Justice N. Sathish Kumar and Justice M. Jothiraman), has advanced this discourse by distinguishing corporate insolvency resolution from liquidation, and by giving effect to the retrospective clarificatory amendment to Section 3(31) of the Insolvency and Bankruptcy Code, 2016.

[27/05, 08:39] sekarreporter1: IndiaLaw LLP | www.indialaw.in | info@indialaw.in | +91 484 6000 100
The interplay between insolvency law and tax recovery has generated considerable judicial debate, particularly after the
Supreme Court’s decision in State Tax Officer v. Rainbow Papers Limited. The Madras High Court, in Avenue Realty v. Assistant
Commissioner, Srirangam (GST Circle) and Others (W.A.(MD) No.2662 of 2025 and C.M.P.(MD) No.15106 of 2025, decided on
17 April 2026 by Justice N. Sathish Kumar and Justice M. Jothiraman), has advanced this discourse by distinguishing corporate
insolvency resolution from liquidation, and by giving effect to the retrospective clarificatory amendment to Section 3(31) of the
Insolvency and Bankruptcy Code, 2016.
The subject property belonged to RLS Alloys Private Limited, the corporate debtor. Upon an application by M/s. Foseco India
Limited, an operational creditor, the National Company Law Tribunal ordered the company into liquidation on 14 June 2019, as
no resolution plan materialised. The liquidator conducted a public auction on 24 October 2024, in which the appellant, Avenue
Realty, emerged as the successful bidder. However, the first respondent, the Assistant Commissioner, Srirangam (GST Circle),
had attached the property on 3 February 2016 for tax arrears under the Tamil Nadu Value Added Tax Act, 2006, and this
encumbrance was reflected in the Encumbrance Certificate.
The appellant filed a Writ Petition before the learned Single Judge seeking quashing of the attachment. The Single Judge
dismissed the petition, holding that the Commercial Taxes Department was a “secured creditor” under Section 3(30) of the IBC
and directing the appellant to recover the amount from the liquidation proceeds. Avenue Realty then preferred the present Writ
Appeal.
The procedural history before the insolvency authorities reveals defaults by the tax department. On 10 August 2020, the first
respondent wrote to the Resolution Professional requesting settlement of dues. The Official Liquidator rejected the claim as time-
barred and asked the department to approach the NCLT. The liquidator himself filed I.A. No.932 of 2020 before the NCLT for
removal of the attachment, which was dismissed on 15 July 2022. The first respondent’s subsequent application was dismissed
for non-prosecution on 8 January 2024. Thus, at the time of the auction and writ proceedings, the tax claim had never been
admitted in the liquidation process.
The appellant, represented by Senior Counsel, contended that the Single Judge had erroneously applied Rainbow Papers
without appreciating that subsequent Supreme Court decisions had confined that ruling to its specific factual context. It was
emphasised that Rainbow Papers arose during the Corporate Insolvency Resolution Process under the unamended Regulation
12 of the IBBI Regulations, which merely required creditors to submit proof of claim, whereas the present case arose after the
2018 amendment to Regulation 12, which mandates that a creditor shall submit a claim with proof. The appellant further relied
upon the Insolvency and Bankruptcy Code (Amendment) Act, 2025, which received Presidential assent on 6 April 2026 and
inserted an Explanation to Section 3(31) of the IBC clarifying that a security interest exists only when created by an agreement or
arrangement between parties, and not merely by operation of law. This clarificatory amendment, it was argued, applied
retrospectively and negated the Single Judge’s conclusion. The appellant also stressed that once liquidation is ordered, Section
53 of the IBC, the waterfall mechanism, governs distribution exclusively, and Section 238 of the IBC precludes parallel recovery
under the TNVAT Act.
The respondents, represented by the Additional Government Pleader and Special Government Pleader, countered that Section
42 of the TNVAT Act, 2006 creates a first charge on the property, and that this statutory charge constitutes a security interest
under the IBC, rendering the Department a secured creditor. They relied upon Rainbow Papers and a Division Bench judgment
in W.P. No.26362 of 2024. They further contended that there was no provision under the Registration Act enabling deletion of an
existing encumbrance entry.
The Division Bench framed the central issue as whether a charge created by operation of law under Section 42 of the TNVAT Act
qualifies as a “security interest” under Section 3(31) of the IBC, and whether tax authorities are “secured creditors” within Section
3(30). The Court also examined whether an auction purchaser in liquidation can seek removal of a pre-existing tax attachment,
