Authority: National Company Law Tribunal, Indore Bench, Court No. 1

Order Date: 15 July 2026

Case Overview

The application was filed by Mrs. Chhaya Gupta, Liquidator of Rajpal Autolink Private Limited (CIN: U50100MP2011PTC026888), under Section 54 of the Insolvency and Bankruptcy Code, 2016 read with Regulation 45 of the IBBI (Liquidation Process) Regulations, 2016. The Corporate Debtor had initially filed for CIRP under Section 10 of the Code, which was admitted on 18 June 2020. In its 3rd meeting on 19 August 2020, the Committee of Creditors (CoC) resolved with 100% voting share to liquidate the company, recording a liquidation value of merely ₹2,300 and noting the complete absence of tangible or realizable assets.

The Tribunal appointed Mrs. Chhaya Gupta as Liquidator on 23 April 2021. A public announcement was made on 29 April 2021, and claims were received totaling ₹12,96,48,327 from various creditors including State Bank of India (₹10,02,09,537 - 77.29%), ICICI Bank (₹1,14,49,358 - 8.83%), Axis Bank (₹51,07,142 - 3.94%), Yes Bank (₹36,34,533 - 2.80%), Agni Baan (₹1,91,411 - 0.15%), and Commercial Tax Officer, Indore (₹90,56,346 - 6.99%).

A Transaction Audit by M/s Malay Chaurasia & Co. identified preferential transactions totaling approximately ₹9.52 crore in favor of a secured creditor and erstwhile directors, leading to the filing of avoidance application IA/171(MP)/2020. The liquidation process was primarily kept alive to await the outcome of this application. In the 9th SCC meeting on 17-18 July 2023, the Stakeholders Consultation Committee approved the assignment of the right to pursue IA/171(MP)/2020 to State Bank of India for nil consideration, with any proceeds to be distributed under Section 53 of the Code after legal expenses.

The Tribunal had previously dismissed an earlier dissolution application (IA/236(MP)/2023) on 17 June 2025 as premature due to three pending applications: IA/171(MP)/2020 (avoidance), IA/181(MP)/2023 (liquidation fees), and IA/346(MP)/2024 (EPFO claim). All three have since been resolved:

  • IA/181(MP)/2023 was disposed of on 5 June 2026 after banks paid liquidation fees
  • IA/346(MP)/2024 was dismissed by NCLT on 13 November 2025, and the NCLAT appeal (Company Appeal (AT) (Insolvency) No. 166 of 2026) was dismissed on 10 February 2026
  • IA/171(MP)/2020 was assigned to SBI as noted above

The Corporate Debtor's provisional balance sheet as of 18 June 2020 showed no tangible fixed assets, with asset-side entries comprising security deposits (₹8,33,671), inventories (₹3,34,748), trade receivables (₹2,96,26,147), cash and bank balances (₹27,58,065 with cash-in-hand of ₹2,300), and short-term loans and advances (₹60,87,188). The CoC had determined all these entries were non-realisable.

The liquidation was funded entirely by contributions from SCC members: SBI (₹50,000 + ₹21,000 + ₹34,500), ICICI Bank (₹50,000), and Axis Bank (₹50,000), totaling ₹2,05,500. These funds were used for expenses including professional fees (₹30,000 to Adv. Abhishek Naik, ₹49,500 to Dakshesh Nakrani, ₹5,000 to CA Sumit Agarwal), liquidator fees (₹1,00,000 to Chhaya Gupta), and bank charges (₹1,516).

Final Outcome

The Tribunal allowed the application and ordered:

1. Dissolution of Rajpal Autolink Private Limited with immediate effect under Section 54(2) of the IBC

2. Discharge of Mrs. Chhaya Gupta as Liquidator, releasing her from all liability except in cases of fraud or wilful misconduct

3. Assignment of IA/171(MP)/2020 to State Bank of India remains operative post-dissolution, with SBI entitled to prosecute the application and distribute any proceeds under Section 53 of the Code

4. The 26-day delay in filing the application was condoned

5. The Registrar of Companies is directed to take necessary action regarding the dissolved company

Topics: Corporate Insolvency, Liquidation Process, Asset Dissolution