NCLT Mumbai dismissed an application by Ms. Usha seeking exclusion of industrial land from SVP Textiles' CIRP assets.
The applicant had paid full consideration in a SARFAESI auction, but a DRT stay prevented issuance of the sale certificate.
The tribunal ruled ownership remained with the corporate debtor as the sale was incomplete without a certificate.
The property forms part of the insolvency estate due to the CIRP moratorium overriding SARFAESI proceedings.