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    <title>2026 (3) TMI 1082 - NATIONAL COMPANY LAW APPELLATE TRIBUNAL, CHENNAI</title>
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    <description>Provident fund dues excluded from the liquidation estate under Section 36(4)(a)(iii) were not recoverable through reallocation where the estate had been exhausted by CIRP costs, liquidation costs and limited employee payments. The Tribunal treated the circumstances as exceptional, reasoning that statutory process costs could not be left unpaid if doing so would frustrate the insolvency process. No recovery order under Regulation 43 was warranted. Dissolution under Section 54 was valid because liquidation had been completed, required compliance records were filed, claims had been addressed under the liquidation schedule, no assets remained and revival was not possible.</description>
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      <title>2026 (3) TMI 1082 - NATIONAL COMPANY LAW APPELLATE TRIBUNAL, CHENNAI</title>
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      <description>Provident fund dues excluded from the liquidation estate under Section 36(4)(a)(iii) were not recoverable through reallocation where the estate had been exhausted by CIRP costs, liquidation costs and limited employee payments. The Tribunal treated the circumstances as exceptional, reasoning that statutory process costs could not be left unpaid if doing so would frustrate the insolvency process. No recovery order under Regulation 43 was warranted. Dissolution under Section 54 was valid because liquidation had been completed, required compliance records were filed, claims had been addressed under the liquidation schedule, no assets remained and revival was not possible.</description>
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