Binding effect of approved resolution plan on statutory tax liabilities upheld, postapproval tax demands held invalid and review dismissed.

An approved resolution plan was held to bind statutory tax liabilities such that tax demands raised after plan approval for earlier assessment years were invalid; the court reviewed the matter on merits despite a 208day delay in filing and found no basis to overturn the earlier conclusion that the plan approved on 21 May 2019 precluded the subsequent demands for the relevant assessment years. Consequently the postapproval income tax demands were invalidated, and the review petition was dismissed both for inordinate delay and on substantive grounds.

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Issues: Whether the Review Petition seeking review of the judgment dated 20.03.2025 should be entertained despite a 208-day delay and whether the petition merits review on merits.

Analysis: The Review Petition was examined on two aspects: (i) delay in filing of 208 days without a satisfactory explanation, and (ii) merits of the review. On the delay aspect, the filing period was not adequately explained, and no justification was found to condone the delay. On the merits aspect, the review material was considered and found not to establish any error or ground warranting review of the earlier judgment dated 20.03.2025.

Conclusion: The Review Petition is dismissed on the ground of delay and on merits; the result is adverse to the petitioner and favourable to the assessee.

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