The delay did not cross the statutory outer limit for condonation, and no deliberate or intentional delay was found.

Conclusion: The delay was rightly condoned and the appeal was maintainable.

Issue (ii): Whether the transaction concerning the subject land was a concluded transaction in favour of the corporate debtor so as to justify direction for execution of the sale deed.

Analysis: The record showed execution of the memorandum of understanding, agreement to sell, registered power of attorney, and deed of possession. The consideration was treated as paid in the contemporaneous documents, possession had been delivered, the land was reflected as an asset of the corporate debtor, and the assignment and possession arrangements showed that the sellers had divested their interest. The unregistered character of the agreement to sell and assignment deed did not displace the factual finding that the transaction had substantially been completed before the relevant legal challenge.

Conclusion: The corporate debtor had acquired rights and interest in the subject land, and direction to execute the sale deed was justified.

Issue (iii): Whether the Adjudicating Authority had jurisdiction under Section 60(5) of the Insolvency and Bankruptcy Code, 2016 to direct execution of the sale deed in aid of the resolution plan.

Analysis: The dispute arose in relation to implementation of the approved resolution plan and perfecting title over an asset treated as belonging to the corporate debtor. The jurisdiction under Section 60(5) extends to questions of law or fact arising out of or in relation to insolvency resolution proceedings, provided there is a real nexus with the insolvency process. On the facts, the request for execution of the sale deed was directly connected with implementation of the resolution plan and did not trench upon an unrelated civil dispute.

Conclusion: The Adjudicating Authority acted within jurisdiction in issuing directions for execution of the sale deed.

Final Conclusion: The appeal was found meritless, the impugned order was sustained, and the directions for execution of the sale deed to implement the resolution plan were upheld.

Ratio Decidendi: Where a disputed property is shown, on contemporaneous documents and conduct, to have already vested in the corporate debtor and the relief sought is only to perfect title for implementing an approved resolution plan, the insolvency tribunal may exercise jurisdiction under Section 60(5) of the Insolvency and Bankruptcy Code, 2016 to issue consequential directions.

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