NCLAT dismissed appeals by Gujarat State Tax Officer seeking secured creditor status for Rs 1.65 crore Central Sales Tax dues in Jay Formulations' insolvency.
Tribunal ruled CST Act's Section 9(2) is procedural and doesn't create statutory charge like GVAT Act's Section 48, distinguishing from Rainbow Papers case.
The 2026 IBC amendment clarifying security interest requires contractual arrangement was noted as additional consideration supporting the impugned order.
Resolution Plan approval upheld with CST dues treated as unsecured operational debt while GVAT component was already recognized as secured.