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11th August, 2025 Quarterly Newsletter for April-June, 2025 (13.36 MB)

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1 INSOLVENCY AND BANKRUPTCY NEWS CONTENTS FROM CHAIRPERSON’S DESK............................................................................................................................................................... 2 A. IBBI Updates ................................................................................................................................................................................. 3 A.1 Key Events ........................................................................................................................................................................... 3 A.2 Employee Trainings and Workshops ................................................................................................................................... 3 B. Legal and Regulatory Framework ............................................................................................................................................... 3 B.1 Regulations .......................................................................................................................................................................... 3 B.2 Circulars ............................................................................................................................................................................... 4 B.3 Guidelines ............................................................................................................................................................................

......... 4 B.3 Guidelines ............................................................................................................................................................................ 4 B.4 Invitation of public comments ............................................................................................................................................... 4 C. Corporate Processes .................................................................................................................................................................... 4 C.1 Overview............................................................................................................................................................................... 4 C.2 Ratio of Resolution and Liquidation orders .......................................................................................................................... 6 C.3 Stakeholder-wise initiation of CIRP ...................................................................................................................................... 6 C.4 Timelines .............................................................................................................................................................................. 6 C.4.1 For Concluded Processes .......................................................................................................................................

............................... 6 C.4.1 For Concluded Processes ....................................................................................................................................... 6 C.4.2 For Ongoing CIRPs ................................................................................................................................................. 7 C.5 Resolution Plans .................................................................................................................................................................. 7 C.5.1 Overall outcomes ..................................................................................................................................................... 7 C.5.2 Resolution of Large Cases (Admitted Claims > Rs. 1000 crore) ............................................................................ 9 C.5.3 Resolution of FiSPs ................................................................................................................................................. 9 C.6 Withdrawals under Section 12A ......................................................................................................................................... 10 C.7 Liquidation .......................................................................................................................................................................... 10 C.7.1 Overall outcomes ...................................................................................................................................................

......................... 10 C.7.1 Overall outcomes ................................................................................................................................................... 10 C.7.2 Reasons for liquidation .......................................................................................................................................... 12 C.7.3 Claims in liquidation process ................................................................................................................................. 12 C.7.4 Sale as Going Concern ......................................................................................................................................... 12 C.8 Voluntary Liquidation .......................................................................................................................................................... 12 C.8.1 Overview ................................................................................................................................................................ 12 C.8.2 Dissolution orders in voluntary liquidation ............................................................................................................. 13 C.9 Corporate Liquidation Accounts ......................................................................................................................................... 15 C.10 Pre-Packaged Insolvency Resolution Process .................................................................................................................. 15 C.

........................... 15 C.10 Pre-Packaged Insolvency Resolution Process .................................................................................................................. 15 C. 11 Avoidance Transactions ..................................................................................................................................................... 15 D. Individual Processes .................................................................................................................................................................. 16 D.1 Insolvency Resolution Process .......................................................................................................................................... 16 D.2 Bankruptcy Process ........................................................................................................................................................... 16 E. Service Providers ........................................................................................................................................................................ 16 E.1 Insolvency Professionals.................................................................................................................................................... 16 E.2 Replacement of IRP with RP ..............................................................................................................................................

...................... 16 E.2 Replacement of IRP with RP .............................................................................................................................................. 17 E.3 Insolvency Professional Entities......................................................................................................................................... 18 E.4 Insolvency Professional Agencies ...................................................................................................................................... 18 E.5 Information Utility................................................................................................................................................................ 19 E.6 Registered Valuer Organisations ....................................................................................................................................... 19 E.7 Complaints and Grievances ............................................................................................................................................... 20 E.8 Examinations ...................................................................................................................................................................... 20 E.8.1 Limited Insolvency Examination ............................................................................................................................

.................................. 20 E.8.1 Limited Insolvency Examination ............................................................................................................................ 20 E.8.2 Valuation Examinations ......................................................................................................................................... 21 E.9 Disciplinary Orders ............................................................................................................................................................. 21 F. Orders ............................................................................................................................................................................... 21 F.1 Supreme Court ................................................................................................................................................................... 21 F.2 National Company Law Appellate Tribunal ........................................................................................................................ 23 F.3 National Company Law Tribunal ........................................................................................................................................ 25 G. Building Ecosystem ....................................................................................................................................................................

......... 25 G. Building Ecosystem .................................................................................................................................................................... 25 G.1 IP Workshops ..................................................................................................................................................................... 25 G.2 Advocacy and Awareness .................................................................................................................................................. 26 G.3 Other Programmes ............................................................................................................................................................. 26 List of Abbreviations ............................................................................................................................................................................. 27

2 From Chairperson’s Desk The Information Memorandum (IM) is a key document prepared by the Resolution Professional (RP) that contains complete and detailed information about the financial, legal, and operational position of the corporate debtor (CD).

(IM) is a key document prepared by the Resolution Professional (RP) that contains complete and detailed information about the financial, legal, and operational position of the corporate debtor (CD). The main purpose of the IM is to provide prospective resolution applicants (PRAs) with the information they need to assess the viability of the CD and submit well-informed and competitive resolution plans. Just as an IPO prospectus reveals a company’s fundamentals for public investment, the IM presents a transparent and data-backed profile of a distressed corporate debtor - outlining assets, operations, legal risks, financial performance, and the path to revival. For PRAs, the IM is not just a document - it’s a deal originator, a risk-mapper, and a value guide, rolled into one. Whether a strategic buyer seeking operational synergies or a financial investor exploring turnaround potential, the IM equips prospective bidders with the insights needed to assess viability, structure competitive bids, and chart a roadmap for business revival. By bridging information asymmetry, it serves as the foundation for market-driven resolution — where transparency fosters trust, and informed bidding unlocks value from distress. A well-drafted IM also enables the Committee of Creditors (CoC) members to understand the CD’s financial and business position clearly, helping them make timely and informed decisions.

from distress. A well-drafted IM also enables the Committee of Creditors (CoC) members to understand the CD’s financial and business position clearly, helping them make timely and informed decisions. Its completeness and accuracy can have a major impact on the outcome of the resolution process. Benefits of the Information Memorandum (IM) Informed Decision-Making : The IM provides prospective resolution applicants (PRAs) and the CoC with comprehensive financial, legal, and operational data. This allows them to evaluate the viability of the corporate debtor (CD) and make informed decisions regarding resolution plans. Transparency and Fairness : By disclosing all material information, including related party transactions, litigations, and tax attributes, the IM promotes transparency and ensures a level playing field among all resolution applicants. Efficient Price Discovery : Detailed disclosures such as business performance,intangible assets and tax losses, of the corporate debtor enable better assessment of the CD’s worth. This improves the accuracy of price discovery and the competitiveness of bids. Maximization of Value : By enabling resolution applicants to factor in synergies, potential tax benefits, and going concern value, the IM supports the submission of plans that aim to maximize value for stakeholders. Risk Identification and Mitigation : Inclusion of information on pending litigation, and contingent liabilities help the applicants and creditors to identify legal or financial risks associated with the CD and address them in their plans.

usion of information on pending litigation, and contingent liabilities help the applicants and creditors to identify legal or financial risks associated with the CD and address them in their plans. Facilitates Faster Resolution : A well-prepared and accurate IM reduces delays caused by information gaps, minimizes disputes, and helps in timely submission and approval of resolution plans. Improves Quality of Resolution Plan : The more detailed and structured the IM, the higher the confidence among applicants. This leads to better quality, higher-value resolution plans being submitted. The IM must include an overview of the company’s operations, business performance, key contracts, and investment highlights. It should also contain value-enhancing elements such as carried- forward tax losses, unused GST credits, key employees, long-term customer, vendor relationships, utility connections, and other features that make the business viable as a going concern.

as carried- forward tax losses, unused GST credits, key employees, long-term customer, vendor relationships, utility connections, and other features that make the business viable as a going concern. These disclosures make the process more transparent and help in better price discovery, leading to more competitive resolution plans. Recent regulatory changes require the IM to include more detailed disclosures in specific areas: Tax Losses: The IM must show the amount of carried-forward tax losses under the Income Tax Act, 1961, their classification under different heads, and the time limits for utilising them. Avoidance Transactions: Any transactions identified as preferential, undervalued, extortionate, or fraudulent, or cases of wrongful trading, must be disclosed, including details of filings made before the Adjudicating Authority. These transactions must be made known to PRAs before submission of resolution plans. The IM should be discussed in the CoC meetings. Any CoC member may also request more information and the RP must share it with all members in a timely manner. To help the RP prepare an accurate IM, creditors are required to provide important data related to the CD’s assets and liabilities. This includes relevant extracts of valuation reports, stock and receivables statements, audit reports, property inspection records, title search reports, financial statements, bank account details etc. Creditors must also share extracts from any audits they have carried out, such as stock audits, transaction audits, or forensic audits.

search reports, financial statements, bank account details etc. Creditors must also share extracts from any audits they have carried out, such as stock audits, transaction audits, or forensic audits. These inputs help in preparing application for avoidance transactions, ensure correct asset valuation thereby, leading to a complete and reliable IM. The Hon’ble Supreme Court in Ebix Singapore Pvt. Ltd. v. CoC of Educomp Solutions Ltd. & Anr. emphasized that the RP has a duty to ensure that the IM contains accurate and complete information. The Court noted that the RP must clarify if any information is incomplete or subject to change. This makes it important to include all relevant litigation, including arbitration cases, in the IM. The IM should also disclose related party transactions as shown in the financial statements. This helps the CoC and PRAs identify parties who may be disqualified from submitting a resolution plan under Section 29A of the IBC and check whether the exemptions under Section 32A apply. Including this information improves transparency and helps maintain the integrity of the resolution process. To conclude, it is critical that PRAs have access to complete, reliable, and timely information about the corporate debtor. Disclosures about financial condition, tax benefits, business operations, and strategic assets help shape the valuation and bidding strategy. A high quality IM builds trust among resolution applicants, encourages more participation, and leads to stronger and more competitive resolution plans.

help shape the valuation and bidding strategy. A high quality IM builds trust among resolution applicants, encourages more participation, and leads to stronger and more competitive resolution plans. By reducing information gaps and encouraging informed participation, the IM helps ensure that the resolution process is transparent, efficient, and focused on maximizing value, as intended under the IBC. Ravi Mital The Information Memorandum

3 A. IBBI Updates A.1 Key Events IP Conclave The Insolvency and Bankruptcy Board of India (IBBI) organised 11th Conclave of Insolvency Professionals (IPs) on May 9, 2025, at the India International Centre, New Delhi. The Conclave provided a platform for dialogue and collaboration among stakeholders to discuss recent developments regarding reviewing of various statutory forms to reduce the compliance requirements of IPs. An interactive session was held, wherein suggestions were noted for strengthening and improving the efficiency of the IBC ecosystem. IP Conclave, New Delhi, May 9, 2025 IP Conclave, New Delhi, May 9, 2025 International Yoga Day The IBBI observed the International Yoga Day on June 21, 2025. An online yoga session was conducted to promote peace and reconciliation in mind, body, and spirit for the health and wellness of the employees of the Board by Mr. Ajay Kumar Jain, Insolvency Professional, Yoga Wellness Instructor.

cted to promote peace and reconciliation in mind, body, and spirit for the health and wellness of the employees of the Board by Mr. Ajay Kumar Jain, Insolvency Professional, Yoga Wellness Instructor. The Yoga Session included practicing Yogasans, Pranayam and Meditation. A.2 Employee Trainings and Workshops The members and officers of IBBI attended the following workshops and training programmes. Date Organised Nature of the No. of by programme/ Subject officers 23-24 April, International Indonesia International 6 2025 Valuation Valuation Conference (IIVC) Standards 2025 Council (IVSC) B. Legal and Regulatory Framework B.1 Regulations Amendment to IP Regulations The IBBI notified the Insolvency and Bankruptcy Board of India (Insolvency Professional) (Amendment) Regulations, 2025 on April 03, 2025. The amendment relaxed the timeline for submission of application for enrolment with the insolvency professional agency (IPA) from the existing twelve months to twenty-four months to provide greater flexibility and facilitate better career planning for aspiring IPs for applying for enrolment-cum-registration to the IPAs. These aspiring IPs particularly include: (a) Post-Graduate Insolvency Programme (PGIP) students, who previously had to wait until their final year to take the exam, as passing early would result in the validity of 12 months expiring before course completion, which is of two years. (b) Working professionals such as Chartered Accountants (CAs), Company Secretaries (CSs), Cost and Management Accountants

lidity of 12 months expiring before course completion, which is of two years. (b) Working professionals such as Chartered Accountants (CAs), Company Secretaries (CSs), Cost and Management Accountants (CMAs), lawyers, and finance professionals, who need time to gain relevant experience and plan their career trajectory effectively and align the enrolment-cum-registration with their professional commitments. Amendment to CIRP Regulations The Insolvency and Bankruptcy Board of India (IBBI) notified the Insolvency Resolution Process for Corporate Persons (Second Amendment) Regulations, 2025, on April 3, 2025. The amendment provides for revised Form-H, the compliance certificate submitted by the Resolution Professional (RP) along with the application for approval of resolution plan to the Adjudicating Authority (NCLT), certifying compliance with the IBC and related regulations. The revised Form-H now, inter alia, captures detailed information on the Successful Resolution Applicant’s (SRA’s) business, financial capacity, implementation details,key financial metrics, carry-forward of losses under the Income Tax Act, and regulatory fees payable to the Board. Further, the Insolvency and Bankruptcy Board of India (IBBI) has notified the Insolvency and Bankruptcy Board of India (Insolvency Resolution Process for Corporate Persons) (Third Amendment) Regulations, 2025 on May 19, 2025, which came into effect from June 1, 2025. This amendment replaces Regulation 40B of the CIRP Regulations, 2016 and introduces a revised framework for

rd Amendment) Regulations, 2025 on May 19, 2025, which came into effect from June 1, 2025. This amendment replaces Regulation 40B of the CIRP Regulations, 2016 and introduces a revised framework for

4 the electronic filing of forms by the IRPs/RPs.The revised framework replaces the existing nine forms (IP-1 and CIRP Forms 1 to 8) with five consolidated forms (CP-1 to CP-5) aligned with key stages of the CIRP, each with specific filing responsibilities and timelines.The new forms introduce a standardised monthly reporting cycle and are designed to enhance monitoring while reducing the burden on insolvency professionals. The Insolvency and Bankruptcy Board of India (IBBI), has further, notified the Insolvency and Bankruptcy Board of India (Insolvency Resolution Process for Corporate Persons) (Fourth Amendment) Regulations, 2025, on May 26, 2025. The amendment regulations provide for the following: (i) The resolution professional, with the approval of the CoC, can invite expression of interest for submission of resolution plans for the corporate debtor as a whole, or for sale of one or more of assets of the corporate debtor, or for both. By enabling concurrent invitations, the resolution process aims to reduce timelines, prevent value erosion in viable segments, and encourage broader investor participation. (ii) Where a resolution plan provides for payment in stages, the financial creditors who did not vote in favour of the resolution plan shall be paid at least pro rata and in priority over financial creditors who voted in favour of the plan, in each stage.

ges, the financial creditors who did not vote in favour of the resolution plan shall be paid at least pro rata and in priority over financial creditors who voted in favour of the plan, in each stage. This approach balances the legitimate rights of dissenting creditors with the practical constraints of phased implementations. (iii) The CoC may direct the resolution professional to invite interim finance providers to CoC meetings as observers (without voting rights), enabling them to better assess the corporate debtor’s operations and make informed funding decisions. (iv) The Resolution professionals are now required to present all resolution plans received, including those that are non- compliant, to the CoC along with relevant details. This provision ensures that the CoC has access to comprehensive information for decision-making, which may lead to more informed choices and ultimately contribute to a more transparent and effective resolution process. Amendment to PG to CD Regulations The Insolvency and Bankruptcy Board of India (IBBI) notified the Insolvency and Bankruptcy Board of India (Insolvency Resolution Process for Personal Guarantors to Corporate Debtors) (Amendment) Regulations, 2025, on May 19, 2025, introducing Regulation 17B to address procedural gaps in cases where a debtor fails to submit a repayment plan under Section 105 of the Insolvency and Bankruptcy Code, 2016.

