Issues: (i) Whether the show-cause notice was invalid because it was issued by an Assistant Commissioner and later corrected by corrigendum, and for want of pre-notice consultation; (ii) Whether differential customs duty could be demanded under Section 28 without first challenging self-assessment; (iii) Whether the imported CKD e-bike components were classifiable as complete electrically operated motorcycles under CTH 87116020; (iv) Whether the goods qualified for concessional duty under Serial No. 531A(1), or alternatively Serial No. 531A(2), of Notification No. 50/2017-Customs dated 30.06.2017; (v) Whether confiscation and penalty were sustainable.

Issue (i): Whether the show-cause notice was invalid because it was issued by an Assistant Commissioner and later corrected by corrigendum, and for want of pre-notice consultation.

Analysis: An officer designated as an officer of customs under Section 2(34) of the Customs Act, 1962 is a proper officer for the assigned function. A corrigendum issued before adjudication that merely corrected the clause making the notice answerable to the Principal Commissioner caused no prejudice and related back to the notice. The record also showed receipt of the pre-consultative letter.

Conclusion: The show-cause notice and adjudication proceedings were valid, against the assessee.

Issue (ii): Whether differential customs duty could be demanded under Section 28 without first challenging self-assessment.

Analysis: Recovery proceedings for duty not levied or not paid under Section 28 of the Customs Act, 1962 are distinct from refund proceedings. The existence of self-assessment did not bar issuance of a notice for recovery of differential duty.

Conclusion: Differential duty could be demanded under Section 28 without prior challenge to self-assessment, against the assessee.

Issue (iii): Whether the imported CKD e-bike components were classifiable as complete electrically operated motorcycles under CTH 87116020.

Analysis: Rule 2(a) of the General Rules for the Interpretation of the First Schedule to the Customs Tariff Act, 1975 requires classification by the identity and essential character of goods as presented for assessment. An incomplete vehicle may retain the essential character of a complete vehicle despite absence of items such as a battery or charger. The imported goods were declared as e-bikes in CKD condition with pre-assembled essential parts and components.

Conclusion: The goods possessed the essential character of complete electrically operated motorcycles and were correctly classified under CTH 87116020, against the assessee.

Issue (iv): Whether the goods qualified for concessional duty under Serial No. 531A(1), or alternatively Serial No. 531A(2), of Notification No. 50/2017-Customs dated 30.06.2017.

Analysis: The exemption under Serial No. 531A(1) required a knocked-down kit containing all necessary components for assembly of the complete vehicle. Battery packs, chargers and electric compressors were admittedly not imported. The alternative exemption had not been claimed in the Bills of Entry and could not be claimed subsequently.

Conclusion: The claimed concessional and alternative exemption benefits were unavailable, against the assessee.

Issue (v): Whether confiscation and penalty were sustainable.

Analysis: Confiscation under Section 111(m) of the Customs Act, 1962 and imposition of redemption fine are legally distinct. The absence of redemption fine did not invalidate confiscation or the penalty under Section 112(a)(ii) of the Customs Act, 1962.

Conclusion: The confiscation and penalty were sustainable, against the assessee.

Final Conclusion: The denial of the claimed exemption and the consequential customs liability were maintained.

Issues: Whether the impugned orders, being consequential implementation of prior binding appellate directions, warranted appellate interference.

Analysis: The order under challenge merely reiterated earlier appellate directions, already affirmed by the Supreme Court, and supplied no independent factual or legal finding affecting the merits of the company petition. The connected directions were consequential compliance measures. Entertaining the challenge would indirectly reopen the affirmed appellate directions.

Conclusion: The consequential orders did not warrant appellate interference and remain governed by the finality of the prior affirmed directions.

Issues: Whether cancellation, refund and no-show charges recovered by an airline from passengers constitute consideration for a distinct declared service of agreeing to tolerate an act.

Analysis: Section 66E(e) of the Finance Act, 1994 applies where an agreement is intended to tolerate an act for consideration. The passenger-airline contract is intended for carriage of the passenger in return for fare; cancellation charges operate only upon the passenger's failure to perform that contract. Such charges are liquidated damages compensating the airline for breach and do not arise from a separate agreement to tolerate cancellation or default. The absence of a service charge makes the question of abatement immaterial.

