Tax Revision Notice Under Section 263 Quashed as Resolution Plan Extinguished All Prior Tax Liabilities

The HC quashed a tax revision notice issued under section 263 against a dissolved company. The court held that the approved Resolution Plan had explicitly extinguished all tax liabilities of the Corporate Debtor for periods prior to NCLT approval on 12.10.2023. Relying on Essar and Edelweiss Supreme Court precedents, the court determined that once the Resolution Plan extinguished all tax liabilities, there was no legal basis for authorities to issue revision notices for Assessment Year 2015-16. The petition was allowed and the impugned notice dated 13.01.2025 was set aside as the question of its merits had become academic. .....

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