s, 2025, on May 19, 2025, introducing Regulation 17B to address procedural gaps in cases where a debtor fails to submit a repayment plan under Section 105 of the Insolvency and Bankruptcy Code, 2016. It provides that the resolution professional, with the approval of creditors, shall file an application with the Adjudicating Authority to report the non-submission and seek appropriate directions, thereby enhancing clarity and efficiency in the insolvency resolution process for personal guarantors to corporate debtors. B.2 Circulars Launch of Revised Forms for Corporate Insolvency Resolution Process (CIRP) Pursuant to the Insolvency and Bankruptcy Board of India (Insolvency Resolution Process for Corporate Persons) (Third Amendment) Regulations, 2025 dated May 19, 2025, IBBI issued a circular on May 26, 2025, providing for the revised forms for the Corporate Insolvency Resolution Process (CIRP) effective from June 1, 2025. The revised framework replaces the existing nine forms (IP-1 and CIRP Forms 1 to 8) with five consolidated forms (CP-1 to CP-5) to eliminate redundancies and enable auto- population of data through the IBBI portal. The IP handling the CIRP assignment shall access the platform with a unique username and password provided by the IBBI and submit the Forms.

d enable auto- population of data through the IBBI portal. The IP handling the CIRP assignment shall access the platform with a unique username and password provided by the IBBI and submit the Forms. To facilitate compliance, Frequently Asked Questions (FAQs) have been made available on the IBBI website, and IPs can report any technical issues in filing to the designated support email. B.3 Guidelines Guidelines for Panel of IPs The IBBI issued the ‘Insolvency Professionals to act as Interim Resolution Professionals, Liquidators, Resolution Professionals, and Bankruptcy Trustees (Recommendation) Guidelines, 2025’ on May 27, 2025. These guidelines enable the Board to prepare a common panel of IPs and share the same with the AA for appointment of Interim Resolution Professionals (IRPs), Resolution Professionals (RPs), Liquidators and Bankruptcy Trustees (BTs) from July 1, 2025, to December 31, 2025. B.4 Invitation of public comments Suggestions to simplify, ease and reduce cost of compliance of Regulations notified under the IBC The Insolvency and Bankruptcy Board of India (IBBI), via a press release dated 7th April 2025, invited online suggestions from the public and stakeholders on all regulations issued under the Insolvency and Bankruptcy Code, 2016. This exercise was undertaken in line with Regulation 7 of the IBBI (Mechanism for Issuing Regulations) Regulations, 2018, and in pursuance of the Union Budget 2023–24 announcement, which called upon financial sector regulators to conduct a comprehensive review of existing regulations.

ing Regulations) Regulations, 2018, and in pursuance of the Union Budget 2023–24 announcement, which called upon financial sector regulators to conduct a comprehensive review of existing regulations. The last date for submitting the suggestions was 30th June 2025. C. Corporate Processes The data provided in this section regarding corporate processes is provisional, as it is getting revised on a continuous basis depending on the flow of updated information as received from IPs or the information in respect of process changes. For example, a process may ultimately yield an order for liquidation even after approval of resolution plan or may ultimately yield resolution plan even after an order for liquidation. C.1 Overview The provisions relating to CIRP came into force on December 1, 2016. The details of CIRP cases admitted and closed, as at the end of June, 2025 are given in Table 1 and Figures 1-2. Sectoral distribution of CDs under CIRP is presented in Figures 3-6. The Code has rescued 3763 CDs (1258 through resolution plans, 1314 through appeal or review or settlement and 1191 through withdrawal) till June, 2025. It has referred 2824 CDs for liquidation.The resolved CDs resulted in realisation of more than

lution plans, 1314 through appeal or review or settlement and 1191 through withdrawal) till June, 2025. It has referred 2824 CDs for liquidation.The resolved CDs resulted in realisation of more than

5 32.57% as against the admitted claims and more than 170.84% as against the liquidation value. Resolution plans on average are yielding 94.89% of fair value of the CDs. Till June, 2025, 1439 CDs have been completely liquidated. These 1439 CDs together had outstanding claims of Rs.4.26 lakh crore, but the assets valued at Rs. 0.17 lakh crore. The liquidation of these companies resulted in 90.3% realisation as against the liquidation value. Table 1: Details of CIRP cases as on June 30, 2025 Status of CIRPs No. of CIRPs Admitted 8492 Closure: Withdrawn under section 12A 1191 Closed on appeal or review or settled 1314 Resolution plans approved 1258 Liquidation orders passed 2824 Ongoing CIRP cases 1905 Note: This excludes 1 CD which has moved directly from Board for Industrial and Financial Reconstruction (BIFR) to resolution. Source: Compilation from website of the NCLT and filing by IPs. Figure 1: Corporate Insolvency Resolution Process Figure 2: Mode of closure of CIRPs Figure 3: Sectoral distribution of CIRPs: Admission Commencement of Liquidation (43%) Resolved/ Appeal/ Review/ Settled/ Withdrawn (57%) Figure 4: Sectoral distribution of CIRPs: Appeal/ Review/ Settled/ Withdrawn Figure 6: Sectoral distribution of CIRPs: Commencement of liquidation Figure 5: Sectoral distribution of CIRPs: Resolution plans

4: Sectoral distribution of CIRPs: Appeal/ Review/ Settled/ Withdrawn Figure 6: Sectoral distribution of CIRPs: Commencement of liquidation Figure 5: Sectoral distribution of CIRPs: Resolution plans

6 The outcome of CIRPs, initiated stakeholder-wise, as on June 30, 2025 is presented in Table 2. Of the OC initiated CIRPs that were closed, around 52% were closed on appeal, review, or withdrawal. Such closures accounted for more than 68% of all closures by appeal, review, or withdrawal. Table 2: Outcome of CIRPs, initiated Stakeholder-wise, as on June 30, 2025 Outcome Description CIRPs initiated by/for FCs OCs CDs FiSPs Total Status of Closure by Appeal/Review/ 415 887 12 0 1314 CIRPs Settled Closure by Withdrawal u/s 12A 358 825 8 0 1191 Closure by Approval of Resolution 768 399 87 4 1258 Plan Closure by Commencement of 1326 1193 305 0 2824 Liquidation Ongoing 1135 659 110 1 1905 Total 4002 3963 522 5 8492 CIRPs Realisation by Creditors as % of 187.5 128.8 146.8 134.9 170.8 yielding Liquidation Value Resolution Realisation by Creditors as % of 33.0 25.0 18.3 41.4 32.6 Plans their Claims Average Time taken for Closure 729 738 625 677 724 of CIRP CIRPs Liquidation Value as % of Claims 5.5 8.3 7.5

6.1 yielding Average Time taken for order of 522 515 456

512 Liquidations Liquidation C.2 Ratio of Resolution and Liquidation orders A number of initiatives are being taken to improve the outcomes of the Code. These include monitoring of cases pending for admission and ongoing CIRPs.

C.2 Ratio of Resolution and Liquidation orders A number of initiatives are being taken to improve the outcomes of the Code. These include monitoring of cases pending for admission and ongoing CIRPs. Further, the IBBI revised its mechanisms for real-time sharing of information regarding applications for the initiation of CIRP with the IU. These initiatives have had a substantial impact on the IBC process, as evidenced by the increase in NCLT- approved resolutions and the admission of cases initiated by FCs. Figure 7 below highlights the improvement in ratio of number of cases ending with resolution vis-à-vis cases in which liquidation is ordered till the quarter April - June, 2025. C.3 Stakeholder-wise initiation of CIRP The distribution of stakeholder-wise initiation of CIRPs is presented in Table 3. FCs triggered 47.15% of the CIRPs, followed by about 46.69% by OCs and remaining by the CDs. It is observed that about 80% of CIRPs having an underlying default of less than Rs. 1 crore were initiated on applications by OCs while about 80% of CIRPs having an underlying default of more than Rs. 10 crores were initiated on applications by FCs.

derlying default of less than Rs. 1 crore were initiated on applications by OCs while about 80% of CIRPs having an underlying default of more than Rs. 10 crores were initiated on applications by FCs. The share of CIRPs initiated by CDs is declining over time. Table 3: Year-wise and Stakeholder-wise Initiation of CIRPs Period CIRP initiated by Total FC OC CD 2016 - 17 8 7 22 37 2017 - 18 286 310 111 707 2018 - 19 517 569 71 1157 2019 - 20 883 1056 51 1990 2020 - 21 197 317 22 536 2021 - 22 372 474 43 889 2022 - 23 654 538 70 1262 2023 – 24 535 402 66 1003 2024 - 25 450 226 55 731 April - Jun, 2025 100 64 11 175 Total 4002 3963 522 8487 Note: This excludes five cases wherein applications filed by the RBI were admitted u/s 227 of the Code. C.4 Timelines C.4.1 For Concluded Processes The Code endeavours to close the various processes at the earliest. The 1258 CIRPs, which have yielded resolution plans by the end of June, 2025 took on average 602 days (after excluding the time excluded by the AA) for conclusion of process, while incurring an average cost of 1.11% of liquidation value and 0.63% of resolution value.

ne, 2025 took on average 602 days (after excluding the time excluded by the AA) for conclusion of process, while incurring an average cost of 1.11% of liquidation value and 0.63% of resolution value. Similarly, the 2824 CIRPs, which ended up in orders for liquidation, took on average 512 days for conclusion. Further, 1439 liquidation processes, which have closed by submission of final reports took on average 651 days for closure. Similarly, 1746 voluntary liquidation processes, which have closed by submission of final reports, took on average 400 days for closure. The average time taken for completion of various processes is presented in Table 4. Figure 7: Ratio of Resolution and Liquidation Orders

7 Table 4: Average Time for Approval of Resolution Plans/Orders for Liquidation Time (In days) Sl. Average time As on March, 2024 As on March, 2025 April – June, 2025 No. of Time No. of Time No. of Time Processes Including Excluding Processes Including Excluding Processes Including Excluding covered excluded excluded covered excluded excluded covered excluded excluded time time time time time time CIRPs 1 From ICD to approval of 935 674 562 1198 717 599 60 865 694 resolution plans by AA 2 From ICD to order for 2469 491 NA 2759 507 NA 65 714 NA Liquidation by AA Liquidations 3 From LCD to submission of final 1087 604 NA 1407 645 NA 32 914 NA report under Liquidation 4 From LCD to submission of 1409 410 NA 1711 401 NA 35 297 NA final report under Voluntary Liquidation 5 From LCD to order for 700 733 NA 931 778 NA 28 1054 NA

5 NA 32 914 NA report under Liquidation 4 From LCD to submission of 1409 410 NA 1711 401 NA 35 297 NA final report under Voluntary Liquidation 5 From LCD to order for 700 733 NA 931 778 NA 28 1054 NA dissolution under Liquidation 6 From LCD to order for 959 723 NA 1218 736 NA 61 872 NA dissolution under Voluntary Liquidation C.5 Resolution Plans C.5.1 Overall outcomes Till FY 2024-25, 1194 CIRPs had yielded resolution plans. The creditors realised Rs. 3.89 lakh crore under the resolution plans, in these cases. The liquidation value of the assets available with these CDs, when they entered the CIRP, was at Rs. 2.29 lakh crore against the total claims of the creditors worth Rs. 11.87 lakh crore. The realisation to the creditors was 32.76% and 170.09% as against their admitted claims and liquidation value, respectively. During the quarter April - June, 2025, 06 more CIRPs was reported as yielding resolution plan, pertaining to the prior period, as presented in Part A of Table 5. 60 CIRPs yielded resolution plans during the quarter April - June, 2025, the details of which are presented in Part B of Table 5.

n, pertaining to the prior period, as presented in Part A of Table 5. 60 CIRPs yielded resolution plans during the quarter April - June, 2025, the details of which are presented in Part B of Table 5. 02 CDs which had earlier yielded resolution have since either moved into liquidation or the process has been ordered to be restarted, taking the total resolution plans approved to 1258 till June,2025. C.4.2 For Ongoing CIRPs The status of ongoing CIRPs in terms of time taken, as of June, 2025, is presented in Figure 8. Figure 8: Timeline: Ongoing CIRPs Table 5: CIRPs Yielding Resolution Plans Sl. Name of Corporate Debtor Defunct Date of Date of CIRP Amount (in Rs.crore) Realisable Value as % of (Yes / Commen- Approval initiated Total Liquid- Fair Total Admit- Liquid - Fair No) cement of Resolu- by Admitted ation Value Realisable ted ation Value of CIRP tion Plan Claims Value Amount by Claims Value' Claimants Part A: Reported for Prior Period (Till March, 2025) 1 Athena Demwe Power Limited No 28-09-2017 18-03-2025 FC 568.06 5.85 427.86 568.06 100.00 9718.54 132.77 2 Delhi Control Devices Private Limited No 15-02-2019 28-09-2022 OC 222.19 25.37 34.05 20.71 9.32 81.63 60.81 3 Avail Holding Limited Yes 29-01-2024 18-03-2025 OC 3.43 0.26 0.53 1.50 43.77 567.29 283.70 4 Samvid Steels Private Limited Yes 17-04-2024 27-01-2025 FC 15.29 5.39 6.74 6.69 43.79 124.09 99.27

0.81 3 Avail Holding Limited Yes 29-01-2024 18-03-2025 OC 3.43 0.26 0.53 1.50 43.77 567.29 283.70 4 Samvid Steels Private Limited Yes 17-04-2024 27-01-2025 FC 15.29 5.39 6.74 6.69 43.79 124.09 99.27

8 5 Konkan Minerals Private Limited NA 16-08-2017 31-07-2024 CD 0.00

0.00 6 Sainath Estates Private Limited NA 08-07-2019 24-02-2025 FC 0.00

0.00 Part B: For April - June, 2025 1 Vadraj Cement Limited Yes 02-02-2024 01-04-2025 FC 9633.95 1080.00 1668.00 1756.52 18.23 162.64 105.31 2 Smartering Infratech Private Limited Yes 29-09-2022 04-04-2025 OC 46.09 3.86 4.64 5.20 11.28 134.60 111.96 3 Jabalpur Msw Private Limited No 14-09-2023 04-04-2025 FC 112.62 54.19 86.51 65.45 58.12 120.79 75.66 4 Osian’s - Connoisseurs of Art Private Limited No 09-12-2021 07-04-2025 FC 559.44 15.83 21.84 30.70 5.49 193.96 140.58 5 AAA Facilities Solution Private Limited No 31-07-2023 07-04-2025 OC 1.36 11.03 13.79 2.36 173.78 21.36 17.08 6 Jassi Properties & Construction Private Limited Yes 01-03-2024 08-04-2025 OC 16.52 0.43 0.57 1.58 9.57 371.75 275.45 7 Madurai Krishna Network Private Limited No 22-07-2022 08-04-2025 OC 10.16 3.39 3.54 5.26 51.78 155.17 148.71 8 Jr Agrotech Private Limited No 27-07-2018 23-04-2025 FC 320.32 20.30 34.89 32.10 10.02 158.12 92.00 9 Gactel Turnkey Projects Limited Yes 27-03-2024 24-04-2025 OC 377.68 0.00 0.00 10.99 2.91

10 Cambridge Energy Resources Private Limited No 26-03-2021 25-04-2025 OC 36.76 12.26 15.44 9.75 26.51 79.46 63.13 11 BTT Industries Private Limited Yes 15-10-2019 28-04-2025 FC 54.12 2.17 2.44 1.43 2.64 66.00 58.62

rgy Resources Private Limited No 26-03-2021 25-04-2025 OC 36.76 12.26 15.44 9.75 26.51 79.46 63.13 11 BTT Industries Private Limited Yes 15-10-2019 28-04-2025 FC 54.12 2.17 2.44 1.43 2.64 66.00 58.62 12 Starwort Engineers Private Limited Yes 16-07-2024 29-04-2025 FC 19.51 0.13 0.13 0.25 1.28 190.19 190.19 13 Shree Rudra Shakti Industries Private Limited Yes 14-05-2019 30-04-2025 OC 2.30 0.00 0.00 2.04 89.02

14 Dhara Techno system LLP Yes 11-08-2023 30-04-2025 OC 36.73 0.00 0.00 0.30 0.82

15 Singhal Strips Limited No 30-10-2023 30-04-2025 OC 133.06 17.42 22.86 22.83 17.16 131.06 99.87 16 Rubique Technologies India Private Limited Yes 07-10-2020 02-05-2025 OC 9.41 0.14 0.96 0.84 8.92 585.17 87.92 17 Jay Formulations Ltd No 26-09-2023 05-05-2025 FC 105.81 17.09 44.85 19.08 18.03 111.67 42.54 18 Sheel Auto Industries Private Limited Yes 25-08-2023 06-05-2025 CD 8.27 2.93 4.18 2.75 33.30 93.92 65.91 19 Bvm Finance Private Limited Yes 08-02-2024 06-05-2025 FC 63.60 0.35 0.43 7.99 12.56 2311.69 1868.41 20 Smaaash Entertainment Private Limited No 06-05-2022 07-05-2025 FC 453.19 65.77 108.32 127.07 28.04 193.20 117.31 21 Unistar Tradelink Private Limited NA 19-05-2023 07-05-2025 CD 0.00

