Committee of Creditors of Essar Steel India Ltd. v. Satish Kumar Gupta

8 SCC 531Supreme Court of India2020#10757 most cited

What is Committee of Creditors of Essar Steel India Ltd. v. Satish Kumar Gupta authority for?

A successful resolution applicant under the Insolvency and Bankruptcy Code cannot be faced with undecided claims after the approval of a resolution plan, as this would create uncertainty regarding payable amounts and undermine the 'clean slate' principle.

10

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2021 to 2026.

Also referred to as

Essar Steel India Ltd v Satish Kumar Gupta · Section 31(1) IBC · clean slate principle · successful resolution applicant · undecided claims · NCLT approval · corporate debtor · auction purchaser · Insolvency and Bankruptcy Code

Sections most often in play

Section 14Section 143(3)Section 147Section 148Section 31Section 115BBESection 144Section 144B

Issues it is cited on

section 31(1)section 32astatutory duessection 53going concernsection 31section 30section 270section 32section 270asection 44assistant commissioner

Judgments citing Committee of Creditors of Essar Steel India Ltd. v. Satish Kumar Gupta

ACIT, Circle-7(1), Delhi vs. Delhi Control Devices Private Limited, Delhi

In the result, the revenue’s appeal is dismissed

ITA 5909/DEL/2025[2018-19]Status: HeardITAT Delhi05 Mar 2026AY 2018-19

Bench: Shri Mahavir Singh & Shri S. Rifaur Rahmanasstt. Year : 2018-19

For Appellant: NoneFor Respondent: Shri Manish Gupta, Sr. DR
Section 14Section 147Section 53

…IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH “G’’ : NEW DELHI) BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENT AND SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER Asstt. Year : 2018-19 ACIT, CIRCLE 7(1), vs. DELHI CONTROL DEVICES New Delhi PRIVATE LIMITED, ROOM NO. 406, 4TH FLOOR, K-185/2, BASEMENT SURYA C.R. BUILDING, PLAZA, I.P. ESTATE, NEW DELHI NEW FRIENDS COLONY, NEW DELHI – 110 065 (PAN: AAACD2208G) (Appellant) (Respondent) ASSESSEE by : None REVENUE by : Shri Manish Gupta, Sr. DR Date of Hearing 02.03.2026 Date of Pronouncement 02.03.2026 ORDER PER MAHAVIR SINGH, VP: This appeal has been filed by the Revenue…

Ritesh Singh ACIT Circle 3 3 1, Mumbai vs. Trend Electronics Limited, Mumbai

In the result, all the three appeals are allowed for

ITA 5461/MUM/2024[2018-19]Status: DisposedITAT Mumbai24 Dec 2025AY 2018-19

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Shri Parth Parikh, AdvFor Respondent: Shri Leyaqat Ali, Sr. DR
Section 143(3)Section 270ASection 7

…force, such as authorities to whom statutory dues are owed. This provision essentially embodies the clean slate principle. 9. Elucidating the objective of Section 31(1) of IBC, it was held in the case of Essar Steel India Limited Vs Satish Kumar Gupta (2020) 8 SCC 531, that it meant to ensure that the successful resolution applicant (or, as the case may be, the Auction Purchaser) starts running the business of the corporate debtor on a fresh slate. It was also specifically held that the resolution applicant (or, as the case may be, the Auction Purchaser) cannot suddenly be faced with 'undecided' claims after the…

Ritesh Singh ACIT Circle 3 3 1, Mumbai vs. Trend Electronics Limited, Mumbai

In the result, all the three appeals are allowed for statistical purpose

ITA 5460/MUM/2024[2018-19]Status: DisposedITAT Mumbai24 Dec 2025AY 2018-19

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

Section 143(3)Section 270ASection 7

…force, such as authorities to whom statutory dues are owed. This provision essentially embodies the clean slate principle. 9. Elucidating the objective of Section 31(1) of IBC, it was held in the case of Essar Steel India Limited Vs Satish Kumar Gupta (2020) 8 SCC 531, that it meant to ensure that the successful resolution applicant (or, as the case may be, the Auction Purchaser) starts running the business of the corporate debtor on a fresh slate. It was also specifically held that the resolution applicant (or, as the case may be, the Auction Purchaser) cannot suddenly be faced with 'undecided' claims after the…