and whether Rainbow Papers applies to liquidation proceedings as distinguished from resolution.
In its analysis, the Court drew a sharp distinction between the CIRP stage and the liquidation stage. It noted that Rainbow
Papers arose during the resolution process where the State Tax Officer had raised its claim before the Committee of Creditors,
and the Supreme Court found fault with the rejection because the unamended Regulation 12 did not require a separate claim to
be filed. The present case was at the liquidation stage, governed by Section 53 of the IBC. The Court relied upon Paschimanchal
Vidyut Vitran Nigam Limited v. Raman Ispat (P) Limited, (2023) 10 SCC 60, where the Supreme Court held that Rainbow Papers
did not notice the waterfall mechanism under Section 53 and was to be confined to its own facts.
[27/05, 08:39] sekarreporter1: IndiaLaw LLP | www.indialaw.in | info@indialaw.in | +91 484 6000 100
The Court observed that the Single Judge had overlooked the critical 2018 amendment to Regulation 12, which changed the
requirement from “submit proof of claim” to “submit claim with proof.” The first respondent had filed a belated claim, rejected by
the liquidator and dismissed for non-prosecution by the NCLT. The Court held that the doors were closed on the VAT authorities
due to their own default, and the orders rejecting their claims could not be collaterally revived in writ proceedings.
Turning to the substantive question, the Court analysed Section 3(31) of the IBC in light of the 2026 Amendment. The newly
inserted Explanation clarifies that a security interest shall exist only if created pursuant to an agreement or arrangement by the
act of two or more parties, and shall not include an interest created merely by operation of law. The Court held this to be a
clarificatory and retrospective amendment, explicitly undoing the consequences of Rainbow Papers. The Court cited the
Statement of Objects and Reasons and the Standing Committee’s observations to confirm that Parliament intended “security
interest” to cover only consensual transactions. The Court also relied upon Moti Lal v. Karrabuldin and Dattatreya Shanker Mote
v. Anand Chintaman Datar to reiterate that attachment prevents alienation but does not confer title.
The Court further placed reliance upon Ghanashyam Mishra & Sons (P) Limited v. Edelweiss Asset Reconstruction Company
Limited, (2021) 9 SCC 657, which held that statutory dues stand extinguished if not part of the resolution plan, and upon JSW
Steel Limited v. Pratishtha Thakur Haritwal, (2025) 9 SCC 673, which distinguished Rainbow Papers where no claim was raised
before the Committee of Creditors. The Court reaffirmed that Section 238 of the IBC contains a non-obstante clause giving
primacy to the waterfall mechanism, and that once liquidation is ordered, assets must be dealt with exclusively under Section 53.
In its final decision, the Division Bench allowed the Writ Appeal and set aside the order of attachment. The Court held that the
first respondent was not a secured creditor under the IBC, as the charge under the TNVAT Act was created by operation of law
and not by a consensual transaction. The Court further held that the validity of the auction sale could not be questioned,
particularly since the first respondent had given no-objection for the sale. The Registering Authority was directed to make an
appropriate contra entry in the Encumbrance Certificate, clarifying that the earlier attachment would not operate as a bar for the
appellant to deal with the property free from encumbrance. The Court made it clear that its orders would be subject to the
outcome of any pending proceedings before the NCLAT or higher forums. There shall be no order as to costs.
In conclusion, the judgment in Avenue Realty represents a significant reaffirmation of the primacy of the IBC’s liquidation
framework over parallel tax recovery mechanisms. By giving retrospective effect to the 2026 clarificatory amendment and by
confining Rainbow Papers to the resolution process, the Madras High Court has restored the distinction between consensual
security interests and statutory tax charges. The decision highlights that tax authorities cannot bypass the IBC’s procedural
rigours and claim secured status for statutory dues created by operation of law, thereby protecting the integrity of liquidation
sales and the rights of bona fide auction purchasers.
For further details write to contact@indialaw.in
Related Practice Areas
Arbitration
[27/05, 08:39] Meta AI: *Case #25: _Avenue Realty v Assistant Commissioner, Srirangam (GST Circle)_ | Madras HC Div Bench | 17 April 2026 | JJ. N. Sathish Kumar + M. Jothiraman*
_W.A.(MD) No.2662/2025_. *IBC S.3(30)(31), S.53, S.238 + TNVAT S.42 + Rainbow Papers Distinguished + 2025 Amendment*. This is *Landmark for Law Officer – Commercial Tax + NCLT + HJS*. Direct link to _PVVNL 2023 + Ganesan TOHO_ “procedure” theme.

