Liquidation sale prevails over belated VAT claims; statutory charge alone does not create secured creditor status under insolvency law.

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....A VAT attachment could not survive a liquidation sale where the Department's claim was filed belatedly, rejected, and never admitted in insolvency. The Court distinguished Rainbow Papers, noting that it concerned the unamended regulation and corporate resolution, whereas the present case arose in liquidation under the amended claim process. It held that the Insolvency and Bankruptcy Code's waterfall mechanism and overriding effect prevent a pre-existing attachment from defeating the auction purchaser's title or being revived through writ proceedings. The Court also held that a statutory charge under the TNVAT Act does not, by itself, make the Department a secured creditor under the Code, and directed a contra entry in the encumbrance records.....