Conclusion: Cancellation, refund and no-show charges are compensation for breach of contract and are not taxable as consideration for tolerating an act under Section 66E(e) of the Finance Act, 1994.

Issues: Whether tender fee collected for supplying tender documents is consideration for a taxable service liable to service tax.

Analysis: Service tax under Section 65B(44) of the Finance Act, 1994 requires an identifiable service provided for consideration. The prescribed tender fee was the cost of supplying tender documents and constituted sale or supply of documents, rather than a service rendered to bidders. A tender is merely an invitation to offer and does not create a contractual service arrangement between the tendering authority and every purchaser of tender documents.

Conclusion: Tender fee collected towards supply of tender documents is not consideration for a taxable service and is not liable to service tax; decided in favour of the assessee.

Issues: Whether the extended period of limitation could be invoked for recovery of service tax from a subcontractor where conflicting decisions had created uncertainty about the subcontractor's tax liability after payment of tax by the main contractor.

Analysis: The substantive tax liability of a subcontractor stood settled by the Larger Bench decision. However, prior conflicting Tribunal decisions had generated genuine uncertainty on whether a subcontractor was independently liable where the main contractor had paid service tax. This acknowledged confusion supported the appellant's bona fide belief and precluded invocation of the extended limitation period under Section 73(1) of the Finance Act, 1994. The normal limitation period remained unaffected.

Conclusion: The extended-period demand and the penalty under Section 78 of the Finance Act, 1994, were set aside; the demand for the normal period and the penalty under Section 72 of the Finance Act, 1994, were sustained. The issue was decided partly in favour of the assessee.

Issues: (i) Whether the relevant date for limitation of refund of accumulated CENVAT credit attributable to export of services is the date of the export invoice or the last day of the quarter in which foreign exchange is received; and (ii) Whether refund of CENVAT credit can be denied solely because the invoices relate to unregistered premises.

Issue (i): Whether the relevant date for limitation of refund of accumulated CENVAT credit attributable to export of services is the date of the export invoice or the last day of the quarter in which foreign exchange is received.

Analysis: Rule 5 of the CENVAT Credit Rules, 2004, read with Notification No. 27/2012-C.E. (N.T.) dated 18.06.2012, governed the refund. Although Section 11B of the Central Excise Act, 1944 applied to such refund claims, it did not prescribe a specific relevant date for export of services. The applicable principle fixed the relevant date as the last day of the quarter in which the export proceeds were received in foreign exchange. The date of the export invoice could not invariably be adopted, and the prospective character of the subsequent notification did not displace that principle.

Conclusion: The one-year limitation is to be reckoned from the last day of the quarter in which foreign exchange is received, and not from the date of the export invoice. The issue is decided in favour of the assessee.

Issue (ii): Whether refund of CENVAT credit can be denied solely because the invoices relate to unregistered premises.

Analysis: Rule 5 of the CENVAT Credit Rules, 2004, did not make registration of the premises a prerequisite for refund of unutilised CENVAT credit attributable to exported services. The requirement concerning the jurisdictional authority for filing the refund application could not operate as a prohibition on refund merely because the premises from which services were exported were unregistered. The jurisdictional High Court ruling on this point was binding.

Conclusion: Refund cannot be denied merely because the invoices pertain to unregistered premises. The issue is decided in favour of the assessee.

Final Conclusion: The limitation objection based on the export-invoice date and the objection based solely on non-registration of premises cannot defeat the refund claim.

Issues: (i) Whether service tax on construction of the residential complex was sustainable under Construction of Residential Complex Service; (ii) Whether receipts accounted for as sub-contract and petty job receipts were liable to service tax under the same category; and (iii) Whether the demand under Renting of Immovable Property Service was sustainable.

Issue (i): Whether service tax on construction of the residential complex was sustainable under Construction of Residential Complex Service.