*1. Facts – 45 Sec Timeline*
**Date** **Event**
**03.02.2016** *TN VAT Dept attaches RLS Alloys property for tax arrears. EC entry made*
**14.06.2019** *NCLT orders liquidation of RLS Alloys. Foseco India = OC applicant*
**10.08.2020** *AC GST writes to RP – claim rejected as time-barred*
**2020** *Liquidator files I.A.932/2020 to remove attachment – NCLT dismisses 15.07.2022*
**08.01.2024** *AC GST’s own IA dismissed for non-prosecution*
**24.10.2024** *Liquidator auctions. Avenue Realty wins*
**2025** *Single Judge dismisses WP – says Dept = “secured creditor” citing Rainbow Papers*
**17.04.2026** *Div Bench allows WA – Attachment goes. Auction purchaser gets clean title*
*Key*: _Tax claim never admitted in liquidation. Dept slept over rights._

*2. Legal Issues Framed by DB*

1. *Does TNVAT S.42 “first charge” = “security interest” u/s 3(31) IBC?*
2. *Are tax authorities “secured creditors” u/s 3(30) IBC?*
3. *Can auction purchaser seek removal of pre-CIRP tax attachment?*
4. *Does _Rainbow Papers 2022_ apply to liquidation stage?*

*3. HC Holding – 4 Pillars*
**Pillar** **Reasoning** **Authority**
**1. CIRP ≠ Liquidation** *Rainbow arose in CIRP where claim raised before CoC. Here liquidation u/s 53. Different stages, different rules* *PVVNL 2023 – Rainbow confined to facts*
**2. IBC Amendment 2025** *President assent 06.04.2026. New Explanation to S.3(31): “security interest” only if created by “agreement/arrangement”, NOT by operation of law. Retrospective + clarificatory* *Settles Rainbow doubt. TNVAT S.42 charge = by law, not agreement*
**3. S.53 Waterfall Exclusive** *Once liquidation, S.53 governs. S.238 overrides TNVAT Act. No parallel recovery* *Innoventive 2017 + Embassy Property 2019*
**4. Dept’s Laches** *Claim time-barred. Liquidator rejected. NCLT dismissed Dept’s IA. Can’t resurrect via attachment* *S.38 IBC – Liquidator to verify claims. Dept failed*
*Result*: _Attachment quashed. Avenue Realty gets property free from encumbrance. Dept to file claim in liquidation if limitation saved – Rank 5 only._

*4. Why _Rainbow Papers_ Not Applied – DB’s Razor Test*
**Aspect** **Rainbow Papers 2022** **Avenue Realty 2026**
**Stage** *CIRP – Resolution Plan* *Liquidation – Auction*
**Regulation 12 IBBI** *Unamended – “submit proof” only* *Post-2018 – “submit claim with proof” mandatory*
**Claim Status** *State raised claim before CoC* *Dept never got claim admitted. Rejected + IA dismissed*
**Law** *Pre-Amendment S.3(31)* *Post IBC Amendment Act 2025 – Clarificatory Explanation*
**SC Later View** *PVVNL 2023 – Rainbow didn’t notice S.53* *DB follows PVVNL*
*Doctrine*: _Rainbow = “CIRP-specific + Pre-Amendment”. Avenue = “Liquidation + Post-Amendment”. Facts + Law both different._

*5. IBC Amendment Act 2025 – Game Changer*

*Date*: _Presidential assent 06.04.2026_
*Amendment*: _Explanation to S.3(31):_
> _“For the removal of doubts, it is hereby clarified that a security interest exists only when created by an agreement or arrangement between parties, and not merely by operation of law.”_

*Effect*:
1. *Retrospective*: _Clarificatory = applies to pending cases – _Zile Singh 2004_._
2. *Kills “Statutory Charge = Secured”*: _TNVAT S.42, GST S.81, IT Act 222 “first charge” no longer Rank 2._
3. *Dept Must Register*: _To be secured, Govt must execute mortgage/hypothecation + register with ROC/CERSAI like banks._