Ritesh Singh ACIT Circle 3 3 1 Mumbai, Mumbai vs. Trend Electronics Limited, Mumbai

In the result, all result, all the three appeals are allowed for three appeals are allowed for statistical purpose statistical purpose

ITA 5459/MUM/2024[2017-18]Status: DisposedITAT Mumbai24 Dec 2025AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Shri Leyaqat Ali, Sr. DRFor Respondent: Shri Parth Parikh, Adv
Section 143(3)Section 270ASection 7

…ng the objective of Section 31(1) of IB was held in the case of Essar Steel India Limited of Essar Steel India Limited was held in the case ITA No. 5459 to 5461/MUM/2024 ITA No. 5459 to 5461/MUM/2024 11 Trend Electronics Limited Vs Satish Kumar Gupta (2020) 8 SCC 531, that Vs Satish Kumar Gupta (2020) 8 SCC 531 Vs Satish Kumar Gupta (2020) 8 SCC 531 it meant to ensure that the successful resolution it meant to ensure that the successful resolution it meant to ensure that the successful resolution applicant (or, as the case may be, the Auction applicant (or, as the case may be, the Auction applicant (or, as the…

DCIT., Circle-1(1), Hyderabad vs. Rvr Enterprises (Successful Bidder of M/S Chadalavada Infratech Ltd.), Hyderabad

In the result, appeal of the Revenue is allowed for statistical purposes

ITA 782/HYD/2024[2017-18]Status: DisposedITAT Hyderabad03 Jun 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA Satya DinakarFor Respondent: Shri Narender Kumar Naik
Section 143(3)

…ision of Hon’ble Supreme Court in the case of Ghanshyam Mishra & 7 ITA.No.782/Hyd./2024 Sons Pvt. Ltd., vs., Edelweiss Asset Reconstruction Company Ltd., & Ors. Civil Appeal No.8129 of 2019 and in COC of Essar Steel India Ltd., vs., Satish Gupta & Ors [2020] 8 SCC 531 (SC) that, while approving a ‘Corporate Debtor’ sale as a ‘going concern’ in liquidation proceedings without it’s dissolution in terms of Regulation 32(e) of the Liquidation Process Regulations, 2016, it is essential to see that the 'Corporate Debtor' is not burdened by any past or remaining unpaid outstanding liabilities prior to the sale of the C…

Vaibhav Goel vs. Deputy Commissioner of Income Tax

C.A. No.-000049 - 2022Supreme Court20 Mar 2025

Bench: HON'BLE MR. JUSTICE ABHAY S. OKA

Section 154Section 61Section 62

…mmittee of Creditors of Essar Steel India Ltd. vs. Satish Kumar Gupta & Ors.1. He submitted that the issue was squarely covered by a decision of a Bench of three Hon’ble Judges of this court in the case of Ghanashyam Mishra and Sons Pvt. Ltd. 1 (2020) 8 SCC 531 Civil Appeal No.49 of 2022 Page 4 of 12 through the authorised signatory v. Edelweiss Asset Reconstruction Company Ltd. through the Directors & Ors.2. However, the NCLAT has brushed aside the said binding decision. He, therefore, submitted that the impugned orders of NCLT and NCLAT deserve to be quashed and set…

Assistant Commissioner of Income Tax, Chennai vs. Evocon Pvt Ltd, Chennai

In the result the appeal of the revenue is dismissed

ITA 1634/CHNY/2024[2017-18]Status: DisposedITAT Chennai30 Jan 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपीलसं/.Ita No.: 1634/Chny/2024 िनधा"रण वष" / Assessment Year: 2017-18 The Assistant Commissioner Of M/S. Evocon Pvt Ltd Income Tax, V. S Diraviam, No.23, Anaar Flats, 3Rd Floor, Eb Office Road, Central Circle -2(2), Investigation Building, Mogappair East, Chennai – 600 034. Tamil Nadu – 600 037. [Pan:Aacce-9530-C] (अपीलाथ"/Appellant) (""यथ"/Respondent) : Shri Nilay Baran Som, Cit अपीलाथ" क" ओर से/Appellant By ""यथ" क" ओर से/Respondent By : Shri S. Sathiyanarayanan, Advocate सुनवाई की तारीख/Date Of Hearing : 12.12.2024 घोषणा की तारीख/Date Of Pronouncement : 30.01.2025