Analysis: The statutory definition of a residential complex required proof that the prescribed conditions, including the number of dwelling units, were satisfied. The material did not establish that the additional units were constructed by, or attributable to, the appellant. Further, the Explanation inserted in Section 65(105)(zzzh) with effect from 01.07.2010 could not be retrospectively applied to construction undertaken before that date. The contracts were composite contracts involving goods and services; such contracts could not be taxed under the construction-service categories, which applied to services simpliciter.

Conclusion: The construction-service demand was unsustainable, in favour of the assessee.

Issue (ii): Whether receipts accounted for as sub-contract and petty job receipts were liable to service tax under the same category.

Analysis: The receipts were treated as consideration for construction services without establishing their precise nature or that they represented independently taxable services simpliciter. The absence of documents from the appellant did not displace the Department's obligation to prove the taxable service and its legal basis. The reasoning applicable to composite works contracts also precluded their taxation under the construction-service category.

Conclusion: The demand on sub-contract and petty job receipts was unsustainable, in favour of the assessee.

Issue (iii): Whether the demand under Renting of Immovable Property Service was sustainable.

Analysis: Commercial letting alone did not establish the amount of tax payable. The eligibility for small service provider exemption, year-wise rental receipts, and the asserted tax payment on later receipts required verification. The allegations were not supported by sufficient evidence or cogent rebuttal of these matters; consequently, the evidentiary benefit enured to the appellant.

Conclusion: The demand under Renting of Immovable Property Service was unsustainable, in favour of the assessee.

Final Conclusion: The construction-related and rental demands lacked a sustainable legal and evidentiary basis, and the associated penalties could not survive.

Issues: (i) Whether sewage and drainage pumps were eligible for the concessional duty rate under Entry No. 235 of Notification No. 12/2012-C.E. dated 17.03.2012; (ii) Whether the earlier audit objection or the principle of res judicata precluded Revenue from denying the concessional rate; (iii) Whether the penalty imposed for availing the concessional rate was sustainable.

Issue (i): Whether sewage and drainage pumps were eligible for the concessional duty rate under Entry No. 235 of Notification No. 12/2012-C.E. dated 17.03.2012.

Analysis: Entry No. 235 grants the concessional rate only to power-driven pumps primarily designed for handling water. As the expression "water" is undefined, it was construed in its common and commercial sense as clean water, and not as sewage or drainage water. A claimant for a concessional notification must establish clear compliance with its conditions. The material showed that sewage and drainage pumps had a different design and manufacturing process from pumps for handling water; the engineer's certificate only stated that the pumps could also handle clean water and did not establish design similarity.

Conclusion: Sewage and drainage pumps were not eligible for the concessional rate under Entry No. 235; the differential duty and applicable interest were rightly sustained, against the assessee.

Issue (ii): Whether the earlier audit objection or the principle of res judicata precluded Revenue from denying the concessional rate.

Analysis: The audit objection was neither implemented through adjudication nor accepted by the assessee, which continued to pay duty at the full rate until March 2016. It therefore did not constitute a concluded determination capable of binding Revenue. Further, res judicata does not apply to distinct tax periods in the manner asserted, and a different position may be adopted where the prior view is not a binding final decision.

Conclusion: The earlier audit objection did not bar Revenue from denying the concessional rate, against the assessee.

Issue (iii): Whether the penalty imposed for availing the concessional rate was sustainable.

Analysis: The assessee had initially paid duty at the full rate and began claiming the concession after the audit objection. Revenue subsequently reversed its position and demanded differential duty. These circumstances did not disclose evidence warranting the penalty retained by the appellate authority.

Conclusion: The penalty was unsustainable and was set aside, in favour of the assessee.

Final Conclusion: The differential duty together with interest remains enforceable, while no penalty is exigible.

Ratio Decidendi: A claimant for a concessional excise notification must establish strict satisfaction of its conditions, and an undefined product expression is to be understood in its common-parlance meaning.

Issues: (i) Whether the claimed transitional input tax credit attributable to input services, exceeding the closing balance reflected in the ER-1 and ST-3 returns, required verification. (ii) Whether the notice under section 74(1) could be sustained on the alleged wilful misstatement or suppression of facts.