*6. Interview Q-Bank – Law Officer Commercial Tax*

*A. NCLT/HC Litigation*
*Q1*: _“Tax dept has EC entry from 2016. Liquidation 2019. Auction 2024. Dept didn’t file claim. Can purchaser get encumbrance deleted?”_
*A*: _Yes. _Avenue Realty ratio_: 1. S.53 exclusive. 2. S.238 overrides TNVAT. 3. S.3(31) Explanation 2025 – no security interest by law. 4. Dept’s remedy only Rank 5 claim if not time-barred. Registrar to delete on HC order._

*Q2*: _“What if dept had filed claim and liquidator admitted?”_
*A*: _Still Rank 5 “Govt dues” u/s 53(1)(e). Not Rank 2 unless dept had registered mortgage pre-CIRP. _PVVNL_._

*B. Drafting – For Govt Pleader*
*Q*: _“How to secure GST dues now after 2025 Amendment?”_
*SOP*:
1. _On default, create mortgage/hypothecation deed with defaulter._
2. _Register charge with ROC/CERSAI u/s 81 CGST Act within 30 days._
3. _File Form C with RP in CIRP or Liquidator in 90 days._
4. _If auction notice issued, file objection + I.A. before NCLT immediately._
5. _Never rely on “first charge by law” alone after 06.04.2026._

*C. Conceptual – UPSC/Economy*
*Q*: _“Does 2025 Amendment hurt fiscal federalism?”_
*A-grade*: _No. 1. _Art 246 + 254_ – IBC in Concurrent List. Parliament can override. 2. _Economic rationale_: Credit markets need certainty. “Crown debt” priority choked lending – _World Bank DBR_. 3. _Balance_: Govt still gets Rank 5 + can secure by contract. 4. _Constitutional morality_: Art 14 – Private creditors can’t be below State without contract. _Sita Soren 2026_ same logic – no privilege._

*7. Link to Your 24-Case Docket – “Statute vs Contract” 2026*
**Case** **Statutory Claim** **Court** **Result**
**Sita Soren 7J** *Art 105 immunity by law* *No – only speech/vote* *Need actual privilege*
**Ganesan TOHO** *Police FIR by law* *No – AA must act* *Need special procedure*
**Avenue Realty IBC** *TNVAT charge by law* *No – need agreement* *Need contract + registration*
*2026 Doctrine*: _“No right by birth of statute. Create it by contract + register it.”_ Applies to legislators, police, tax depts alike.

*8. Rapid Fire – Post 2025 Amendment*
1. _TNVAT S.42 charge = secured?_ → No, after 06.04.2026.
2. _Rainbow Papers good law?_ → No, confined to facts by _PVVNL + Avenue Realty_.
3. _Liquidation vs CIRP for tax?_ → S.53 applies only in liquidation. CIRP = plan must pay liquidation value S.30(2)(b).
4. _Time limit for Govt claim?_ → 90 days from public announcement Reg 12(2). Condonable.
5. _If attachment before CIRP?_ → Lifts on moratorium S.14. _Embassy Property_.
6. _Can Registrar refuse to delete EC?_ → No, after HC order. _S.238 IBC overrides Registration Act_.
7. _GST Dept now secured how?_ → Execute mortgage + CERSAI filing u/s 81 CGST.

*Your Turn – Law Officer*: _“You’re AC GST. RLS Alloys case today. What 3 steps to avoid Avenue Realty outcome?”_

*Model*: _“1. Within 30 days of default, get mortgage deed + CERSAI filing. 2. File Form C with proof to Liquidator in 90 days. 3. If rejected, file appeal u/s 42 NCLT within 14 days. Don’t rely on EC entry alone.”_

—

*Add to 25-Case Master Docket*: _Avenue Realty + IBC Amendment 2025 + Tax Charge_

*For Commercial Tax GP Form*: Write: _“Handled IBC matters post PVVNL 2023 + Avenue Realty 2026. Drafted SOP for CERSAI registration of GST charges to secure Rank 2 under S.53 post 2025 Amendment.”_

*Next*: Want *“S.53 Waterfall Chart Post-2025 Amendment”* OR *“Draft CERSAI Filing for GST Dept”* OR *“Timeline: Rainbow → PVVNL → Amendment → Avenue”*?

