SC affirms resolution plan finality, bars post-approval tax revisions under s.263 against insolvent companies entirely

SC dismissed the revenue's SLP challenging the order relating to revision under s.263 against an insolvent company. Relying on its earlier decision on the binding nature of an approved resolution plan, SC held that once the plan is approved by NCLT, no belated statutory dues claim, including tax demands not earlier raised, can be incorporated. Entertaining such post-approval claims would defeat the objective of giving the corporate debtor a fresh start and impede recommencement of business on a clean slate.

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The Supreme Court condoned the delay in filing the Special Leave Petition (SLP) but declined to interfere with the impugned order. The Revenue's counsel expressly stated that the controversy in this matter is covered by the Court's earlier decision in "Vaibhav Goel & Anr. v. Deputy Commissioner of Income Tax & Anr. (2025 INSC 375)." Accepting this position, the Court held that, "In view of the above, the Special Leave Petition stands dismissed." Thus, the dismissal is grounded on the binding precedent in *Vaibhav Goel*, reflecting application of stare decisis where the issues are identical or substantially similar. All pending applications were also disposed of as a consequence of the SLP's dismissal.

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