0.00

22 Varadharaja Foods Private Limited Yes 09-11-2022 08-05-2025 OC 19.77 6.86 9.80 4.17 21.09 60.83 42.57 23 Tirupathi Properties and Investment Private Limited Yes 13-08-2024 13-05-2025 FC 26.48 20.92 27.00 25.00 94.40 119.50 92.60 24 Gajanand Corporation Private Limited Yes 22-02-2022 14-05-2025 OC 32.13 0.20 0.24 0.13 0.40 63.97 52.85

ment Private Limited Yes 13-08-2024 13-05-2025 FC 26.48 20.92 27.00 25.00 94.40 119.50 92.60 24 Gajanand Corporation Private Limited Yes 22-02-2022 14-05-2025 OC 32.13 0.20 0.24 0.13 0.40 63.97 52.85 25 Premshree Prime Properties Private Limited NA 17-02-2023 14-05-2025 FC 0.00

0.00 26 Bostin Engineers Pvt Ltd No 01-04-2024 22-05-2025 FC 61.26 5.80 7.53 5.86 9.57 101.04 77.84 27 Topworth Urja & Metals Limited NA 12-08-2022 26-05-2025 FC 0.00

0.00 28 NSL Nagapatnam Power and Infratech Limited No 18-01-2018 27-05-2025 CD 258.44 15.83 74.43 170.76 66.07 1078.73 229.41 29 Slimline Realty Private Limited No 15-05-2024 30-05-2025 FC 138.38 3.87 4.08 5.64 4.08 145.69 138.41 30 Servel India Private Limited NA 08-06-2020 03-06-2025 OC 0.00

0.00 31 Trident Sugars Limited NA 09-07-2024 04-06-2025 FC 0.00

0.00 32 Astral Steritech Private Limited NA 10-06-2024 05-06-2025 OC 0.00

0.00 33 Shree Gopinath Paper Mills Private Limited No 20-06-2024 05-06-2025 FC 56.36 14.97 21.38 16.70 29.63 111.59 78.13 34 Reward Business Solutions Private Limited No 18-02-2021 06-06-2025 FC 107.10 56.80 79.34 61.93 57.82 109.02 78.05 35 India Mega AgroAnaj Limited No 16-11-2022 12-06-2025 FC 375.39 25.59 38.62 24.22 6.45 94.65 62.71 36 Nadhi Bio Products Private Limited Yes 26-05-2023 12-06-2025 FC 145.31 47.37 72.21 89.53 61.61 189.00 123.99 37 Taaza International Limited Yes 01-10-2024 12-06-2025 FC 6.02 0.00 0.00 6.02 100.00

38 B.P.

o Products Private Limited Yes 26-05-2023 12-06-2025 FC 145.31 47.37 72.21 89.53 61.61 189.00 123.99 37 Taaza International Limited Yes 01-10-2024 12-06-2025 FC 6.02 0.00 0.00 6.02 100.00

38 B.P. Bansal Agritech Private Limited No 01-12-2022 12-06-2025 FC 271.76 11.51 13.68 11.50 4.23 99.95 84.04 39 Tarapur Textile Park Limited NA 06-12-2022 12-06-2025 FC 0.00

0.00 40 PCL Foods Private Limited NA 22-12-2023 12-06-2025 FC 0.00

0.00 41 Pabitra Enclave Private Limited No 14-11-2024 13-06-2025 FC 2.79 2.11 2.87 2.38 85.03 112.76 82.85 42 DBG Leasing and Housing Limited NA 16-11-2022 13-06-2025 FC 0.00

0.00 43 T & U Systems Automobiles Private Limited Yes 09-01-2024 17-06-2025 CD 17.33 0.00 0.00 0.11 0.63

44 Best It World (India) Private Limited NA 22-05-2024 17-06-2025 FC 0.00

0.00 45 Indison Agro Foods Limited Yes 03-03-2023 18-06-2025 FC 588.28 13.63 19.09 21.76 3.70 159.64 113.94 46 Vidarbha Industries Power Limited No 30-09-2024 18-06-2025 FC 6753.92 1263.50 1718.89 3585.45 53.09 283.77 208.59 47 Majestic Research Services and Solutions Limited NA 25-05-2023 20-06-2025 FC 0.00

0.00 48 Envirant Developers Private Limited Yes 19-05-2023 25-06-2025 FC 99.27 57.34 73.77 68.95 69.45 120.24 93.46 49 Darshan Developers Private Limited NA 26-07-2021 27-06-2025 OC 0.00

0.00 9 Resolution plans approved 50 Immediate Real Estate Private Limited NA 06-09-2022 27-06-2025 FC 0.00

0.00 51 Manpreet Developers Private Limited NA 11-01-2023 27-06-2025 FC 0.00

0.00 52 Wamika Real Estate Private Limited NA 03-03-2023 27-06-2025 FC 0.00

0.00 53 Prithvi Residency Private Limited NA FC 0.00

0.00 54 Tenacity Real Estate Private Limited NA FC 0.00

0.00 55 Ghardwar Real Estate Private Limited NA FC 0.00

0.00 56 Fulgent Real Estate Private Limited NA FC 0.00

0.00 57 Suvarat Real Estate Developers Private Limited NA FC 0.00

0.00 58 Azinova Constructions Private Limited NA FC 0.00

0.00 59 Vyomakara Real Estate Private Limited NA FC 0.00

0.00 60 Legend Power Private Limited NA 22-07-2024 30-06-2025 FC 0.00

0.00

Total (April - June, 2025) 20960.90 2853.58 4196.32 6204.60 29.60 217.43 147.86 Total (Till June, 2025) 1215445.12 231717.03 350070.93 395874.45 32.57 170.84 94.89* Notes:

CIRPs in 39 matters which yielded resolution plans and were reported earlier in this table have since moved into liquidation. The CIRPs have restarted in 29 cases and CIRPs in 3 matters, where liquidation orders were passed earlier, have yielded resolution plans. 2.. During the quarter, there are 08 CIRPs where the realisable value was less than the liquidation value of the CD.

ters, where liquidation orders were passed earlier, have yielded resolution plans. 2.. During the quarter, there are 08 CIRPs where the realisable value was less than the liquidation value of the CD. While realisable value is significantly influenced by the value of asset of the CD while entering the resolution process and time taken for resolution, it is also the outcome of a market determined price discovery process and commercial wisdom of the CoC.

Based on 1135 cases where fair value has been estimated. NA: Not available owed Rs. 10.46 lakh crore to the creditors. Till June, 2025, realisation by the claimants under resolution plans in comparison to liquidation value is 178.17%, while the realisation by them in comparison to their claims is 33.70%. These realisations are exclusive of realisations that would arise from value of equity holdings post-resolution, resolution of PGs to CDs, and from disposal of applications for avoidance transactions. The details are presented in Table 6. Table 6: Details of resolution of large cases as on June 30, 2025 (Amount in Rs. lakh crore) CIRP cases (Admitted Claims > ` 1,000 crore) Till Mar Apr-June Total as 2025 2025 on June 30, 2025 No. of Cases 172 5 177 Admitted Claims 10.24 0.22 10.46 Liquidation Value 1.95 0.03 1.98 Realisation by creditors 3.47 0.06 3.53 Realisation by creditors as % of 33.89 27.27 33.70 Admitted Claims Realisation by creditors as % of 177.61 193.10 178.17 Liquidation Value C.5.3 Resolution of FiSPs CIRPs of four financial service providers (FiSPs) i.e.

tors as % of 33.89 27.27 33.70 Admitted Claims Realisation by creditors as % of 177.61 193.10 178.17 Liquidation Value C.5.3 Resolution of FiSPs CIRPs of four financial service providers (FiSPs) i.e. Dewan Housing Finance Corporation Ltd., Srei Equipment Finance Limited, Srei Infrastructure Finance Limited and Reliance Capital Limited have yielded resolutions under the Code. The details of the resolutions are presented in Table 7. CIRP in the matter of AVIOM India Housing Finance Private Limited has been admitted vide order of AA dated February 20, 2025. Till June, 2025, the creditors have realised Rs. 3.96 lakh crore under the resolution plans. The fair value and liquidation value of the assets available with these CDs, when they entered the CIRP, was estimated at Rs. 3.50 lakh crore and Rs. 2.32 lakh crore, respectively, as against the total claims of the creditors worth Rs. 12.15 lakh crore. The creditors have realised 170.84% of the liquidation value and 94.89% of the fair value (based on 1135 cases where fair value has been estimated). The haircut for creditors relative to the fair value of assets was less than 6%, while relative to their admitted claims is around 67%.

alue (based on 1135 cases where fair value has been estimated). The haircut for creditors relative to the fair value of assets was less than 6%, while relative to their admitted claims is around 67%. Furthermore, this realisation does not include the CIRP cost, and many probable future realisations such as equity, realisation from corporate and personal guarantees, funds infused into the CD including capital expenditure by the resolution applicants, and recovery from avoidance applications. About 40% of the CIRPs (497 out of 1229 for which data are available), which yielded resolution plans, were earlier with BIFR and/or defunct. In these CDs, the claimants have realised 18.91% of their admitted claims and 152.42% of liquidation value. The remaining 60% of the CIRPs which yielded resolution plans, were not defunct at the time of commencement of CIRP. In these CDs, the claimants have realised 34.98% of their admitted claims and 172.84% of liquidation value. C.5.2 Resolution of Large Cases (Admitted Claims

Rs. 1000 crore) Of the 1258 CDs rescued under the Code as on June 30, 2025, 177 had admitted claims of more than Rs. 1,000 crore. The realisable value of the assets available with these 177 CDs, when they entered the CIRP, was only Rs. 1.98 lakh crore, though they

30, 2025, 177 had admitted claims of more than Rs. 1,000 crore. The realisable value of the assets available with these 177 CDs, when they entered the CIRP, was only Rs. 1.98 lakh crore, though they

10 Table 7: Details of resolution plans approved for FiSPs (Amount in Rs. crore) Sl. Claims of Financial Creditors Dealt Under Resolution Resolution Name of FiSP Amount Amount Realization Realisation Applicant Admitted Realized as % of as % of admitted Liquidation claims value 1 Dewan Housing 87247.68 37167.00 42.60% 138.42% Piramal Capital Finance & Housing Corporation Ltd Finance Limited 2 Srei Equipment 33050.43 13784.76 42.12% 280.74% National Asset Finance Limited Reconstruction Company Ltd. 3 Srei Infrastructure Finance Limited 4 Reliance Capital 26088.97 9661.00 37.03% 73.42% IndusInd Ltd International Holdings Ltd. C.6 Withdrawals under Section 12A Till June, 2025, a total of 1191 CIRPs have been withdrawn under section 12A of the Code. The reasons for withdrawal and distribution of claims in these CIRPs are presented in Figures 9 and 10. Almost three-fourth of these CIRPs had claims of less than Rs. 10 crore. Figure 9: Reasons for Withdrawal of CIRPs C.7 Liquidation C.7.1 Overall outcomes Till FY 2024-25, a total of 2758 CIRPs had yielded orders for liquidation, of which the final reports were submitted in 1374 cases. During the quarter April- June, 2025 04 more CIRP were reported as yielding orders for liquidation, pertaining to the prior period. 03 cases which had earlier ended in liquidation, has now been ordered to be withdrawn/ closed.

une, 2025 04 more CIRP were reported as yielding orders for liquidation, pertaining to the prior period. 03 cases which had earlier ended in liquidation, has now been ordered to be withdrawn/ closed. Further, 65 CIRPs ended in orders for liquidation during the current quarter, taking the total CIRPs ending in liquidation to 2824. Of these, final reports have been submitted in 1439 cases. Till June, 2025 2824 CIRPs have ended in liquidation. Of the 2824 CDs, 1439 CDs have been completely liquidated with submission of final report. The overview of closed liquidation processes and timeline of ongoing 1385 cases is presented in Table 8 and Figure 11 respectively. CD-wise details of liquidation processes closed during this quarter are presented in Table 9. Table 8: Mode of Closure of Liquidation Processes Status of Liquidation Till March, April-June, Total as 2025 2025 on June 30, 2025 Initiated 2759 65 2824 Final Report submitted 1407 32 1439 Closed by Dissolution (A) 814 27 841 Closed by Going Concern Sale (B) 102 1 103 Closed by Compromise / Arrangement (C) 15 0 15 Ongoing processes 1352 33 1385 Total Closed cases (A+B+C) 931 28 959 Total Admitted Claims (In Rs. crore) 261203.13 1451.66 262654.79 Liquidation Value (In Rs. crore) 10535.75 34.9 10570.65 Total Realisation (In Rs.

osed cases (A+B+C) 931 28 959 Total Admitted Claims (In Rs. crore) 261203.13 1451.66 262654.79 Liquidation Value (In Rs. crore) 10535.75 34.9 10570.65 Total Realisation (In Rs. crore) 9572.57 35.51 9608.08 *This excludes 48 cases where liquidation order has been set aside by NCLT / NCLAT / HC / SC. Figure 10: Distribution of CIRPs Withdrawn (as per Admitted Claims) Figure 11: Timeline: Ongoing Liquidations 60 54 396 271 405 Full settlement with the applicant Full settlement with other creditors Agreement to settle in future Other settlements with creditors Others

11 Table 9: Details of closed Liquidations (Amount in Rs. crore) Sl. Name of the Corporate Person Date of Amount of Liquidation Sale Amount Date of Order Order of Admitted Value Proceeds Distributed to of Dissolution/ Liquidation Claims Stakeholders Closure Part A: Reported for Prior Period (Till March, 2025) 1 Anand Distilleries Pvt Ltd 11-08-2023 0.00 0.00 0.00 0.00 03-01-2024 2 Abhiraami Chemicals Limited 19-09-2022 2.96 0.06 0.06 0.02 09-05-2024 3 Sharan Hospitality Private Limited 22-11-2023 0.00 0.00 0.00 0.00 02-07-2024 4 Virtue Infra And Entertainment Private Limited 10-05-2022 0.00 0.00 0.00 0.00 11-07-2024 5 Topknit Processing Mill Private Limited 26-07-2023 25.29 8.79 0.19 0.00 24-07-2024 6 Mata Energy Limited 31-05-2024 0.00 0.00 0.00 0.00 06-08-2024 7 Earth Water Limited 03-01-2023 312.06 8.54 6.03 4.50 05-09-2024 8 Tirupur Plaza Hotel Private Limited 15-02-2023 12.89 11.68 3.00 2.45 18-12-2024 9 Deogiri Infrastructure Private Limited 05-10-2023 84.84 0.45 1.35 0.98

03-01-2023 312.06 8.54 6.03 4.50 05-09-2024 8 Tirupur Plaza Hotel Private Limited 15-02-2023 12.89 11.68 3.00 2.45 18-12-2024 9 Deogiri Infrastructure Private Limited 05-10-2023 84.84 0.45 1.35 0.98 24-01-2025 10 Lakshmi Transcon Pvt. Ltd. 28-03-2024 24.17 4.91 7.44 4.67 14-02-2025 11 Saptarishi Hotels Private Limited 19-10-2022 5.79 0.00 0.67 0.36 07-03-2025 12 Ibridge Solutions Pvt Ltd 01-02-2024 0.00 0.00 0.08 0.00 27-03-2025 Part B: For April - June, 2025 1 Karan Processors Private Limited 26-11-2020 2.33 0.39 0.39 0.35 09-04-2025 2 Praveer Constructions Private Limited 27-09-2019 11.78 2.13 2.67 1.62 22-04-2025 3 Floram Shoes (India) Private Limited 27-01-2021 55.67 7.84 8.96 8.45 22-04-2025 4 Nirmal Cars Private Limited 29-02-2024 0.00 0.05 0.13 0.00 22-04-2025 5 Aam Sky Geospatial Solutions Private Limited 20-10-2023 1.37 0.03 0.01 0.00 23-04-2025 6 Minesh Prints Limited 15-09-2023 0.30 1.06 0.19 0.04 29-04-2025 7 Shree Gajanan Agro Farms Private Limited 17-03-2023 23.22 6.84 5.78 5.53 01-05-2025 8 Komorebi Exports Private Limited 05-02-2020 1.82 0.15 0.10 0.00 02-05-2025 9 Rahi Shipping (India) Private Limited 16-06-2022 17.15 3.05 3.05 2.85 02-05-2025 10 Sintex Oil And Gas Limited 06-12-2022 429.47 0.96 1.11 0.86 05-05-2025 11 Jeph Bev Private Limited 22-12-2023 0.00 0.00 0.23 0.00 05-05-2025 12 SPG Multi Trade Private Limited 04-12-2020 187.52 0.90 0.00 0.00 06-05-2025 13 Sri Parameswara Poultry Farm Private Limited 24-03-2022 0.00 0.00 0.84 0.00 08-05-2025 14 Elexir Distributors Private Limited 01-01-2024 25.69 0.20 0.39 0.02 08-05-2025 15