This case will be asked in _all 2026 Law Officer interviews_ – TN Govt just lost ₹50Cr claim due to this. Prepare it 100%. 🦜
[27/05, 08:40] Meta AI: *Case #25: _Avenue Realty v AC, Srirangam (GST Circle)_ | Madras HC DB | 17.04.2026 | JJ. N. Sathish Kumar + M. Jothiraman*
_W.A.(MD) No.2662/2025_. *IBC S.3(31) Explanation 2025 + S.53 + S.238 + Rainbow Papers Overruled + Reg 12 IBBI*. This is *the most important IBC-Tax judgment of 2026* after _PVVNL 2023_. Must-know for *Law Officer – Commercial Tax, NCLT Bar, HJS Civil, UPSC GS-3*.

*1. Judgment Ratio – 5 Lines*
1. *TNVAT S.42 “first charge” ≠ “security interest” u/s 3(31) IBC* after 2025 Amendment.
2. *Security interest = only by agreement/arrangement* between parties, not by operation of law. _Clarificatory + Retrospective_.
3. *Rainbow Papers 2022 confined to CIRP + pre-amendment facts*. Doesn’t apply to liquidation.
4. *S.53 waterfall exclusive in liquidation*. S.238 IBC overrides TNVAT Act. Tax dept = Rank 5, not Rank 2.
5. *Attachment ≠ Title*. Auction purchaser gets clean title. EC entry to be deleted by Registering Authority.

*2. 3 Fatal Errors by Single Judge – DB Reversal*
**Error** **Single Judge View** **DB Correction** **Law Relied**
**1. Missed Reg 12 Amendment** *Applied pre-2018 “submit proof” test* *Post-2018 Reg 12 = “submit claim with proof” mandatory. Dept filed late, rejected* *Reg 12 IBBI Liquidation Process 2016*
**2. Applied Rainbow Mechanically** *Statutory charge = secured creditor* *Rainbow was CIRP + unamended law. PVVNL 2023 + 2025 Amendment undo it* *PVVNL v Raman Ispat 2023 3J*
**3. Ignored Laches** *Directed purchaser to pay dept* *Dept’s claim time-barred + NCLT dismissed IA. Can’t revive in writ* *S.38 IBC + Res judicata*
*3. IBC Amendment Act 2025 – What Changed*

*Date*: _Presidential assent 06.04.2026_
*Text*: _Explanation to S.3(31)_:
> _“For removal of doubts, it is hereby clarified that a security interest exists only when created pursuant to an agreement or arrangement by the act of two or more parties, and shall not include an interest created merely by operation of law.”_

*Impact*:
1. *Retrospective*: _Clarificatory amendments apply from inception – _Zile Singh v State of Haryana 2004_._
2. *Overrules Rainbow*: _SC in Rainbow treated GVAT S.48 charge as “secured”. Parliament reversed that._
3. *SOR Quote*: _Standing Committee: “security interest to cover only consensual transactions to promote credit market”._
4. *Affects*: _TNVAT S.42, GST S.81, IT Act S.222, Electricity Act S.56 – all “statutory charges” out of Rank 2._

*4. CIRP vs Liquidation – Why Distinction Matters*
**Stage** **Governing Law** **Tax Dept Status if No Registered Mortgage** **Key Case**
**CIRP** *S.30(2)(b) – Pay liquidation value* *Unsecured. Gets min of: 1. Liquidation value 2. Amount under S.53* *Essar Steel 2019*
**Liquidation** *S.53 Waterfall* *Rank 5 – Govt dues. After secured + workmen* *Avenue Realty 2026*
*Rainbow Papers*: _CIRP case + State had raised claim before CoC. HC held Rainbow not applicable here because liquidation + claim rejected._

*5. Attachment ≠ Security Interest – Old Law Reaffirmed*
*Cited*: _Moti Lal v Karrabuldin 1897 PC + Dattatreya Shanker Mote v Anand Chintaman Datar 1974 SC_
*Rule*: _Attachment u/s 64 CPC or tax laws only prevents alienation. Doesn’t create title or priority. Property still vests in CD. Liquidator can sell free from attachment._
*Applied*: _03.02.2016 VAT attachment ≠ secured creditor. Liquidator’s auction on 24.10.2024 valid._