Issue (i): Whether the claimed transitional input tax credit attributable to input services, exceeding the closing balance reflected in the ER-1 and ST-3 returns, required verification.

Analysis: Section 140(1) permits carry-forward of eligible credit under the existing law. The difference between the credit declared in TRAN-1 and the balance reported in the pre-GST returns required verification against the relevant records before entitlement could be determined.

Conclusion: The transitional credit claim is to be verified by the Proper Officer/Adjudicating Authority through a reasoned order.

Issue (ii): Whether the notice under section 74(1) could be sustained on the alleged wilful misstatement or suppression of facts.

Analysis: Invocation of section 74(1) requires material establishing fraud, wilful misstatement, or suppression of facts with a deliberate intent to evade tax. Mere incorrect information or an ordinary non-declaration does not by itself establish those elements. No investigation or evidence establishing such deliberate intent was on record.

Conclusion: The notice issued under section 74(1) was not sustainable, in favour of the assessee.

Final Conclusion: The transitional-credit claim remains subject to factual verification, but the fraud-based notice cannot be maintained.

Ratio Decidendi: An incorrect declaration, without material evidence of a deliberate intent to evade tax, does not establish wilful misstatement or suppression of facts for invoking section 74(1).

Issues: Whether the extended period of limitation could be invoked on an allegation of suppression of facts.

Analysis: The differential demand arose from an audit-based verification of the assessee's books of account and invoices, with a prior departmental communication quantifying the liability. The record disclosed no material establishing deliberate suppression of facts or an intent to evade tax. Mere delayed payment and detection upon scrutiny of accounts were insufficient to invoke the extended period of limitation. A show-cause notice issued beyond the normal limitation period raises a jurisdictional challenge and cannot sustain the demand.

Conclusion: The extended period of limitation was not invocable; the show-cause notice and consequential demand were time-barred, in favour of the assessee.

Issues: Whether GST registration could be cancelled for non-production of a rent agreement for an additional place of business despite proof of the principal place of business.

Analysis: Section 29(2)(a) of the Central Goods and Services Tax Act, 2017, read with Rule 21 of the Central Goods and Services Tax Rules, 2017, permits cancellation where the prescribed contraventions are established, including where no business is conducted from a declared place of business. Rule 25 contemplates physical verification of business premises in specified cases. Rule 8 and Form REG-01 require documentary proof concerning the principal place of business; they do not prescribe submission of a rent agreement for an additional place of business as a condition for continuation of registration. The petitioner had furnished proof for the undisputed principal place of business, while the cancellation notice and order rested solely on absence of a rent agreement for the additional place.

Conclusion: Cancellation of registration on that ground was contrary to the statutory scheme; the show-cause notice and cancellation order were quashed and the GST registration was restored from the date of suspension.

Issues: (i) Whether retention money, previously included in income and written off as irrecoverable, was deductible as bad debt under Section 36(1)(vii) read with Section 36(2). (ii) Whether the entire rent paid to related parties could be disallowed under Section 40A(2)(b) absent material establishing excessiveness or unreasonableness having regard to fair market value.

Issue (i): Whether retention money, previously included in income and written off as irrecoverable, was deductible as bad debt under Section 36(1)(vii) read with Section 36(2).

Analysis: The retained sums formed part of the gross invoice amounts recognised as income in the relevant earlier years and were reflected as receivables. On forfeiture by the contracting authority, the amounts were written off in the accounts for the relevant previous year. Following the post-1989 position under Section 36(1)(vii), proof that the debt became irrecoverable in a particular year was not required once it was actually written off; the requirement of prior inclusion in income under Section 36(2) stood satisfied.

Conclusion: The bad-debt claim was allowable and the disallowance was deleted, in favour of the assessee.

Issue (ii): Whether the entire rent paid to related parties could be disallowed under Section 40A(2)(b) absent material establishing excessiveness or unreasonableness having regard to fair market value.

Analysis: Section 40A(2)(b) permits disallowance only to the extent a related-party payment is excessive or unreasonable having regard to the fair market value of the goods, services or facilities. No comparable material or other evidence established that the rent was excessive or unreasonable. A disallowance founded merely on suspicion or an allegation that the transaction was not revenue-neutral lacked a factual foundation under the provision.

