Where assessee-company was undergoing CIRP and the resolution plan had been approved by NCLT on 23-12-2022, no belated claim could subsequently be included therein, as otherwise the resolution applicant would not be in a position to recommence business of the corporate debtor with a clean slate; accordingly, the order passed under section 148A(3) and the notice issued under section 148, both dated 30-6-2025, as well as consequential orders/notices, were quashed and set aside. (AY. 2019-20)