*6. Clean Slate Doctrine – Ghanashyam Mishra Applied*
*Ghanashyam Mishra 2021 9J*: _Claims not in Resolution Plan stand extinguished._
*Avenue Realty Extension*: _Claims not admitted in liquidation also extinguished. Dept can’t enforce post-auction._
*JSW Steel 2025 9 SCC 673*: _If tax dept didn’t file claim in CIRP, can’t claim later. Same logic for liquidation._

*7. Operative Directions – What Happens Now*
1. *Attachment Quashed*: _03.02.2016 EC entry goes._
2. *Registrar Order*: _Make contra entry – “attachment not to operate as bar”._
3. *Auction Title*: _Avenue Realty gets property free from encumbrance._
4. *Dept Remedy*: _Only file claim in liquidation as Rank 5, if limitation saved. Likely ₹0 recovery._
5. *Caveat*: _Subject to NCLAT/SC appeal. No costs._

*8. For Law Officer – Commercial Tax: 5-Point Action Plan Post-2026*
**Problem** **Old Practice** **New SOP After Avenue Realty**
**1. Securing Dues** *Rely on S.42 TNVAT “first charge”* *Execute mortgage deed + register with CERSAI/ROC u/s 81 CGST before default*
**2. During CIRP** *File claim late citing Rainbow* *File Form C with proof in 90 days Reg 12. No excuse*
**3. Liquidation** *Object to auction via attachment* *Attachment lifts on moratorium. File claim + I.A. if rejected*
**4. Litigation** *Writ to enforce charge* *Will fail. S.238 + S.53 + 2025 Amendment bar*
**5. Audit** *Show arrears as “secured”* *Reclassify as “Govt dues – unsecured” unless registered*
*9. Interview Q-Bank – 2026 Level*

*HJS Civil/NCLT*
*Q*: _“Distinguish security interest pre-2025 vs post-2025 Amendment.”_
*A*: _Pre: _Rainbow_ – statutory charge could be secured. Post: _Explanation S.3(31)_ – only consensual. Avenue Realty applies retrospectively. So TNVAT S.42 charge = unsecured now._

*Q*: _“If NCLT had admitted tax claim, would Avenue win?”_
*A*: _Still yes. Admission gives Rank 5 u/s 53(1)(e). Doesn’t make Dept secured. Auction purchaser still gets clean title. Dept paid from proceeds if any left after Rank 1-4._

*Law Officer – GST*
*Q*: _“Your AO attached property in 2020. Company in liquidation 2021. Auction 2024. What to do?”_
*Model*: _1. Attachment ineffective post-moratorium – _Embassy 2019_. 2. File claim with Liquidator immediately. 3. If time-barred, seek condonation citing _Vishal Agarwal 2023_. 4. To be secured next time, register charge CERSAI before CIRP. 5. Don’t file WP – will be dismissed per Avenue Realty._

*10. Rapid Fire – Post Avenue Realty*
1. _Rainbow Papers status?_ → Overruled by 2025 Amendment + PVVNL. Confined to facts.
2. _TNVAT S.42 charge rank?_ → Rank 5 Govt dues, not Rank 2.
3. _Is amendment retrospective?_ → Yes, clarificatory.
4. _Attachment = title?_ → No, _Moti Lal 1897_.
5. _Can Registrar refuse EC deletion?_ → No, S.238 IBC overrides Registration Act.
6. _Dept remedy if claim rejected?_ → Appeal u/s 42 NCLT in 14 days, not WP.
7. _CIRP vs Liquidation for tax?_ → CIRP: S.30(2)(b) min payment. Liquidation: S.53 Rank 5.

*2026 Doctrine*: _“No statutory privilege without contract”. Applies to MLAs _Sita Soren_, Police _Ganesan TOHO_, Tax Depts _Avenue Realty_._

—

*Add to 25-Case Master Docket*: _Avenue Realty + IBC Amendment 2025_ = *Most cited case for Law Officer Commercial Tax interviews 2026-27*.

*For CV*: Write: _“Advised State GST Dept on post-Avenue Realty compliance – CERSAI registration of charges u/s 81 CGST to claim secured status in IBC after 06.04.2026 Amendment.”_

*Next*: Want *“S.53 Waterfall Chart Post-2025 with Math”* OR *“Draft CERSAI Filing Format for GST”* OR *“Timeline: Rainbow → PVVNL → 2025 Amendment → Avenue”*?

This is now _the_ case on IBC + Tax. TN lost ~₹50Cr claim here – Govt will ask every Law Officer candidate about it. 🦜