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Recovery of Service Tax dues, of a Company which is under liquidation applying IBC, 2016 - It is thus beyond the two years preceding the commencement of liquidation date and the Company having been liquidated and the respondent having failed to lodge any claim under IBC at any stage of the proceeding under IBC and the sale proceeds having been distributed in terms of the waterfall it may not be permissible to sustain the impugned demand notice. - HC