For Respondent: Shri S. Sathiyanarayanan
Section 133(6)Section 14Section 144Section 147Section 148Section 69A

…such property is occupied by or in the possession of the corporate debtor. 8.1 Further, the reliance placed by the ld.AR on the decision of the Hon'ble Supreme Court in the matter of Essar Steel India Ltd Committee of Creditors Vs Satish Kumar Gupta [(2020) 8 SCC 531] in support of the order of the ld.CIT(A) is relevant to the present case, wherein their lordships has held as below: "A successful resolution applicant cannot suddenly be faced with "undecided" claims after the resolution plan submitted by him has been accepted as this would amount to a hydra head popping up which would throw into uncertainty amou…

M/S Kohinoor Steel Pvt. Ltd., Kolkata vs. I.T.O., Ward-3(3), Kolkata

In the result, the appeal filed by the assessee in ITA No

ITA 27/KOL/2020[2012-13]Status: DisposedITAT Kolkata19 Feb 2024AY 2012-13

Bench: Dr. Manish Borad & Shri Anikesh Banerjee]

Section 14Section 143(3)Section 15Section 250Section 68Section 9

…guished and no proceedings in respect of such dues for the period prior to the date on which the adjudicating authority grants its approval under Section 31 could be continued.” 9.3. In the matter of Committee of Creditors of Essar Steel India Limited,(2020) 8 SCC 531, Hon’ble Supreme Court has expressed that a successful resolution application cannot be faced with undecided claim after the resolution plan is accepted as this would amount to a hydra head popping up, leading to the uncertainty of amounts payable by a prospective resolution applicant. In this judgment, Hon’ble Supreme Court had held that: “106.…

Sundaresh Bhatt vs. Central Board of Indirect Taxes and Customs

C.A. No.-007667 - 2021Supreme Court26 Aug 2022

Bench: HON'BLE THE CHIEF JUSTICE

Section 13(1)(a)Section 14(4)Section 33(2)Section 33(5)Section 60(5)Section 62(1)

…Kalpraj Dharamshi and Another v. Kotak Investment Advisors Limited and Another. 46 , Ghanashyam Mishra And Sons Private Limited through the Authorized Signatory v. Edelweiss Asset Reconstruction Company Limited through the 43 (2020) 8 SCC 531 44 (2019) 12 SCC 150 45 (2021) 4 SCC 457 46 (2021) 10 SCC 401 Page 56 of 59 Civil Appeal No.7722 of 2021 and Civil Appeal No.7731 of 2021 Director and Others. 47 and Jaypee Kensington Boulevard Apartments Welfare Association and Others (Supra). The aforesaid view will apply with equal force to any commercial or business decision taken by the…

Deputy Commissioner of Income Tax vs. M/S Pepsi Foods Ltd. (Now Pepsico India Holdings Pvt. Ltd.)

C.A. No.-001106-001106 - 2021Supreme Court06 Apr 2021

Bench: HON'BLE MR. JUSTICE ROHINTON FALI NARIMAN

Section 254

…nifestly arbitrary being a provision which is capricious, irrational and disproportionate so far as the assessee is concerned. 18.In fact, in a recent judgment of this Court in Essar Steel India Ltd. Committee of Creditors v. Satish Kumar Gupta (2020) 8 SCC 531, the word “mandatorily” in the 2nd proviso inserted through an amendment made to Section 12(3) of the Insolvency and Bankruptcy Code, 2016 was struck down. This Court held: “124. Given the fact that timely resolution of stressed assets is a key factor in the successful working of the Code, the only real argument against the amendment is tha…