.90 0.00 0.00 06-05-2025 13 Sri Parameswara Poultry Farm Private Limited 24-03-2022 0.00 0.00 0.84 0.00 08-05-2025 14 Elexir Distributors Private Limited 01-01-2024 25.69 0.20 0.39 0.02 08-05-2025 15 Suashish Capital Pvt Ltd 06-10-2023 0.00 0.00 0.00 0.00 22-05-2025 16 Dentorth India Private Limited 13-03-2024 0.00 0.13 0.14 0.00 27-05-2025 17 Moli Merchant Traders Private Limited 25-11-2022 19.54 0.00 0.00 0.00 29-05-2025 18 Nandanam Tiles And Sanitaries Private Limited 14-08-2024 0.00 0.00 0.00 0.00 03-06-2025 19 Richa Creation India Private Limited 09-04-2019 0.00 0.00 0.00 0.00 04-06-2025 20 Aethon Energy LLP 08-06-2022 0.09 0.59 0.00 0.00 05-06-2025 21 Tyson Retail Services Private Limited 22-12-2022 1.72 0.39 0.00 0.00 06-06-2025 22 BrightsunTechnocraft Private Limited 24-12-2020 0.00 0.01 0.01 0.00 09-06-2025 23 Mono Acriglass Industries Private Limited 01-08-2022 617.50 2.03 2.80 2.70 10-06-2025 24 Sangaman Chit Funds Private Limited 11-01-2022 4.93 2.14 2.18 2.02 12-06-2025 25 PN Steel Traders Private Limited 02-09-2024 0.00 0.00 0.00 0.00 16-06-2025 26 FR Tech Innovations Private Limited 04-03-2024 1.13 0.00 0.00 0.00 17-06-2025 27 Sonali Energees Pvt. Ltd. 03-03-2021 28.87 3.91 4.42 3.88 23-06-2025 28 Globalite Industries Private Limited 18-11-2020 21.54 2.11 2.11 0.00 30-06-2025 Note: ‘-’ means no value; 0 means an amount below two decimals NA means Not Applicable

87 3.91 4.42 3.88 23-06-2025 28 Globalite Industries Private Limited 18-11-2020 21.54 2.11 2.11 0.00 30-06-2025 Note: ‘-’ means no value; 0 means an amount below two decimals NA means Not Applicable

12 Around 78% of the CIRPs ending in liquidation (2144 out of 2747 for which data are available) were earlier with BIFR and/or defunct. The economic value in most of these CDs had almost completely eroded even before they were admitted into CIRP. These CDs had assets, on average, valued at 6.13% of the outstanding debt amount. C.7.2 Reasons for liquidation The AA passes an order for liquidation under four circumstances. As on June, 2025, 2824 orders for commencement of liquidation have been passed. The details of liquidation in these circumstances are presented in Figure 12. Figure 12: Reasons for Liquidations C.7.3 Claims in liquidation process Regulation 12 of the Liquidation Regulations requires the liquidator to make a public announcement calling upon stakeholders to submit their claims as on the liquidation commencement date (LCD), within 30 days from the LCD. The details of the claims admitted by the liquidators in 2824 liquidations, for which data are available, are presented in Table 10. Table10: Claims in Liquidation Process (Amount in Rs.

the LCD. The details of the claims admitted by the liquidators in 2824 liquidations, for which data are available, are presented in Table 10. Table10: Claims in Liquidation Process (Amount in Rs. crore) Stakeholders Number of Amount of Liquidation Amount Amount under Section Claimants Claims Value Realised Distributed Admitted 1439 Liquidations where Final Report Submitted 52 91 10708.98 668.91 661.93 650.60 53 (1) (a) NA NA

2682.68 53 (1) (b) 11931 291785.53 11392.28 53 (1) (c) 10029 333.60 16.36 53 (1) (d) 2340 79530.75 16268.10 14631.11 293.09 53 (1) (e) 1733 22030.19 51.26 53 (1) (f) 25476 19756.01 172.14 53 (1) (g) 8 17.55 0 53 (1) (h) 279 2175.66 21.66 Total (A) 51887 426338.27 16937.01 15293.04# 15280.07 Ongoing 1385 Liquidations 53 (1) (a) NA NA 53 (1) (b) 39025 640857.52 53 (1) (c) 30452 1343.38 53 (1) (d) 11577 124893.62 53 (1) (e) 2601 32181.09 52670.72*** 53 (1) (f) 1966668 86127.94 53 (1) (g) 50 563.83 53 (1) (h) 105545 2647.62 Total (B) 2155918 888615.00 Grand Total 2207805 1314953.27 69607.73 (A+B)

Inclusive of unclaimed proceeds of Rs.12.97 crore under liquidation.

***Out of 1385 ongoing cases, liquidation value of only 1145 CDs is available. Liquidation value of 740 CDs taken during liquidation process is Rs.39,083.48 crore and liquidation value of rest of the 405 CDs captured during CIRP is Rs.13,587 crore. C.7.4 Sale as Going Concern Till June 2025, 103 CDs were closed by sale as a going concern under liquidation process. These 103 CDs had claims amounting to Rs. 160545.81 crore, as against the liquidation value of Rs. 5673.68 crore. The liquidators in these cases realized Rs. 4678.92 crore and companies were rescued. C.8 Voluntary Liquidation C.8.1 Overview A corporate person may initiate voluntary liquidation proceeding if majority of the directors or designated partners of the corporate person make a declaration to the effect that (i) the corporate person has no debt or it will be able to pay its debts in full, from the proceeds of the assets to be sold under the proposed liquidation, and (ii) the corporate person is not being liquidated to defraud any person. Till March, 2025, 2211 corporate persons initiated voluntary liquidation of which final reports were submitted in 1680 cases and 44 cases were withdrawn. At the end of June, 2025, 2341 corporate persons initiated voluntary liquidation, of which final reports have been submitted in 1746 cases. Further, 44 processes have been withdrawn by June 30, 2025. The details of commencement of voluntary liquidations are presented in Table 11.

of which final reports have been submitted in 1746 cases. Further, 44 processes have been withdrawn by June 30, 2025. The details of commencement of voluntary liquidations are presented in Table 11. The timeline of ongoing voluntary liquidations is presented in Figure 13. Not Applicable Not Applicable

13 Table 11: Commencement of Voluntary Liquidations till June 30, 2025 (Number) Period Liquidations Liquidations Liquidation closed by Liquidations at the Commenced Withdrawal Final at the end beginning Reports of period Submitted 2017 – 18 0 184 0 11 173 2018 – 19 173 232 7 108 290 2019 – 20 290 273 1 170 392 2020 – 21 392 250 2 186 454 2021 – 22 454 303 3 259 495 2022 – 23 495 320 9 335 471 2023 – 24 471 336 12 340 455 2024 - 25 455 383 10 302 526 Apr – Jun, 2025 526 60 0 35 551 Total NA 2341 44 1746 551 Of the 2297 corporate persons that initiated voluntary liquidations (excluding withdrawals) till June 30, 2025, the reasons for these initiations are available for 2275 cases, which are presented in Figure 14. Most of these corporate persons are small entities. 1441 of them have paid-up equity capital of less than or equal to Rs. 1 crore. Only 332 of them have paid-up capital exceeding Rs. 5 crore. The corporate persons, for which details are available, have an aggregate paid-up capital of Rs. 16,735 crore (Table 12). Figure 13: Timeline of ongoing Voluntary Liquidations Figure 14: Reasons for Voluntary Liquidation Table 12: Details of Voluntary Liquidations (Excluding Withdrawals) Details of No. of Amount (in Rs.

imeline of ongoing Voluntary Liquidations Figure 14: Reasons for Voluntary Liquidation Table 12: Details of Voluntary Liquidations (Excluding Withdrawals) Details of No. of Amount (in Rs. crore) Liquid- Paid-up Assets Out- Amount Surplus ations capital* standing paid to debt creditors Liquidations for which ** 1746 9913 12357 665 665 13179 Final Reports submitted Ongoing Liquidations 551 6822 4452#

Total 2297 16735 16809

Notes:

Paid up capital is not available in case of eleven companies as they are limited by guarantee companies where there exist no shareholders and paid-up capital. ** Data of 20 Final Report cases is awaited. *** For ongoing liquidations, data is not available

Assets of 520 cases are available.

C.8.2 Dissolution orders in voluntary liquidation It was reported in the last newsletter that dissolution orders were passed in respect of 1208 voluntary liquidations. Dissolution orders in respect of 10 more voluntary liquidations, which were issued during the earlier period, were reported later. During the quarter April - June, 2025, dissolutions orders in respect of 61 voluntary liquidations were issued taking the total dissolutions to 1279. These 1279 corporate persons owed Rs. 541.23 crore to creditors and through voluntary liquidation process, they were paid full amount. Table 13: Realisations under Voluntary Liquidations (Amount in Rs. crore) Sl Name of Corporate Person Date of Date of Realisation Amount Amount Liquidation Surplus No. Commencement Dissolution of Assets due to paid to Expenses Creditors Creditors Part A: For Prior Period (Till March, 2025) 1 Topstar Projects Private Limited 09-01-2024 01-06-2024 1.74 0.00 0.00 0.04 1.70 2 Vulcan Estates Pvt.Ltd. 20-02-2023 05-06-2024 17.14 1.69 1.69 0.11 15.34 3 Ars Sales Private Limited 27-12-2023 23-07-2024 0.61 0.01 0.01 0.03 0.58 4 Krishna Residency Private Limited 29-12-2023 29-11-2024 2.53 0.00 0.00 0.09 2.44 5 Adil Infratech Private Limited 21-12-2024 02-01-2025 0.00 0.00 0.00 0.00 0.00 6 Premier Logic India Private Limited 21-12-2021 20-02-2025 0.40 0.10 0.10 0.16 0.14 7 Maverick Digital Tech Private Limited 01-08-2023 25-02-2025 13.71 0.00 0.00 0.07 13.64 8 Fairmoney Financial Services Private Limited 05-10-2023 04-03-2025 2.08 0.00 0.00 0.07 2.01 9

0.10 0.16 0.14 7 Maverick Digital Tech Private Limited 01-08-2023 25-02-2025 13.71 0.00 0.00 0.07 13.64 8 Fairmoney Financial Services Private Limited 05-10-2023 04-03-2025 2.08 0.00 0.00 0.07 2.01 9 Nuvo Chryscapital Advisors Private Limited 23-10-2023 20-03-2025 1.46 0.00 0.00 0.04 1.42 10 Tech Ideas Computer Systems Private Limited 29-04-2024 26-03-2025 1.04 0.10 0.10 0.04 0.90

14 Part B: For Apr - June, 2025 1 Ashuji Distributors Private Limited 22-07-2019 01-04-2025 0.50 0.00 0.00 0.02 0.49 2 Vinked Cloths Private Limited 07-01-2023 02-04-2025 5.84 0.00 0.00 0.13 5.70 3 Ritchie Bros Auctioneers India Private Limited 13-02-2024 04-04-2025 0.15 0.00 0.00 0.15 0.00 4 B & C Textiles Private Limited 17-10-2023 07-04-2025 1.23 0.00 0.00 0.06 1.16 5 Zenfer Marketing Pvt Ltd 30-10-2024 07-04-2025 2.36 0.00 0.00 2.36 0.00 6 Indore Fire Bricks Pvt Ltd 07-12-2024 07-04-2025 0.60 0.00 0.00 0.60 0.00 7 Ras Polybuild Products Private Limited 22-08-2020 09-04-2025 1.10 0.00 0.00 0.06 1.03 8 Dafater Consultants Private Limited 06-06-2022 09-04-2025 0.46 0.00 0.00 0.09 0.38 9 Saltmines Technologies Private Limited 13-06-2022 09-04-2025 0.15 0.00 0.00 0.04 0.11 10 Innovium India Private Limited 17-03-2023 09-04-2025 0.64 0.00 0.00 0.14 0.50 11 Rwe Renewables India Private Limited 14-11-2024 09-04-2025 0.00 0.00 0.00 0.00 0.00 12 Shree Cement Foundation 06-12-2024 17-04-2025 0.00 0.00 0.00 0.00 0.00 13 Shree Cement East Bengal Foundation 06-12-2024 17-04-2025 0.00 0.00 0.00 0.00 0.00 14 Gravitate Ventures Private Limited 22-12-2023 22-04-2025 0.68 0.00 0.00 0.06 0.62 15

0.00 0.00 0.00 0.00 0.00 13 Shree Cement East Bengal Foundation 06-12-2024 17-04-2025 0.00 0.00 0.00 0.00 0.00 14 Gravitate Ventures Private Limited 22-12-2023 22-04-2025 0.68 0.00 0.00 0.06 0.62 15 Erwin India Private Limited 06-03-2024 22-04-2025 0.16 0.00 0.00 0.16 0.00 16 Coinwealth Ventures India Private Limited 07-12-2023 24-04-2025 0.29 0.27 0.27 0.02 0.00 17 Garda Tech Private Limited 22-12-2023 24-04-2025 0.76 0.00 0.00 0.47 0.29 18 Gupta Polymers Pvt.Ltd. 16-09-2023 25-04-2025 5.16 0.01 0.01 0.10 5.05 19 Jovial Trading Company Private Limited 23-02-2024 25-04-2025 0.19 0.00 0.00 0.02 0.18 20 Magic Hospitalities Private Limited 27-02-2023 28-04-2025 40.51 0.00 0.00 0.10 40.41 21 Ca Media India Advisors Private Limited 07-01-2019 30-04-2025 2.50 0.00 0.00 0.26 2.24 22 Mueller Prost Shared Services Private Limited 24-07-2024 30-04-2025 0.00 0.00 0.00 0.00 0.00 23 SSG Advisors LLP 23-11-2024 30-04-2025 0.56 0.00 0.00 0.56 0.00 24 Ricoh Innovations Private Limited 29-06-2020 01-05-2025 10.06 0.00 0.00 1.71 8.35 25 Itapp Software Private Limited 28-11-2022 01-05-2025 7.33 0.13 0.13 3.52 3.68 26 Shri Chamundi Captive Energy Private Limited 26-08-2019 02-05-2025 6.41 1.50 1.50 0.18 4.73 27 Vikram Health Services Private Limited 10-01-2022 02-05-2025 16.09 0.00 0.00 2.22 13.87 28 Linear Technology Semiconductor India Private Limited 14-03-2023 02-05-2025 0.40 0.00 0.00 0.07 0.33 29 R And S Engineering India Pvt Ltd 20-09-2023 02-05-2025 3.78 0.19 0.19 0.07 3.52 30 NRTU Foundation 17-01-2024 06-05-2025 0.04 0.00 0.00 0.04 0.00 31