Conclusion: The rent disallowance was unsustainable and was deleted, in favour of the assessee.

Final Conclusion: The disallowances of bad debts and related-party rent payments cannot be sustained.

Issues: Whether global-ranking support, institutional facilitation and coordination services constituted business activities eligible for presumptive taxation under section 44AD rather than a specified profession attracting section 44ADA.

Analysis: Section 44ADA applies only where the assessee carries on a profession referred to in section 44AA(1). The statutory test is the substance and actual nature of the services, not merely the use of expressions such as advisory or consultancy in agreements, nor the payer's withholding treatment under section 194J. The services comprised institutional support, stakeholder coordination, data organisation, reporting, benchmarking and operational guidance for improving educational rankings. They did not amount to legal, medical, engineering, architectural, accountancy, interior-decoration, technical consultancy, or any notified profession. The material also did not establish commission, brokerage or agency business excluded under section 44AD(6). Since the premise that section 44ADA applied was unsustainable, the estimation of income at 70% of gross receipts on that basis lacked a sustainable statutory foundation.

Conclusion: The services were business activities and not a specified profession under section 44AA(1); section 44ADA and the consequential 70% income estimation were unsustainable, and the income offered under section 44AD was required to be accepted.

Issues: Whether non-deduction of tax under Section 195 of the Income-tax Act, 1961 justified disallowance under Section 40(a)(i) of the Income-tax Act, 1961 of commission paid to a United States non-resident entity.

Analysis: The obligation to withhold tax under Section 195 arises only where the remitted sum is chargeable to tax in India. A Tax Residency Certificate is relevant to claiming treaty relief under Section 90(4) of the Income-tax Act, 1961, but its absence does not itself create a domestic tax charge where the income is otherwise not chargeable. The material showed that the commission was for services rendered outside India and that the recipient had no business operations, office, or Permanent Establishment in India. Revenue established neither rendition of services in India nor a sufficient nexus for the commission income to accrue or arise in India. The description of the remittance as consulting services in Form 15CB was not determinative; the transaction's substance had to be ascertained from the underlying agreement, invoices, and actual services.

Conclusion: The commission paid to the non-resident entity was not chargeable to tax in India; consequently, no tax was deductible under Section 195 of the Income-tax Act, 1961, and the corresponding disallowance under Section 40(a)(i) of the Income-tax Act, 1961 was unsustainable, in favour of the assessee.

Issues: (i) Whether penalty under Section 112(a)(i) of the Customs Act, 1962 could be imposed for an act rendering the goods liable to confiscation or for abetment of such act; (ii) Whether penalty under Section 114AA of the Customs Act, 1962 could be imposed for knowingly or intentionally making, signing, using, or causing the use of a false document.

Issue (i): Whether penalty under Section 112(a)(i) of the Customs Act, 1962 could be imposed for an act rendering the goods liable to confiscation or for abetment of such act.

Analysis: Section 112(a)(i) requires proof that the person committed or omitted an act that rendered the goods liable to confiscation, or abetted such act. The respondent was neither the importer, declarant, nor Customs Broker, and had only introduced persons and forwarded documents to the licensed Customs Broker. The concealment and misdeclaration had occurred before that role. No evidence established that the respondent knew of the import or concealment, was a beneficiary, or participated in or abetted the acts rendering the goods confiscable.

Conclusion: Penalty under Section 112(a)(i) was not sustainable; the issue was decided in favour of the assessee.

Issue (ii): Whether penalty under Section 114AA of the Customs Act, 1962 could be imposed for knowingly or intentionally making, signing, using, or causing the use of a false document.

Analysis: Section 114AA applies only where knowing or intentional involvement in making, signing, using, or causing use of a false document is proved. The record did not establish that the respondent prepared any invoice or declaration, knew of the concealed goods, or knowingly used or caused the use of any false document.

Conclusion: Penalty under Section 114AA was not sustainable; the issue was decided in favour of the assessee.

