(i) In view of the declaration of law made in Ghanashyam Mishra and Sons Pvt. Ltd v. Edelweiss Asset Reconstruction Company Ltd (2021) 9 SCC 657, all the dues including the statutory dues owed to the Central Government, if not a part of the Resolution Plan, shall stand extinguished and no proceedings could be continued in respect of such dues for the period prior to the date on which the adjudicating authority grants its approval under Section 31 of the IB Code. In this case,the income tax dues of the corporate debtor for the assessment years 2012-13 and 2013-14 were not part of the approved Resolution Plan. Therefore, in view of sub-section (1) of Section 31, as interpreted by this Court in the above decision, the dues of the income-tax department owed by the corporate debtor for the assessment years 2012-13 and 2013-14 stand extinguished.

(ii) Once the Resolution Plan is approved by the NCLT, no belated claim can be included therein that was not made earlier. If such demands are taken into consideration, the appellants will not be in a position to recommence the business of the CD on a clean slate.