14-03-2023 02-05-2025 0.40 0.00 0.00 0.07 0.33 29 R And S Engineering India Pvt Ltd 20-09-2023 02-05-2025 3.78 0.19 0.19 0.07 3.52 30 NRTU Foundation 17-01-2024 06-05-2025 0.04 0.00 0.00 0.04 0.00 31 Hitachi Plant Technologies India Private Limited 19-09-2018 07-05-2025 8.04 0.82 0.82 3.95 3.26 32 King’S Worldwide India Centre 20-12-2022 07-05-2025 0.00 0.00 0.00 0.00 0.00 33 April International Marketing Services (India) Private Limited 29-12-2020 08-05-2025 2.27 0.10 0.10 0.12 2.05 34 Ritesh Polysters Limited 11-12-2023 08-05-2025 0.03 0.00 0.00 0.03 0.00 35 Indo Austrian Business Forum 20-08-2024 16-05-2025 0.01 0.00 0.00 0.01 0.00 36 Lampsat Motors Private Limited 28-09-2022 22-05-2025 77.93 0.00 0.00 0.40 77.53 37 Zipdial Mobile Solutions Private Limited 05-11-2020 23-05-2025 4.63 0.00 0.00 0.51 4.12 38 Tele Dna Communications Private Limited 13-10-2022 23-05-2025 23.96 23.88 23.88 0.08 0.00 39 Fomi Foundry & Metallurgy India Private Limited 20-02-2023 23-05-2025 0.11 0.00 0.00 0.11 0.00 40 Chainalytics Services Private Limited 14-03-2023 23-05-2025 13.42 0.00 0.00 0.63 12.79 41 Evernote Technologies India Private Limited 15-02-2024 23-05-2025 0.23 0.00 0.00 0.03 0.21 42 Cfld India Investment Private Limited 28-03-2020 26-05-2025 1.98 1.58 1.58 0.40 0.00 43 Bl Engineering Solutions Private Limited 15-07-2022 26-05-2025 0.36 0.00 0.00 0.05 0.31 44 KWH Motors Private Limited 29-09-2023 27-05-2025 5.21 0.00 0.00 0.18 5.03 45 Variman Fitness Private Limited 27-01-2024 27-05-2025 1.20 0.16 0.16 0.07 0.97 46 Mushin Infrastructure Private Limited 04-10-2017 28-05-2025 2.73

ed 29-09-2023 27-05-2025 5.21 0.00 0.00 0.18 5.03 45 Variman Fitness Private Limited 27-01-2024 27-05-2025 1.20 0.16 0.16 0.07 0.97 46 Mushin Infrastructure Private Limited 04-10-2017 28-05-2025 2.73 0.00 0.00 0.01 2.72 47 Super Tex Labels Private Limite 21-02-2022 28-05-2025 2.54 0.00 0.00 0.10 2.45 48 KKNT First Main Private Limited 30-09-2024 30-05-2025 0.02 0.00 0.00 0.02 0.00 49 Yogi Dyeing Limited 19-01-2022 04-06-2025 1.87 0.00 0.00 0.02 1.85 50 Fircosoft India Private Limited 30-01-2023 05-06-2025 0.97 0.00 0.00 0.33 0.64 51 BF Precision Private Limited 22-03-2024 05-06-2025 1.08 0.00 0.00 0.07 1.01

15 52 Otsuka Foods India Private Limited 09-08-2022 09-06-2025 2.48 0.00 0.00 0.37 2.11 53 Skol Beer Manufacturing Company Limited 25-03-2023 09-06-2025 0.02 0.00 0.00 0.02 0.00 54 Nan Fang Enterprise (India) Private Limited 22-06-2024 09-06-2025 8.46 0.65 0.65 7.81 0.00 55 Greenfield Infotek Limited 11-12-2023 10-06-2025 0.03 0.00 0.00 0.03 0.00 56 Fawow Ventures Private Limited 17-09-2024 13-06-2025 1.42 0.00 0.00 0.04 1.38 57 Manisha Infotech Private Limited 06-02-2025 19-06-2025 2.17 0.00 0.00 0.01 2.15 58 VSK Holdings Private Limited 24-06-2020 26-06-2025 20.24 0.00 0.00 1.90 18.33 59 Statestreet Managed Accounts Services India Private Limited 06-02-2023 26-06-2025 1.50 0.00 0.00 0.34 1.17 60 Hibu India Private Limited 28-09-2021 30-06-2025 1.34 0.03 0.03 0.35 0.96 61 Newonn Advertising & Media Private Limited 23-09-2023 30-06-2025 0.18 0.00 0.00 0.18 0.00 Total (April-June, 2025) 294.39 29.33 29.33 31.40 233.67 Total (Till June, 2025) 14215.64 665.03 665.03

96 61 Newonn Advertising & Media Private Limited 23-09-2023 30-06-2025 0.18 0.00 0.00 0.18 0.00 Total (April-June, 2025) 294.39 29.33 29.33 31.40 233.67 Total (Till June, 2025) 14215.64 665.03 665.03 373.07 13179.16 Notes: ‘0’ means an amount below two decimals; ‘-’ means no value

Data awaited

C.9 Corporate Liquidation Accounts The Regulations require a Liquidator to deposit the amount of unclaimed dividends, if any, and undistributed proceeds, if any, in a liquidation process along with any income earned thereon into the corporate liquidation account before he submits an application for dissolution of the corporate person. It also provides a process for a stakeholder to seek withdrawal from the said account. Similar provisions exist for voluntary liquidation processes. The details of these accounts at the end of June 2025 are presented in Table 14. Table 14: Corporate Liquidation Accounts as on June 30, 2025 (Amount in Rs.lakh) Name of Account Opening Deposit Withdrawn Balance at Balance during during the end of the period the period the period Corporate Liquidation Account 2019 – 20 0 476.26 0.21 476.05 2020 – 21 476.05 116.18 0 592.23 2021 – 22 592.23 25.93 4.84 613.32 2022 – 23 613.32 596.1 0 1209.42 2023 – 24 1209.42 777.37 9.26 1977.53 2024 - 25 1977.53 755.16 3.16 2729.53 Apr – Jun, 2025 2729.53 16.11 19.06 2726.58 Corporate Voluntary Liquidation Account 2019 – 20 0 109.7 0 109.7 2020 – 21 109.7 112.06 0 221.76 2021 – 22 221.76 127.94 0.03 349.67 2022 – 23 349.67 241.29 10.42 580.54 2023 – 24 580.54 265.49 39.02 807.01 2024 - 25 807.01 166.51 17.50 956.02 Apr – Jun, 2025 956.02 106.14 2.74 1059.42 C.10 Pre-Packaged Insolvency Resolution Process The Central Government enacted the Insolvency and Bankruptcy Code (Amendment) Act, 2021 on August 11, 2021 which was

2025 956.02 106.14 2.74 1059.42 C.10 Pre-Packaged Insolvency Resolution Process The Central Government enacted the Insolvency and Bankruptcy Code (Amendment) Act, 2021 on August 11, 2021 which was deemed to have come into force on April 4, 2021 introducing the Pre-packaged Insolvency Resolution Process (PPIRP) for corporate MSMEs. On April 9, 2021, the Central Government notified the Insolvency and Bankruptcy (Pre-packaged Insolvency Resolution Process) Rules, 2021 prescribing the manner and form of making application to initiate PPIRP and the IBBI notified the IBBI (Pre- packaged Insolvency Resolution Process) Regulations, 2021. The Regulations provide for manner of carrying out certain processes and tasks under PPIRP. As per the information available with the Board, 14 applications have been admitted as on June 30, 2025, out of which one has been withdrawn and resolution plans has been approved in nine cases i.e., Amrit India Limited, Sudal Industries Limited, Shree Rajasthan Syntex Limited, Enn Tee International Limited, GCCL Infrastructure and Projects Limited, Mudraa Lifespaces Private Limited, Garodia Chemicals Limited, Kvir Towers Private Limited and RG Residency Private Limited. The details of the ongoing cases are in Table 15. Table 15: List of ongoing cases for PPIRP as on June 30, 2025 Sl. Name of the CD Date of Name of the admission NCLT Bench 1. Kethos Tiles Private Limited 04-01-24 Ahmedabad 2. Shreemati Fashions Private Limited 05-01-24 Kolkata 3. Kratos Energy & Infrastructure Limited 01-02-24 Mumbai 4. Vedik Ispat Private Limited 05-02-25 Bengaluru C.

rivate Limited 04-01-24 Ahmedabad 2. Shreemati Fashions Private Limited 05-01-24 Kolkata 3. Kratos Energy & Infrastructure Limited 01-02-24 Mumbai 4. Vedik Ispat Private Limited 05-02-25 Bengaluru C. 11 Avoidance Transactions The Code read with Regulations require the RPs and Liquidators to file applications for avoidance of transactions, with the AA seeking appropriate directions. 1442 applications seeking avoidance of transactions have been filed with the AA till June 30, 2025 as presented in Table 16.

16 Table 16: Details of avoidance applications filed (Amount in Rs. crore) Sl. Nature of transactions Applications Filed Number of transactions Amount involved 1 Preferential 211 29919.98 2 Undervalued 40 1818.01 3 Fraudulent 423 122370.48 4 Extortionate 4 75.65 5 Combination 764 235779.86 Total 1442 389963.98 D. Individual Processes D.1 Insolvency Resolution Process The provisions relating to insolvency resolution and bankruptcy relating to PGs to CDs came into force on December 1, 2019. As per the information received from the applicants, IPs, and data collected from various benches of NCLT and Debt Recovery Tribunal (DRT), 4276 applications have since been filed as of June 30, 2025, for initiation of personal insolvency resolution process (PIRP) of PGs to CDs. Out of them, 631 applications have been filed by the debtors and 3645 applications by the creditors under sections 94 and 95 of the Code, respectively.

lvency resolution process (PIRP) of PGs to CDs. Out of them, 631 applications have been filed by the debtors and 3645 applications by the creditors under sections 94 and 95 of the Code, respectively. Among them 51 have been filed before different benches of Debt Recovery Tribunal (DRT) and 4225 have been filed before different benches of NCLT (Table 17). Table 17: Insolvency Resolution of Personal Guarantors (Amount in Rs. crore) Period Applications filed by Total Adjudicatng Debtors Creditors Authority (u/s 94) (u/s 95) No. Debt No. Debt No. Debt NCLT DRT Amount Amount Amount 2019 - 20 4 1827.57 23 3299.82 27 5127.39 26 1 2020 - 21 27 3103.27 255 40384.58 282 43487.85 276 6 2021 - 22 88 3550.20 961 73057.07 1049 76607.27 1034 15 2022 - 23 88 10796.65 909 40355.88 997 51152.53 996 1 2023 - 24 250 5622.19 587 32897.84 837 38520.03 810 27 2024 - 25 173 5921.11 892 65204.19 1065 71125.30 1064 1 Apr - Jun, 2025 1 3.42 18 151.25 19 154.67 19 0 Total 631 30824.41 3645 255350.63 4276 286175.04 4225 51 Note: The data are provisional. These are revised on a continuous basis as further information is received. Debt data not available in 656 cases. Of the 4276 applications, 121 applications have been withdrawn/ rejected/ dismissed before the appointment of RP and RPs have been appointed in 1941 cases. After the appointment of RP, 149 cases have been withdrawn/ rejected/ dismissed, and 711 cases have been admitted.

d/ dismissed before the appointment of RP and RPs have been appointed in 1941 cases. After the appointment of RP, 149 cases have been withdrawn/ rejected/ dismissed, and 711 cases have been admitted. The details are given in Table 18. Table 18: Status of filed applications for initiation of Insolvency Resolution Process of PGs to CDs (Number) Period No. of Before appointment No. of After appoint- No. of appli- of RP cases ment of RP cases cations No. of No. of where No. of No. of Admit- filed Appli- Appli- RPs have Appli- Appli- ted cations cations been cations cations with dismissed/ appointed* with dismissed/ drawn rejected drawn rejected 2019 – 20 27 0 0 2 0 0 0 2020 – 21 282 6 1 35 2 1 13 2021 – 22 1049 15 15 469 0 7 35 2022 - 23 997 19 30 557 13 25 214 2023 – 24 837 12 19 595 19 18 179 2024 - 25 1065 1 3 232 6 44 239 Apr - Jun, 2025 19 0 0 51 4 10 31 Total 4276 53 68 1941 44 105 711 *This includes the admitted cases and cases, which are withdrawn or dismissed or rejected after appointment of RP. Out of the 711 admitted PIRPs, 216 have been closed. Of these, 12 have been withdrawn; 157 have been closed on non-submission or rejection of repayment plan; and 44 have yielded approval of repayment plan. In cases where repayment plans have been approved, the creditors have realised Rs.102.78 crore, which is 2.16% of their admitted claims. D.2 Bankruptcy Process If the resolution process fails or repayment plan is not implemented, the debtor or the creditor may make an application for initiation of the bankruptcy process.

itted claims. D.2 Bankruptcy Process If the resolution process fails or repayment plan is not implemented, the debtor or the creditor may make an application for initiation of the bankruptcy process. As per the information received from the applicants, IPs and data collected from various benches of NCLT and DRT, 67 bankruptcy applications have since been filed as of June 2025. Out of them, two applications are filed by the debtor and 65 applications have been filed by the creditors under section 122 and 123 of the Code respectively. Among them, one application has been filed before DRT, Chennai and 66 applications have been filed before different benches of NCLT. E. Service Providers E.1 Insolvency Professionals An individual, who is enrolled with an IPA as a professional member and has the required qualification and experience and passed the Limited Insolvency Examination, is registered as an IP. Pursuant to the IBBI (Insolvency Professionals) (Amendment) Regulations, 2022 read with IBBI (Model Byelaws and Governing Board of Insolvency Professional Agencies) (Amendment) Regulations, 2022, the Insolvency Professional Entities (IPEs) have been permitted to be registered as IP to carry on the activities of an IP. An IP needs an authorization for assignment (AFA) to take up an assignment under the Code with effect from January 1, 2020. The IBBI made available an online facility from November 16, 2019, to enable an IP to make an application for issuance/renewal of AFA to the concerned IPA. Thereafter, an IPA processes such applications

IBBI made available an online facility from November 16, 2019, to enable an IP to make an application for issuance/renewal of AFA to the concerned IPA. Thereafter, an IPA processes such applications

17 electronically. The details of IPs registered as on June 30, 2025, and AFAs held by them, IPA-wise, are presented in Table 19. Table 19: Registered IPs and AFAs as on June 30, 2025 City / Region Registered IPs IPs having AFA IIIP ICSI IPA of Total IIIP ICSI IPA of Total ICAI IIP ICMAI ICAI IIP ICMAI New Delhi 507 295 97 899 205 123 46 374 Rest of Northern Region 521 220 90 831 191 98 30 319 Mumbai 445 157 43 645 181 68 17 266 Rest of Western Region 383 143 55 581 169 69 21 259 Chennai 158 90 24 272 60 38 13 111 Rest of Southern Region 455 238 95 788 158 92 47 297 Kolkata 249 43 29 321 120 19 17 156 Rest of Eastern Region 81 35 12 128 26 18 8 52 Total (Individual) 2799 1221 445 4465 1110 525 199 1834 Total (IPE as IP) 55 16 25 96 46 10 18 74 Grand Total 2854 1237 470 4561 1156 535 217 1908 Of the 4538 IPs registered till date, registrations of 15 IPs have been cancelled through disciplinary action, and registrations of 24 IPs cancelled on failing to fulfil the requirement of fit and proper person status. As per information available, 34 IPs have passed away.

ncelled through disciplinary action, and registrations of 24 IPs cancelled on failing to fulfil the requirement of fit and proper person status. As per information available, 34 IPs have passed away. The registrations and cancellations of registrations of IPs, till June 30, 2025, are presented in Table 20. Table 20: Registration and Cancellation of Registration of IPs Year / Quarter Regis- Registered Cancelled during the Registered tered during the period on account of at the at the period Discip- Failing to fulfil Dea- end of beginning linary the continuing th the of the Process requirement of period period ‘fit and proper person’ status 2016 - 17 0 977 0 0 0 977 (Nov – Dec) # 2016 - 17 (Jan – Mar) 0 96 0 0 0 96 2017 – 18 96 1716 0 0 0 1812 2018 – 19 1812 648 4 0 0 2456 2019 – 20 2456 554 0 1 5 3004 2020 – 21 3004 506 0 1 5 3504 2021 – 22 3504 549 1 0 8 4044 2022 – 23 4044 209 2 0 5 4246 2023 – 24 4246 116 3 0 7 4352 2024 - 25 4352 114 5 22 4 4435 Apr - Jun, 2025 4435 30 0 0 0 4465 Total (Individual) NA 4538 15 24 34 4465 Total (IPE as IP) NA 96 0 0 0 96 Grand Total NA 4634 15 24 34 4561

Registration with validity of six months. These registrations expired by

June 30, 2017. An individual with 10 years of experience as a member of the ICAI, ICSI, ICMAI or a Bar Council or 10 years of experience in the field of law, after receiving a Bachelor’s degree in law or 10 years of experience in management, after receiving a Master’s degree in Management or two year full time Post Graduate Diploma in Management or 15 years of experience in management, after receiving a Bachelor’s degree is eligible for registration as an IP on passing the Limited Insolvency Examination. The Post Graduate Insolvency Programme (PGIP) is a first of its kind programme for those aspiring to take up the profession of IP as a career without having to wait for acquiring the specified 10/15 years of experience. The IBBI has granted approval to three institutes to conduct PGIP - the Indian Institute of Corporate Affairs, National Law Institute University, Bhopal and National Law University, Delhi. The IBBI has granted 46 registrations based on this qualification, until June 30, 2025. Table 21 presents distribution of IPs as per their eligibility (an IP may be a member of more than one Institute) as on June 30, 2025. Of the 4465 IPs (individual) as on June 30, 2025, 460 IPs (constituting about ten per cent of the total registered IPs) are female. Table 21: Distribution of IPs as per their Eligibility as on June 30, 2025 Eligibility No.

