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Issues: Whether the tax appeals could be continued after approval of the resolution plan under the Insolvency and Bankruptcy Code, 2016, and whether claims not forming part of the approved plan stood extinguished.
Analysis: Once the Adjudicating Authority approves a resolution plan under Section 31(1) of the Insolvency and Bankruptcy Code, 2016, the plan binds the corporate debtor and all stakeholders, including statutory creditors. Claims not included in the approved plan cease to survive, and proceedings to recover such dues cannot be continued. The Tribunal also noted that, in the absence of any express provision in the approved plan permitting continuation of the pending appeals, the Tribunal could not proceed further and had no jurisdiction to adjudicate the merits.
Conclusion: The pending appeals could not be continued and were liable to be disposed of in view of the approved resolution plan.
Final Conclusion: The approval of the resolution plan brought the pending tax appeals to an end, as the Tribunal lacked authority to proceed where continuation was not preserved in the plan.
Ratio Decidendi: Approval of a resolution plan under Section 31(1) of the Insolvency and Bankruptcy Code, 2016 renders all unprovided claims unenforceable and bars continuation of pending proceedings unless the plan expressly permits them.