Final Conclusion: The essential statutory prerequisites for imposing either penalty were not established by evidence.

Ratio Decidendi: Penalties for abetment of acts rendering goods confiscable and for false documents require proof of the person's knowing participation in the relevant prohibited act or document; mere introduction of persons or forwarding of documents is insufficient.

Issues: Whether a service-tax demand for the extended period can be sustained solely on Form 26AS and income-tax-return data without independent corroborative evidence of taxable services.

Analysis: Form 26AS and income-tax-return figures, maintained for tax-deduction purposes on a receipt basis, do not by themselves establish the taxable value or rendition of taxable services for service-tax purposes. Independent verification of the nature of receipts and corroborative evidence are necessary. The adjudicating authority had not properly addressed the explanation regarding differences between billing-based service-tax liability and figures reflected in Form 26AS.

Conclusion: The demand confirmed for the extended period solely on CBDT data was set aside; service-tax liability, if any, for the normal period together with interest remained payable.

Issues: (i) Whether road transportation without issue of a consignment note is taxable as Goods Transport Agency service; and (ii) whether transportation of food-grains is taxable as Goods Transport Agency service.

Issue (i): Whether road transportation without issue of a consignment note is taxable as Goods Transport Agency service.

Analysis: Section 65B(26) of the Finance Act, 1994 defines a Goods Transport Agency as a person providing road transport service who issues a consignment note. Since no consignment notes were issued, the activity did not qualify as Goods Transport Agency service. Transportation of goods by road other than by a Goods Transport Agency or courier agency falls within the negative list under Section 66D(p)(i) of the Finance Act, 1994.

Conclusion: The road transportation activity was not taxable as Goods Transport Agency service and was in favour of the assessee.

Issue (ii): Whether transportation of food-grains is taxable as Goods Transport Agency service.

Analysis: The receipts related to transportation of food-grains. The activity was held not liable to service tax.

Conclusion: Transportation of food-grains was not taxable as Goods Transport Agency service and was in favour of the assessee.

Final Conclusion: The entire service-tax demand, with consequential interest, penalties and late fee, was unsustainable, and the tax already paid became refundable.

Ratio Decidendi: Road transportation without issuance of a consignment note does not constitute Goods Transport Agency service and falls within the negative-list exclusion from service tax.

Issues: Whether the withholding of used multifunction print and copying machines on the basis of the model-wise import restriction was sustainable despite the absence of a centralised all-India monitoring mechanism and the furnishing of security for the entire consignment.

Analysis: The relevant policy framework treated the 100-unit criterion as applicable collectively to a particular model imported through all ports and by all importers. No centralised mechanism had been evolved to monitor that criterion, resulting in inconsistent port-wise practices. A prior decision on identical facts, directing provisional release against a provisional duty bond and bank guarantee, had attained finality following dismissal of the departmental challenge and implementation by the Department. Since security covered the whole consignment, there was no valid basis to retain any part of it.

Conclusion: The direction for provisional release of the withheld machines upon the stipulated security was valid.

Issues: (i) Whether a suspended director who is also a personal guarantor and unsuccessful resolution applicant may maintain an appeal against plan approval under Section 61 of the Insolvency and Bankruptcy Code, 2016; (ii) Whether the challenge-process, e-bidding, treatment of secured statutory dues, Section 29A verification, and consideration of the successful plan were vitiated by material irregularity or unequal treatment; (iii) Whether the CIRP valuation of the corporate debtor's land and building warranted interference; (iv) Whether the continuation of the resolution professional during suspension of authorisation for assignment invalidated the CIRP; (v) Whether the approved consortium plan breached the special-purpose-company and shareholding requirements of the request for resolution plan; and (vi) Whether refusal of the suspended director's one-time-settlement proposal warranted interference.

Issue (i): Whether a suspended director who is also a personal guarantor and unsuccessful resolution applicant may maintain an appeal against plan approval under Section 61 of the Insolvency and Bankruptcy Code, 2016.

Analysis: A suspended director who is also a personal guarantor and an unsuccessful resolution applicant is an aggrieved person with standing to challenge approval of a resolution plan under the statutory appellate framework.