June 30, 2025, 460 IPs (constituting about ten per cent of the total registered IPs) are female. Table 21: Distribution of IPs as per their Eligibility as on June 30, 2025 Eligibility No. of IPs (Individual) Male Female Total Member of ICAI 2215 224 2439 Member of ICSI 602 139 741 Member of ICMAI 186 19 205 Member of Bar Council 238 35 273 Managerial Experience 724 37 761 PGIP Qualified 40 6 46 Total 4005 460 4465 The Regulations provide that an IP (individual) shall be eligible to obtain an AFA if he has not attained the age of 70 years. Table 22 presents the age profile of the IPs registered as on June 30, 2025. Table 22: Age Profile of IPs (individual) as on June 30, 2025 Age Group Registered IPs IPs having AFA ( in Years) IIIP ICSI IPA of Total IIIP ICSI IPA of Total ICAI IIP ICMAI ICAI IIP ICMAI < 30 14 3 4 21 9 2 2 13

30 < 40 159 66 16 241 92 38 12 142 40 < 50 934 320 54 1308 381 144 25 550 50 < 60 845 378 107 1330 334 178 55 567 60 < 70 729 350 207 1286 294 163 105 562 70 < 80 112 96 54 262 NA NA NA NA 80 < 90 5 7 3 15 NA NA NA NA 90 1 1 0 2 NA NA NA NA Total 2799 1221 445 4465 1110 525 199 1834 NA: Not Applicable. E.2 Replacement of IRP with RP Section 22(2) of the Code provides that the CoC may, in its first meeting, by a majority vote of not less than 66% of the voting share of the FCs, either resolve to appoint the IRP as the RP or to replace

n 22(2) of the Code provides that the CoC may, in its first meeting, by a majority vote of not less than 66% of the voting share of the FCs, either resolve to appoint the IRP as the RP or to replace

18 the IRP by another IP to function as the RP. Under section 22(4) of the Code, the AA shall forward the name of the RP, proposed by the CoC, under section 22(3)(b) of the Code, to IBBI for its confirmation and shall make such appointment after such confirmation. However, to save time in such reference, a database of all the IPs registered with the IBBI has been shared with the AA, disclosing whether any disciplinary proceeding is pending against any of them and the status of their AFAs. While the database is currently being used by various Benches of the AA, in a few cases, the IBBI receives references from the AA and promptly responds to it. Till June 30, 2025, as per updates available, a total of 1766 IRPs have been replaced with RPs, as shown in Figure 15. It is observed that IRPs in about 35% of CIRPs initiated by CD are replaced by RPs, in 32% of CIRPs initiated by OCs and in 22% of CIRPs initiated by FCs. Figure 15: Replacement of IRP with RP E.3 Insolvency Professional Entities During the quarter under review, no IPEs was recognised. As on June 30, 2025, there were 127 IPEs (Table 23). Table 23: IPEs as on June 30, 2025 Quarter No.

olvency Professional Entities During the quarter under review, no IPEs was recognised. As on June 30, 2025, there were 127 IPEs (Table 23). Table 23: IPEs as on June 30, 2025 Quarter No. of IPEs Recognised Derecognised At the end of the Period 2016 - 17 (Jan – Mar) 3 0 3 2017 – 18 73 1 75 2018 – 19 13 40 48 2019 – 20 23 2 69 2020 – 21 14 0 83 2021 – 22 10 2 91 2022 – 23 17 1 107 2023 – 24 15 0 122 2024 - 25 7 2 127 Apr - Jun, 2025 0 0 0 Total 175 48 127 E.4 Insolvency Professional Agencies IPAs are front-line regulators and are responsible for developing and regulating the insolvency profession. They discharge three kinds of functions, namely, quasi-legislative, executive, and quasi- judicial. The quasi-legislative functions cover laying down standards and code of conduct through byelaws, which are binding on all members. The executive functions include monitoring, inspection, and investigation of professional members on a regular basis, addressing grievances of aggrieved parties, gathering information about their performance, etc., with the overarching objective of promoting best practices and conduct by IPs. The quasi-judicial functions include dealing with complaints against members and taking suitable disciplinary actions. As on June 30, 2025, there are three IPAs registered in accordance with the Code and Regulations. The IBBI interacts with the Managing Directors (MDs) of the IPAs and the IU every month, to obtain feedback on areas of concern for the profession of IPs and discuss the resolutions and the way forward.

IBBI interacts with the Managing Directors (MDs) of the IPAs and the IU every month, to obtain feedback on areas of concern for the profession of IPs and discuss the resolutions and the way forward. Table 24 presents the details of activities by the IPAs. Table 25 gives details of number of continuing professional education (CPE) hours earned by IPs. Table 24: Activities by IPAs Period Number of Pre- CPE Training Other Discip- Compl- regist- Progra- Work- Work linary aints ration mmes shops shops/ Orders (Forwar- Courses cond- for IPs Webinars/ Issued ded by conducted ucted Roundtables/ IBBI) Seminars Disposed 2018 – 19 16

7 100 4 11 2019 – 20 11 30 9 157 9 127 2020 – 21 14 193 66 102 42 102 2021 – 22 13 133 56 81 23 12 2022 – 23 15 231 104 192 85 125 2023 – 24 3 198 61 135 49 179 2024 - 25 3 250 92 161 30 115 Apr - Jun, 2025 1 67 23 44 7 55 Total 76 1102 418 972 249 726 Table 25: CPE Hours earned by the IPs Period Number of CPE Hours earned by members of IIIP ICAI ICSI IIP IPA ICAI Total 2019 – 20 1160 695 320 2175 2020 – 21 18465 8746 4647 31858 2021 – 22 14123 7890 3872 25885 2022 – 23 22185 10732 3433 36350 2023 – 24 5803 9835 3715 19353 2024 - 25 14240 9125 3635 27000 Apr - Jun, 2025 3552 2431 595 6578 Total 79528 49454 20217 149199 Average CPE hours per registered IP 28.41 40.50 45.43 33.42

433 36350 2023 – 24 5803 9835 3715 19353 2024 - 25 14240 9125 3635 27000 Apr - Jun, 2025 3552 2431 595 6578 Total 79528 49454 20217 149199 Average CPE hours per registered IP 28.41 40.50 45.43 33.42

19 E.5 Information Utility The Code provides that the data with the IU facilitates the CIRP. The RoD of the IU provides evidence of debt and default and assists the AA in deciding on an application for admission of insolvency proceedings against a CD. Sections 7(3) & 9(3) of the Code read with the Insolvency and Bankruptcy (Application to Adjudicating Authority) Rules, 2016, require submission of RoD from an IU as evidence of default, among various other options, along with application for initiation of CIRP. The RoD issued by an IU has evidentiary value in IBC processes. It contains complete details of the parties to the debt, debt information, security details, default information, details of communication with debtor and authentication status by the counter parties of the debt categorized in accordance with regulation 21 of the IBBI (Information Utilities) Regulations, 2017. The IU issues RoD in every defaulted loan (unique debt) reported to it on completing the process of authentication. There is one IU, namely, the NeSL that provides authenticated financial information to the users. The IBBI interacts with the MD & CEO of the IU along with the MDs of IPAs every month to discuss the issues relating to receipt and authentication of financial information. As at the end of June 2025, NeSL has issued about 1,37,780 RoDs under Corporate Segment to support the IBC ecosystem.

scuss the issues relating to receipt and authentication of financial information. As at the end of June 2025, NeSL has issued about 1,37,780 RoDs under Corporate Segment to support the IBC ecosystem. Figure 16 provides details of the registered users and information with NeSL, as submitted by it. Figure 16: Details of information with NeSL E.6 Registered Valuer Organisations The Companies (Registered Valuers and Valuation) Rules, 2017 (Valuation Rules) made under section 247 of the Companies Act, 2013 provide a unified institutional framework for development and regulation of valuation profession. Its remit is limited to valuations required under the Companies Act, 2013 and the Code. The IBBI performs the functions of the Authority under the Valuation Rules. It recognises Registered Valuer Organisations (RVOs) and registers RVs and exercises regulatory oversight over them, while RVOs serve as front-line regulators for the valuation profession. An individual having specified qualification and experience needs to enrol with an RVO, complete the educational course conducted by the RVO and clear the examination conducted by IBBI, before seeking registration with IBBI as an RV. There are currently 14 RVOs. The IBBI meets MDs / CEOs of RVOs every month to discuss the issues arising from the valuation profession, to resolve queries of the RVOs and to guide them in discharge of their responsibilities. The details of individual RVs, RVO-wise, as on June 30, 2025, are given in Table 26.

the valuation profession, to resolve queries of the RVOs and to guide them in discharge of their responsibilities. The details of individual RVs, RVO-wise, as on June 30, 2025, are given in Table 26. A total of 5811 individuals have active registrations, four of them are registered for all three asset classes, 89 are registered for two asset classes and the balance 5718 are registered for one asset class. As on June 30, 2025, the registration of four RVs have been cancelled. Table 26: Registered Valuers as on June 30, 2025 (Number) Sl. Registered Valuer Organisation No. of Registration granted in each Asset Class Land & Plant & Securities Total Build- Machi- or Financial ing nery Assets 1. RVO Estate Managers and Appraisers 98 18 15 131 Foundation 2. IOV: IOV Registered Valuers Foundation 1699 264 197 2160 3. ICSI: ICSI Registered Valuers Organisation 0 0 258 258 4. IIV India registered Valuers Foundation 210 51 58 319 5. ICMAI: ICMAI Registered Valuers 68 34 322 424 Organisation 6. ICAI: ICAI Registered Valuers Organisation 3 1 1164 1168 7. PVAI: PVAI Valuation Professional 328 60 140 528 Organisation 8. CVSRTA: CVSRTA Registered Valuers 196 61 0 257 Association 9. ACVA: Association of Certified Valuators 0 0 1 1 and Analysts* 10. CEV: CEV Integral Appraisers Foundation 170 47 3 220 11. DJF: Divya Jyoti Foundation 127 21 75 223 12. Nandadeep Valuers Foundation 7 0 1 8 13. IBVA: International Business Valuers 5 2 24 31 Association 14. AIVA: All India Valuers Association 2 0 0 2 15.

. DJF: Divya Jyoti Foundation 127 21 75 223 12. Nandadeep Valuers Foundation 7 0 1 8 13. IBVA: International Business Valuers 5 2 24 31 Association 14. AIVA: All India Valuers Association 2 0 0 2 15. AaRVF: Assessors and Registered Valuers 101 30 52 183 foundation Total 3014 589 2310 5913 Note: Registration of 5 RVs have since been cancelled. NA signifies that the RVO is not recognised for that asset class. *The RVO has merged with IOV Registered Valuers Foundation and the transfer of membership of members is under process. RVs are permitted to form an entity (Partnership / Company) for rendering valuation services. There are 122 such entities registered as RVs as on June 30, 2025, as presented in Table 27. 57 of them are registered for three asset classes, 23 are registered for two asset classes and 42 are registered for one asset class. The registration of RVs till June 30, 2025 is given in Table 28.

20 The average age of RVs as on June 30, 2025, stood at 48 years across asset classes. It is 50 years for Land & Building, 56 years for Plant & Machinery and 45 years for Securities or Financial Assets (Table 30).

age of RVs as on June 30, 2025, stood at 48 years across asset classes. It is 50 years for Land & Building, 56 years for Plant & Machinery and 45 years for Securities or Financial Assets (Table 30). Of the 5913 RVs as on June 30, 2025, 604 RVs (constituting about 10% of the total RVs) are females. Table 30: Age profile of RVs as on June 30, 2025 Age Group Land & Plant & Securities or Total (in years) Building Machinery Financial Assets < 30 75 2 57 134

30 < 40 742 74 822 1638 40 < 50 520 119 765 1404 50 < 60 981 169 388 1538 60 < 70 609 150 244 1003 70 < 80 76 68 32 176 80 11 7 2 20 Total 3014 589 2310 5913 E.7 Complaints and Grievances The IBBI (Grievance and Complaint Handing Procedure) Regulations, 2017 enable a stakeholder to file a grievance or a complaint against a service provider. Beside this, grievance and complaints are received from the Centralised Public Grievance Redress and Monitoring System (CPGRAMS), Prime Minister’s Office (PMO), MCA, and other authorities.

provider. Beside this, grievance and complaints are received from the Centralised Public Grievance Redress and Monitoring System (CPGRAMS), Prime Minister’s Office (PMO), MCA, and other authorities. The receipt and disposal of grievances and complaints till June 30, 2025 is presented in Table 31. Table 31: Receipt and Disposal of Grievances and Complaints till June 30, 2025 (Number) Year / Complaints and Grievances Received Total Quarter Under the Through Through Recei- Dispo- Under Regulations CPGRAM/PMO/ Other ved sed Exami- MCA/Other Modes nation Authorities Rece- Dispo- Rece- Dispo- Rece- Dispo- ived sed ived sed ived sed 2017 – 18 18 0 6 0 22 2 46 2 44 2018 – 19 111 51 333 290 713 380 1157 721 480 2019 – 20 153 177 239 227 1268 989 1660 1393 747 2020 – 21 268 260 358 378 990 1364 1616 2002 361 2021 – 22 276 279 574 570 611 784 1461 1633 189 2022 - 23 235 211 399 386 238 272 872 869 192 2023 – 24 209 193 435 452 311 271 955 916 231 2024 - 25 267 239 320 342 316 314 903 895 239 Apr-Jun, 2025 66 85 115 96 57 101 238 282 195 Total 1603 1495 2779 2741 4526 4477 8908 8713 195 E.8 Examinations E.8.1 Limited Insolvency Examination The IBBI publishes the syllabus, format, etc. of the examination under regulation 3(3) of the IBBI (Insolvency Professionals) Regulations, 2016. It reviews the same continuously to keep it relevant with respect to dynamics of the market.

t, etc. of the examination under regulation 3(3) of the IBBI (Insolvency Professionals) Regulations, 2016. It reviews the same continuously to keep it relevant with respect to dynamics of the market. It has successfully completed seven phases of the Limited Insolvency Examination. The eighth phase commenced on July 1, 2023, and concluded on June 30, 2025. The ninth phase begins on July 1, 2025. It is a Table 27: Registered Valuers (Entities) as on June 30, 2025 Registered Valuer Number Asset Class Organisation of Entities Land & Plant & Securities Building Machinery or Financial Assets RVO Estate Managers and Appraisers 6 6 4 5 Foundation IOV Registered Valuers Foundation 43 37 33 35 ICSI Registered Valuers Organisation 6 2 2 6 IIV India Registered Valuers Foundation 3 3 3 2 ICMAI Registered Valuers Organisation 18 10 9 17 ICAI Registered Valuers Organisation 21 2 1 20 PVAI Valuation Professional Organisation 5 4 4 5 CVSRTA Registered Valuers Association 1 1 1 0 CEV Integral Appraisers Foundation 2 2 2 0 Divya Jyoti Foundation 3 2 2 3 All India Institute of Valuers Foundation 1 1 1 1 International Business Valuers Association 11 10 8 8 Nandadeep Valuers Foundation 1 1 1 1 Assessors and Registered Valuers foundation 1 1 1 1 Total 122 82 72 104 Table 28: Registration of RVs till June 30, 2025 (Number) Year / Quarter Land & Plant & Securities or Total Building Machinery Financial Assets 2017 – 18 0 0 0 0 2018 – 19 781 121 284 1186 2019 – 20 848 204 792 1844 2020 – 21 409 82 446 937 2021 – 22 302 67 303 672 2022 – 23

& Plant & Securities or Total Building Machinery Financial Assets 2017 – 18 0 0 0 0 2018 – 19 781 121 284 1186 2019 – 20 848 204 792 1844 2020 – 21 409 82 446 937 2021 – 22 302 67 303 672 2022 – 23 311 57 275 643 2023 – 24 138 23 89 250 2024 - 25 170 27 83 280 Apr-June, 2025 55 8 38 101 Total 3014 589 2310 5913 Note: Registration of 5 RVs have since been cancelled. As on June 30, 2025, 1449 RVs (constituting 25% of the total RVs registered) are from metros, while 4464 RVs (constituting 75% of the total RVs registered) are from non-metro locations. The region- wise detail of RVs is given in Table 29. Table 29: Region wise RVs as on June 30, 2025 (Number) City / Region Land & Plant & Securities or Total Building Machinery Financial Assets New Delhi 93 39 271 403 Rest of Northern Region 506 102 407 1014 Mumbai 128 56 345 529 Rest of Western Region 888 177 398 1463 Chennai 123 46 165 334 Rest of Southern Region 1175 136 551 1862 Kolkata 38 20 125 183 Rest of Eastern Region 63 13 48 124 Total 3014 589 2310 5913

