Finality of rehabilitation orders bars reopened tax exemption claims where the State expressly refused consent to the concession clause.

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....The Tribunal held that an unchallenged BIFR order disposing of MA No. 442/2011 attained finality, so the company could not reopen a claim for entry tax exemption after that proceeding ended. It further held that there was no deemed consent by the State to the rehabilitation scheme's tax concession clause because the State had expressly ? no, must be English. The State had expressly refused consent during objections to the draft scheme, so Clause 20 was not binding on it under SICA. The Tribunal also held that no relief could be founded on the invalid Central Government notification of 24 May 2017, and the NCLT correctly rejected the petition for exemption.....