Conclusion: In favour of the appellants: their status as suspended directors, personal guarantors, and unsuccessful resolution applicants did not bar the appeals.

Issue (ii): Whether the challenge-process, e-bidding, treatment of secured statutory dues, Section 29A verification, and consideration of the successful plan were vitiated by material irregularity or unequal treatment.

Analysis: The e-bidding terms, accepted by all participating resolution applicants, required incorporation of the bid placed in the price-discovery process and prohibited unilateral deviation from that bid. The request for resolution plan allowed the Committee of Creditors to seek clarifications, negotiate terms, and require modifications necessary to ensure feasibility, viability, and statutory compliance. The higher second proposal submitted after closure of e-bidding was unsolicited and could not compel a reopening of the concluded process.

Analysis: Clarifications on equal treatment of the secured operational creditor were sought from all applicants. The successful applicant's subsequent addendum, made in response to a written query and allocating an additional amount to comply with the applicable treatment of secured statutory dues, was a permitted compliance-related modification rather than a discriminatory reopening of financial bidding. Eligibility verification under Section 29A had no bearing on the appellants' failure to enhance their bids during e-bidding. The amended Regulation 39(2), applicable when the plans were considered, required all plans, including non-compliant plans, to be placed before the Committee of Creditors with relevant particulars; the successful plan was compliant when voted upon.

Conclusion: Against the appellants: no material irregularity or unequal treatment was established in rejection of the unilateral revised bid or approval of the successful resolution plan.

Issue (iii): Whether the CIRP valuation of the corporate debtor's land and building warranted interference.

Analysis: Valuation under Regulations 27 and 35 was performed by two registered valuers. The reports accounted for the land's agricultural planning zone, industrial use, surrounding properties, access, prevailing market rates, and relevant adjustments. The objections based on different circle rates, prior valuations, and a private valuation did not establish a glaring illegality in the CIRP valuation. Valuation accepted by the Committee of Creditors after compliance with the prescribed process falls within its commercial domain.

Conclusion: Against the appellants: the valuation process did not justify fresh valuation or interference with plan approval.

Issue (iv): Whether the continuation of the resolution professional during suspension of authorisation for assignment invalidated the CIRP.

Analysis: The suspension order permitted the Committee of Creditors to decide whether the resolution professional should continue. Given the advanced stage of CIRP, the Committee of Creditors consciously retained the same resolution professional. No statutory breach or material irregularity affecting plan approval was shown.

Conclusion: Against the appellants: the resolution professional's continuation did not invalidate the CIRP or the approved plan.

Issue (v): Whether the approved consortium plan breached the special-purpose-company and shareholding requirements of the request for resolution plan.

Analysis: The request for resolution plan used the expression "may" regarding incorporation of a special-purpose company, making such incorporation optional rather than mandatory. The proposed shareholding demonstrated that the consortium collectively retained more than 50% shareholding in the corporate debtor. The consortium remains responsible for implementation of the resolution plan.

Conclusion: Against the appellants: no breach of the special-purpose-company requirement was established; the consortium must retain more than 50% shareholding in the corporate debtor until full implementation of the plan.

Issue (vi): Whether refusal of the suspended director's one-time-settlement proposal warranted interference.

Analysis: The financial creditor had already declined the one-time-settlement proposal. The limited appellate jurisdiction under the Insolvency and Bankruptcy Code, 2016 does not permit a direction requiring acceptance of such a proposal after approval of the resolution plan. Any separate dispute regarding retention of pre-CIRP amounts must be pursued before the competent forum.

Conclusion: Against the appellants: refusal of the one-time-settlement proposal did not warrant interference.

Final Conclusion: The objections disclosed no statutory non-compliance or material irregularity capable of displacing the Committee of Creditors' commercial decision approving the resolution plan, which remains binding and enforceable subject to the consortium's shareholding obligation during implementation.

Ratio Decidendi: A resolution plan approved by the Committee of Creditors is not open to appellate interference absent statutory non-compliance or material irregularity; commercial decisions concerning permitted negotiations, plan viability, and compliant valuation remain within the Committee's domain.