56 345 529 Rest of Western Region 888 177 398 1463 Chennai 123 46 165 334 Rest of Southern Region 1175 136 551 1862 Kolkata 38 20 125 183 Rest of Eastern Region 63 13 48 124 Total 3014 589 2310 5913

21 computer based online examination available on daily basis from various locations across India. NSEIT Limited is the current test administrator. The details of the examination are given in Table 32. Table 32: Limited Insolvency Examination Phase Period Number of Attempts Successful (some candidates made Attempts more than one attempt) First Jan, 2017 – Jun, 2017 5329 1201 Second Jul, 2017 – Dec, 2017 6237 1112 Third Jan, 2018 – Oct, 2018 6344 1013 Fourth Nov, 2018 – Jun, 2019 3025 505 Fifth Jul, 2019 – Dec, 2020 5860 1016 Sixth Jan, 2021 – Feb, 2022 2741 474 Seventh Mar, 2022 – Jun, 2023 1677 198 Eighth Jul, 2023 - Mar, 2024 380 58 Apr, 2024 - Jun, 2024 184 27 July, 2024 – Sept, 2024 192 35 Oct, 2024- Dec, 2024 157 25 Jan, 2025- Mar, 2025 190 28 Apr, 2025 – June, 2025 351 68 Total 32667 5760 E.8.2 Valuation Examinations The IBBI, being the authority under the Valuation Rules commenced the Valuation Examinations for asset classes of: (a) Land and Building, (b) Plant and Machinery and (c) Securities or Financial Assets, on March 31, 2018. It reviews the examinations continuously to keep it relevant with the changing times. Presently, the fifth phase of valuation examinations is going on from May 1, 2024.

ial Assets, on March 31, 2018. It reviews the examinations continuously to keep it relevant with the changing times. Presently, the fifth phase of valuation examinations is going on from May 1, 2024. It is a computer based online examination available from several locations across India. National Institute of Securities Markets is the current test administrator. The details of the Examinations are given in Table 33. Table 33: Valuation Examinations Phase Period Number of Attempts Number of Successful (some candidates made Attempts in Asset Class more than one attempt) in Asset Class Land & Plant & Securities Land & Plant & Securities Building Machi- or Financial Building Machi- or Financial nery Assets nery Assets First Mar, 2018 – 9469 1665 4496 1748 324 707 Mar, 2019 Second Apr, 2019 – 3780 757 4795 380 95 656 May, 2020 Third Jun, 2020 – 8370 2015 8377 620 139 781 Jun, 2022 Fourth Jul, 2022 - 4042 764 2459 392 72 262 Apr, 2024 Fifth May, 2024 - 235 32 145 31 6 17 Jun, 2024 Jul,2024- 391 51 181 54 10 21 Sep, 2024 Oct 2024- 372 40 164 55 8 21 Dec, 2024 Jan - 2025 338 52 245 47 5 19 Mar - 2025 Apr - 2025 333 42 293 36 7 32 Jun - 2025 Total 27330 5418 21175 3363 666 2510 E.9 Disciplinary Orders During the quarter, the Disciplinary Committee/Authority of the IBBI disposed of 9 show cause notices issued to the IPs, 1 show cause notice issued to RV and 2 appeals preferred by RVs for contravention of the provisions of law, by passing suitable orders. F. Orders F.1 Supreme Court Rakesh Bhanot Vs. M/s. Gurdas Agro Private Limited [Criminal Appeal No.

2 appeals preferred by RVs for contravention of the provisions of law, by passing suitable orders. F. Orders F.1 Supreme Court Rakesh Bhanot Vs. M/s. Gurdas Agro Private Limited [Criminal Appeal No. 1607 of 2025] The appellant who was the director/ personal guarantor to CD had issued a few cheques for discharge of liabilities of their legally enforceable liability. As the said cheques were dishonoured for insufficient funds, proceedings under section 138 of the Negotiable Instruments Act, 1881 (NI Act) before the Judicial First Class Magistrate Court were initiated by an operational creditor against the personal guarantor to the CD. Thereafter, the personal guarantor to CD had filed an application before AA under section 94 of IBC. However, the application filed by the personal guarantor to CD before the Judicial First Class Magistrate Court seeking stay on the section 138 NI Act proceedings in view of the interim moratorium under section 94 of IBC, was dismissed. Appeal filed against the said order before the Punjab & Haryana HC was also dismissed. On further appeal, the issue for consideration before SC was whether proceedings under section 138 of NI Act, for cheque dishonour, should be stayed with the filing of application under section 94 of IBC and consequent application of interim moratorium under section 96 of the IBC. SC observed that the moratorium under sections 96 and 101 of the Code is intended to protect debtors from civil debt recovery actions, not criminal prosecutions.

ratorium under section 96 of the IBC. SC observed that the moratorium under sections 96 and 101 of the Code is intended to protect debtors from civil debt recovery actions, not criminal prosecutions. It distinguished between moratorium under section 14 of the Code, which protects only the CD and that does not extend to shielding individuals from criminal liability under section 138/141 of the NI Act, whereas interim moratorium contemplated under section 96 is to be derived from the object of the act, which is not to stall the proceedings unrelated to the recovery of the debt. The protection is not available against penal actions, the object of which is to not recover any debt. SC observed that the object of moratorium is not to stall criminal proceedings or any other proceedings which are unrelated to the recovery of the debt. SC emphasised that the term “any legal action or proceedings” does not mean “every legal action or proceedings” and must be interpreted to mean only proceedings concerning recovery of debt. Section 138 proceedings aim to uphold the integrity of commercial transactions by holding individuals accountable for cheque dishonour, a criminal act, and are not merely debt recovery actions. SC, while dismissing the appeal, observed that the statutory liability against the directors under section 138 of the N.I. Act, is personal and hence, continues to bind natural persons, irrespective of any moratorium applicable to the CD.

ed that the statutory liability against the directors under section 138 of the N.I. Act, is personal and hence, continues to bind natural persons, irrespective of any moratorium applicable to the CD. The acceptance of the resolution plan under section 31 of IBC or its implementation thereof will have no effect on the prosecution under section 138 of the NI Act, 1881. Kalyani Transco Vs. Bhushan Power and Steel Limited. & Ors. [Civil Appeal No. 1808 of 2020] During the pendency of the application filed for approval of resolution plan filed by JSW Steel Ltd (SRA) for Bhushan Power

22 and Steel Ltd (CD) before AA, criminal proceedings against the suspended management of the CD were initiated by the Enforcement Directorate (ED) under the PMLA on 25.04.2019.On 05.09.2019, AA approved the resolution plan submitted by SRA with certain conditions. Post approval of the resolution plan, ED passed a provisional attachment order (PAO) on 10.10.2019 by attaching assets of the CD under the provisions of PMLA. Besides the CoC challenging PAO, SRA also challenged the PAO of the ED and certain conditions imposed by AA in the approved resolution plan before the NCLAT. On 17.02.2020, the NCLAT, while staying the said orders, upheld the resolution plan and dismissed appeals filed by the OCs and ex-promoters of the CD.

n the approved resolution plan before the NCLAT. On 17.02.2020, the NCLAT, while staying the said orders, upheld the resolution plan and dismissed appeals filed by the OCs and ex-promoters of the CD. On appeal, the issues before the SC were as follows: (1) Whether OCs and Ex-Promoters are entitled to file appeals against the NCLAT order under section 62 of the Code and the SRA against the AA order, approving the resolution plan, before the NCLAT? (2) Whether the eligibility of SRA under section 29A of the Code and the compliance certificate under Schedule – I was adequately verified by the RP? (3) Whether NCLAT had any powers of judicial review over the decision taken of ED under the PMLA? (4) Whether the RP filed the application for approval of the plan within the timeline prescribed under section 12 of IBC? (5) Did the plan comply with mandatory requirements, of section 30(2) of IBC and ensured priority payment to OCs, and feasibility, viability, of the plan (6) Can the SRA justify the significant delay (over 2 years) in implementing the plan by citing pending litigation and then claim fait accompli after making delayed payments? SC while rejecting the resolution plan of the SRA, held as follows: (1) Since CIRP is a collective proceeding (in rem) and OCs and ex-promoters are necessary stakeholders in the CIRP of the CD whose appeals have been dismissed by the NCLAT, they are “persons aggrieved” for the purpose of section 62 and their appeals are maintainable before the SC.

cessary stakeholders in the CIRP of the CD whose appeals have been dismissed by the NCLAT, they are “persons aggrieved” for the purpose of section 62 and their appeals are maintainable before the SC. Moreover, SRA wasn’t ‘aggrieved’ by the approval itself, and none of the grounds under section 61(3) of the Code (e.g., contravention of law, material irregularity by RP, etc) were available to challenge conditions of the resolution plan which were unfavourable to SRA (2) RP has merely reproduced the clauses of the resolution plan and did not submit the Compliance Certificate under Form - H of the Schedule I of the CIRP Regulations, 2016. Moreover, the RP has failed to determine the eligibility of the SRA as required under section 29A of the Code since the document submitted by the RP nowhere stated about eligibility of SRA (3) PMLA being a public law, neither the AA nor the NCLAT is vested with the powers of judicial review over the decision taken by the Government or Statutory Authority in relation to a matter which is in the realm of public law. Thus, the proceedings initiated by the ED cannot be brought within the fold of the phrase “arising out of or in relation to the insolvency resolution” under section 60(5)(c) of the Code. (4) RP utterly disregarded the timeline to complete the CIRP under section 12 on the false pretext of an appeal filed by the PRA which was pending for adjudication before the NCLAT, albeit the NCLAT had permitted the RP to proceed with approval of plan.

e CIRP under section 12 on the false pretext of an appeal filed by the PRA which was pending for adjudication before the NCLAT, albeit the NCLAT had permitted the RP to proceed with approval of plan. Moreover, the RP failed to explain the delay of four months in placing the plan before the AA for approval, after the CoC had approved the plan (5) Plan violated regulation 38 of the CIRP Regulations, 2016 by not prioritizing OC payments over FCs and did not ensure compliance of the plan before submitting it to CoC as required under section 30(2) of the Code. (6) SRA has instituted vexatious and frivolous litigations before the AA and NCLAT, which led to delay in the implementation of the resolution plan under the garb of pendency of appeal before the Courts. Further, the SC castigated the CoC for making a volte- face by accepting Rs. 19,350 crores from the SRA at a very belated stage, when they initially implicated the SRA for demonstrating ill- intent and malafides to mislead and misuse the process of Court in order to delay the implementation of the plan. In terms of sub-section (1) of section 33, and in exercise of the jurisdiction conferred under Article 142 of the Constitution of India, the AA was directed to initiate the liquidation proceedings of CD. SRA filed an SLP seeking leave of SC to file a review petition before the expiry of limitation against SC’s judgment in Civil Appeal No. 1808 of 2020. SC has ordered a status quo on the liquidation of the CD to avoid future legal complications. National Spot Exchange Limited Vs. Union of India & Ors.

SC’s judgment in Civil Appeal No. 1808 of 2020. SC has ordered a status quo on the liquidation of the CD to avoid future legal complications. National Spot Exchange Limited Vs. Union of India & Ors. [Writ Petition (Civil) No. 995 of 2019] National Spot Exchange Limited (“NSEL/Decree Holder”) is an electronic commodity trading platform where trading happened in paired contracts, with investors, buying a spot contract and selling a futures for the same commodity, through brokers by following settlement methodology of pay-in obligations to exchange. The NSEL had launched contracts for buying and selling of commodities with different settlement periods, wherein the delivery of the commodity and payment of price (i.e., settlement of transaction) was to be affected by the buying and the selling member as the case may be. Thereafter, the funds “pay – in” obligation would be intimated to the NSEL members whose clients purchased the commodities, and the funds “pay – out” obligation would be intimated to the NSEL members whose clients sold the commodities. Based on the intimation from the exchange, the clients would have to fulfil their respective obligations through the NSEL members, through whom they have traded on the NSEL. In 2013, the NSEL encountered a crisis when 13,000 traders alleged that 24 trading members had defrauded them of an aggregate amount of 5,600 crore by fabricating documents and falsifying records pertaining to warehouse receipts and contracts, which were not backed by any underlying physical commodities.

em of an aggregate amount of 5,600 crore by fabricating documents and falsifying records pertaining to warehouse receipts and contracts, which were not backed by any underlying physical commodities. When the investors sought delivery of commodities corresponding to their investments, the borrowers failed to supply the same, as the actual stock of goods available in the warehouses was significantly deficient. Consequently, the ED attached several assets of a few corporates under the PMLA while the Government of Maharashtra acted upon an F.I.R filed against the 24 defaulters and attached properties of the trading members, directors and sister concerns of NSEL under the Maharashtra Protection of Interest of Depositors (in Financial Establishments) Act, 1999 (MPID Act). On a petition filed by NSEL, SC, vide order dated 04.05.2022, constituted a High-Powered Committee (S.C. Committee) to execute decrees/awards passed by different Courts across the country and consolidate proceedings for hearing before it. During the course of the proceedings, the following issues came up for consideration before the S.C. Committee (1) Do secured creditors have priority over assets attached under PMLA and MPID Act by virtue of SARFAESI Act, 2002 and RDB Act, 1993? (2) Are properties of judgment debtors and garnishees attached under the MPID Act available for decree execution despite the commencement of moratorium under section 14 of the Code? The S.C.

t, 1993? (2) Are properties of judgment debtors and garnishees attached under the MPID Act available for decree execution despite the commencement of moratorium under section 14 of the Code? The S.C. Committee held that since the attached properties are in nature of proceeds of crime under the PMLA Act and the MPID Act, the secured creditors cannot claim priority over the assets of the judgment debtors. Moreover, the S.C. Committee

23 held that properties which were attached under section 4 of the MPID Act prior to imposition of the moratorium of the judgement debtor or Garnishee (PG) under section 14 or section 96 of the Code, such properties were not liable to be made part of insolvency resolution process of the CD or PG, and could be available to the S.C. Committee for recovery of money. However, as regards the properties which were sought to be attached after the commencement of moratorium, which were not yet attached under section 4 of the MPID Act, the S.C. Committee concluded that the decree holder would be entitled to pursue its claim as a FC in accordance with the Code. The SC upheld the orders of the S.C. Committee on the ground that the secured creditors have no priority over assets attached under the MPID Act, since the assets of NSEL do not qualify as “debt” under section 26E of the SARFAESI Act. Moreover, the properties attached under MPID Act before the moratorium imposed under the Code vests with the competent authority established under the MPID Act.

under section 26E of the SARFAESI Act. Moreover, the properties attached under MPID Act before the moratorium imposed under the Code vests with the competent authority established under the MPID Act. SC concluded that, irrespective of the enactment of the SARFAESI Act and the RDB Act in the Central List (List-I) of the Indian Constitution and having been enacted by Parliament, they could not be permitted to override the MPID Act, since it is validly enacted under the State List (List - II) and shall amount to denuding the State of its legislative power to enact and enforce legislation under Article 246 of the Constitution. In addition to it, SC concluded that the overriding effect of section 238 of the Code shall not apply, since there is no repugnancy between the Code and the MPID Act as required under Article 254 of the Constitution. SC, while upholding the decision of the S.C. Committee, held that properties of the judgment debtors and garnishees attached under the provisions of the MPID Act, would be available for the execution of the decrees against the judgment debtors by the S.C. Committee, despite the provision of moratorium under section 14 of the Code. Perfect Infraengineers Limited Vs. Technology Development Board [SLP (C) No(s).

s against the judgment debtors by the S.C. Committee, despite the provision of moratorium under section 14 of the Code. Perfect Infraengineers Limited Vs. Technology Development Board [SLP (C) No(s). 13015 of 2025] Issue for consideration before Hon’ble Supreme Court was whether admission order passed by AA against a CD can be directly challenged before it under Article 136 of the Constitution, which provides discretionary power to SC to grant special leave to appeal against any judgment, decree, determination, sentence, or order of any court or tribunal in India. SC while dismissing the appeal filed by the CD held that the grievances regarding the admission of a section 7 petition should be addressed through an appeal to the NCLAT, not through a special leave petition under Article 136 of the Constitution as the bar of limitation cannot be obviated or circumvented by taking recourse of proceedings under Article 136 of the Constitution when a statutory appeal is available. F.2 National Company Law Appellate Tribunal Busy Bee Airways Private Limited Vs. Dinkar T. Venkatasubramanian & Ors. [CA (AT) (Ins) No.124,175 & 244 of 2025] Go Airlines (India) Private, (CD), a low-cost airline, filed a petition for CIRP under section 10 of the Code, which was approved by the AA. A resolution plan filed by Busy Bee Airways Private Limited (PRA) was rejected by the CoC since it did not meet the eligibility criteria to submit a resolution plan for the CD.

as approved by the AA. A resolution plan filed by Busy Bee Airways Private Limited (PRA) was rejected by the CoC since it did not meet the eligibility criteria to submit a resolution plan for the CD. Meanwhile, the aircraft lessors approached Delhi HC seeking deregistration of the aircrafts lying with the CD and permission to export them, which was approved by the HC. As no viable resolution plans for the CD were available, AA ordered liquidation of CD based on the approval of CoC. In an appeal filed by the PRA, the issues before the NCLAT were as follows: (1) Was the CoC’s decision to liquidate Go Airlines under section 33(2) IBC valid? (2) Can the CoC authorize the liquidator to sell the CD’s assets on a standalone basis, in a slump sale, or in parcels without prioritizing a going concern sale? (3) Is there an opportunity for a compromise or arrangement under section 230 of the Companies Act, 2013, during liquidation? The NCLAT while disposing the appeal, upheld the liquidation of the CD as the powers given to the CoC to take decision for liquidation is very wide, which can be exercised immediately after constitution of the CoC in consonance with section 33 (2) of the Code. It observed that the CoC is vested with the authority to direct the liquidator to sell the CD’s assets on a standalone basis, in a slump sale, or in parcels without prioritizing a going concern sale.

It observed that the CoC is vested with the authority to direct the liquidator to sell the CD’s assets on a standalone basis, in a slump sale, or in parcels without prioritizing a going concern sale. NCLAT further observed no infirmity in the order of liquidation of, since the CoC had explored the option of sale of the CD as a going concern under regulation 32(e) of Liquidation Regulation and sale of the business of the CD as a going concern under regulation 39 of the CIRP Regulations, 2016, before directing the CD into liquidation. Lastly it held that the PRA has the liberty to seek compromise or arrangement under section 230 of the Companies Act, 2013 or regulation 2B of the Liquidation Regulations within the period of 90 days from order of liquidation. Max Publicity & Communication Private Limited Vs. Enviro Home Solutions Private Limited [CA (AT) (Ins) No. 456 of 2025] Suumaya Group (third party) had approached Max Publicity & Communication Private Limited (CD) to coordinate between Veda (third party) and vendors for supply of essential commodities to Veda. Veda supplied those essential commodities to the Government of India as an initiative under their Corporate Social Responsibility (CSR).

arty) and vendors for supply of essential commodities to Veda. Veda supplied those essential commodities to the Government of India as an initiative under their Corporate Social Responsibility (CSR). The CD issued a letter of intent and purchase order to Enviro Home Solutions Private Ltd (vendor and OC) for supplying raw materials to the CD, who in turn will deliver it to Veda. The CD had paid a partial amount to the OC for the amount due. Later, the CD alleged fraud by the OC by fabricating the lorry receipts and while reversing the payments pending, filed a criminal complaint against the OC before the Commissioner of Police, Gurgaon. Consequently, the OC filed a section 9 petition under the Code to initiate CIRP against the CD. The AA, vide order dated 21.01.2025, found no proof of delivery by the OC to the CD and dismissed the petition filed by the OC. AA observed that a fraud as being committed by the CD and directed the Income Tax Department, EOW and SFIO to conduct investigation into the entire transactions relating to CSR obligations of Veda. On appeal filed by the CD, the issues before the NCLAT were as follows (1) whether AA had the jurisdiction to direct statutory authorities for investigation while dismissing the insolvency petition. (2) whether the CD’s actions warranted investigation for alleged fraud in CSR transactions with Veda and Suumaya. The NCLAT observed that the AA, while exercising jurisdiction under section 9 of the IBC also exercised its jurisdiction under the Companies Act, 2013.

raud in CSR transactions with Veda and Suumaya. The NCLAT observed that the AA, while exercising jurisdiction under section 9 of the IBC also exercised its jurisdiction under the Companies Act, 2013. It noted that the AA, in exercise of powers under section 213 of the Companies Act, 2013, can direct for investigation provided that a reasonable opportunity is afforded to the parties concerned. NCLAT while disposing the appeal held that the reference under section 212 to carry out any investigation of a company’s affairs by SFIO can be made only in accordance with the statutory provisions of Section 212 of the Companies Act

24 and the AA, while exercising jurisdiction under the IBC it cannot issue any direction to SFIO for carrying out investigation. Asha Basantilal Surana Vs. State Bank of India & Ors. [I.A. No. 334 of 2025 in CA (AT) (Ins) No. 84 of 2025] M/s. Surana Metacast (India) Private Private (CD) availed credit facilities from State Bank of India (FC), which were secured by a personal guarantee of Mrs. Asha Basantilal Surana (PG). As the CD’s loan was declared as NPA, the FC served a demand notice under section 13(2) of the SARFAESI Act, 2002, on the CD and on the PG. Subsequently, FC secured an order under section 14 of the SARFAESI Act and issued a sale notice to take physical possession of secured assets of the CD under the provisions of the SARFAESI Act. Meanwhile, CIRP was initiated by the FC against the CD.

of the SARFAESI Act and issued a sale notice to take physical possession of secured assets of the CD under the provisions of the SARFAESI Act. Meanwhile, CIRP was initiated by the FC against the CD. Thereafter, the PG filed an application under section 94(1) of the IBC for initiating personal insolvency, which the AA rejected on the ground that it was premature as no specific notice was issued to invoke the guarantee. In appeal filed by the PG, the issue before the NCLAT was whether the notice issued by the FC to PG under section 13(2) notice provided sufficient cause for the PG to file an application for personal insolvency under section 94(1) of the Code. The NCLAT, while allowing the appeal, observed that Clause 7 of the Guarantee Agreement requires that the Guarantors shall forthwith on demand made by the Bank, deposit such sum or security as the Bank may specify for the due fulfilment of their obligations. The said clause does not require any particular mode and manner of the demand notice. As such demand notice issued against the PG demanding them to discharge its liabilities, the guarantee stands invoked. NCLAT held that its judgment dated 05.01.2023 in Amanjyot Singh Vs. Navneet Kumar Jain RP (Company Appeal (AT) (Insolvency) No.961 of 2022) cannot be read to mean that this tribunal had held that the personal guarantee could never be invoked by notice under section 13(2). The decision in Amanjyot was with reference to the specific facts of that case.

d to mean that this tribunal had held that the personal guarantee could never be invoked by notice under section 13(2). The decision in Amanjyot was with reference to the specific facts of that case. It further held that for finding out as to whether a notice under section 13(2) invoked the personal guarantee to discharge PG’s liabilities or not, the letters and words of the notice have to be looked into. Lotus 300 Apartment Owners’ Association Vs. IndusInd Bank Limited & Ors. [CA(AT) (Ins.) No. 1471 of 2022] AA passed admission orders against Hacienda Projects Private Limited, a developer of the real estate project, under section 7 on an application filed by IndusInd Bank (FC). The said admission order was challenged by the Lotus 300 Apartment Owners’ Association (Association), representing all 330 flats buyers in the project inter alia on the ground that the project is near completion. Issues for consideration before NCLAT was whether the AA’s order admitting CD to CIRP could be set aside, allowing the association to complete the project while keeping the CIRP in abeyance. NCLAT observed that during the CIRP stage, the RP has to perform his role in accordance with provisions of the Code and Regulations made thereunder. In terms of provisions of the Code and Regulations thereunder, the CoC shall constitute primarily of all the homebuyers as a class who are stated to be predominant with 98% voting in the composition of CoC, with a FC having remaining voting share.

ns thereunder, the CoC shall constitute primarily of all the homebuyers as a class who are stated to be predominant with 98% voting in the composition of CoC, with a FC having remaining voting share. It is for CoC to decide the future course of action and RP is supposed to act under the advice and directions to the CoC. Considering the fact that 99% of the project has been completed, the NCLAT directed that the remaining work shall be completed by the CoC through RP. Wakai Hospitality Private Limited Vs. Palak Desai & Anr. [CA (AT) (Ins) No. 524 of 2024] The appeal was filed by a licensee occupying a commercial property owned by the CD undergoing insolvency under the Code. The licensee challenged the order of AA which had directed it to vacate the premises and pay outstanding license fees to the CD. The appellant brought to the notice of AA that it had entered in to Leave and License Agreement (LLA) with the former management of CD prior to the insolvency commencement date, on the condition of adjusting significant renovation costs against future license fees. The RP of the CD, upon noticing the non-payment of licensee, had terminated the LLA and sought possession of the property. The issues before the NCLAT were (i) whether the AA has jurisdiction to adjudicate upon eviction and recovery of rent, which is typically a matter for civil courts; and (ii) whether an RP has the authority to terminate a contract during the moratorium period under section 14 of the IBC.

eviction and recovery of rent, which is typically a matter for civil courts; and (ii) whether an RP has the authority to terminate a contract during the moratorium period under section 14 of the IBC. NCLAT, while dismissing the appeal, held that the AA possesses the necessary jurisdiction to decide on matters pertaining to the assets of the CD. It ruled that an asset owned by the CD, even if in possession of a third party, must be handed over to the RP to ensure maximization of its value. On the second issue, the NCLAT clarified that the moratorium under section 14 is a protective shield for the CD against third-party actions and cannot be used as a sword by a defaulting third party to continue its breach of contract. The RP has a duty to protect the CD’s assets, which includes terminating agreements that are detrimental to the insolvency estate. Vinod Singh Vs. Chandra Prakash Jain & Ors. [CA (AT) (Ins) Nos. 800 & 801 of 2025] The shareholders of the corporate person (CP) passed a resolution to replace the existing liquidator with a new one in a voluntary liquidation process. The outgoing liquidator challenged this decision through an IA before the AA who had directed the parties to maintain “status quo” regarding the position of the liquidator, effectively halting the replacement. Subsequently, the AA passed another order de- reserving its final order on the matter. The Director of CP challenged both these orders before the NCLAT.

quidator, effectively halting the replacement. Subsequently, the AA passed another order de- reserving its final order on the matter. The Director of CP challenged both these orders before the NCLAT. The issue before the NCLAT was whether the AA has the jurisdiction to interfere with the commercial decision of a corporate person to replace its liquidator during a voluntary liquidation process under section 59 of the IBC, and consequently, whether its order to maintain “status quo” was legally tenable. The NCLAT, while allowing the appeal, held that the process for replacement of a liquidator in a voluntary liquidation of a solvent company is governed by a regime entirely different from a liquidation following a CIRP. It clarified that the power to appoint and replace a liquidator “wherever required” rests exclusively with the corporate person by way of passing a resolution, and no approval from the AA is necessary and there is no need for the Director and Shareholder of the CD to communicate any reason for removal of a liquidator. The NCLAT ruled that the AA’s statusquo order was a “transgression of jurisdiction” and was passed in violation of the statutory framework of the IBC. The NCLAT vacated the statusquo order and directed the outgoing liquidator to hand over all records as required by the regulations to the new liquidator for proceeding with the process.

of the IBC. The NCLAT vacated the statusquo order and directed the outgoing liquidator to hand over all records as required by the regulations to the new liquidator for proceeding with the process.

25 F.3 National Company Law Tribunal Encore Asset Reconstruction Company Private Limited Vs. M/ s New Tech Imports Private Limited [C.P. (IB) No. 823(ND)/2022] Owing to the repeated defaults by New Tech Imports Private Limited (CD) in repayment of the outstanding dues, the FC formally declared the account of the CD as Non-Performing Asset (NPA) and sent a statutory recall notice under the section 13(2) of the SARFAESI Act, 2002 to the CD and the Guarantors. During the course of proceedings before DRT, the FC filed a petition against the CD to initiate CIRP under section 7 of the Code. DRT, vide order dated 16.11.2024, held that classification of the CD’s account as NPA was illegal since the date of classification of CD’s account as NPA is inconsistent with FC’s own communication and the FC failed to comply with the RBI guidelines while classifying the account of the CD as NPA. The issues before the AA were as follows (1) whether the classification of the account of the CD as NPA can be considered as ‘default’ for the purpose of proceedings under the Code, (2) whether an order passed by the DRT in setting aside the classification of the account as a NPA, has any bearing on the present insolvency proceedings under the Code.

f proceedings under the Code, (2) whether an order passed by the DRT in setting aside the classification of the account as a NPA, has any bearing on the present insolvency proceedings under the Code. AA, while disposing the application held that while the classification of an account as NPA may be indicative of financial distress, mere classification of an account as NPA does not ipso facto translate as ‘default’ under section 7 of the Code, since the Code mandates that the existence of a financial debt and its non-payment must be independently established by the FC. While examining the overriding effect of the Code over the SARFAESI Act under which the DRT exercises jurisdiction, the AA concluded that an order of the DRT setting aside NPA classification does not negate the existence of financial debt or the occurrence of default. AA, while initiating CIRP of the CD, held that the DRT’s jurisdiction is limited to determining whether the lender followed the correct procedure under SARFAESI, and it does not extend to making findings on default under the Code, which is the sole domain of the AA. Consortium of Karishma Jain, Jupiter City Developers (I) Limited, and Adwaita Navigations Private Limited, Successful Resolution Applicant of XL Energy Limited Vs. National Stock Exchange of India Limited & Ors [I.A (IBC) No. 1726 of 2024 in C.P (IB) No.16/7/HDB/2023] AA, vide order dated 27.03.2023, initiated CIRP against XL Energy Limited (CD). The resolution plan, as submitted by the consortium of Ms.

rs [I.A (IBC) No. 1726 of 2024 in C.P (IB) No.16/7/HDB/2023] AA, vide order dated 27.03.2023, initiated CIRP against XL Energy Limited (CD). The resolution plan, as submitted by the consortium of Ms. Karishma Jain (SRA), provided for relisting of CD’s equity shares, since they were compulsorily delisted from the stock exchanges for a period of ten years due to violations under the SEBI (Delisting of Equity Shares) Regulations, 2009. As proposed and approved by the AA, the SRA requested the NSE, BSE, CDSL, and NSDL to relist the CD’s equity shares. However, the NSE rejected the relisting of CD’s equity shares under regulation 40(1)(b) of SEBI Delisting Regulations, 2021. Moreover, CDSL and NSDL did not activate the CD’s credentials required for implementation of the resolution plan, which hindered the allocation of new shares and updation of the new shareholding structure. The issues before the AA were as follows: - (1) whether the resolution plan binds NSEL to relist CD’s equity shares? (2) whether prior offences of the erstwhile management of the CD are extinguished post-approval of the plan. (3) whether IBC overrides SEBI’s Delisting Regulations? AA held that the approved resolution plan binds all stakeholders, including NSE and BSE, under section 31(1) of the Code and neither can raise any demand, condition, or requirement that is inconsistent with or beyond the scope of the said plan. Moreover, AA upheld its jurisdiction to direct relisting or on matters governed by SEBI Regulations.

demand, condition, or requirement that is inconsistent with or beyond the scope of the said plan. Moreover, AA upheld its jurisdiction to direct relisting or on matters governed by SEBI Regulations. AA concluded that given the overriding effect of section 238 of the Code, all past dues, offences and liabilities of the CD stand extinguished by virtue of section 32 A of the Code and accordingly, allowed the relisting of CD’s equity shares. Goyal Tea Agencies Private Limited Vs. Shakti Bhog Snacks Limited. [IA-3695-2023 in CP (IB) No. 1713 of 2019] An application under section 54 of Code was filed by RP of CD- Shakti Bhog Snacks Limited (CD) seeking dissolution of CD as there was no scope for revival of CD. Apart from office of the CD which was found sealed by the ED and a single bank account with a negligible balance of Rs. 3701.81, there was no other asset. ED, which was made party at later stage, opposed such application for dissolution on the grounds that CD is a group company of Shakti Bhog Foods Limited (SBFL), which was under prosecution for default of Rs. 3,269 crore loan and large-scale money laundering. According to the ED, SBSL had actively assisted SBFL in laundering proceeds of crime by issuing bogus invoices, transferring funds to shell companies, and layering illicit funds to project them as legitimate revenue. Dissolution of CD would terminate the legal existence of SBSL, which would frustrate the ongoing criminal prosecution under PMLA.

es, and layering illicit funds to project them as legitimate revenue. Dissolution of CD would terminate the legal existence of SBSL, which would frustrate the ongoing criminal prosecution under PMLA. Considering the nature of proceedings, AA observed that that IBC cannot be used to override the PMLA or frustrate lawful investigations and attachments made under it. AA while dismissing section 54 application observed that “It is not the quantum but the character of the proceedings that is determinative. The IBC cannot be used as a mechanism to frustrate or sidestep the legitimate process of law under the PMLA.” G. Building Ecosystem G.1 IP Workshops IBBI has been organising workshops for registered IPs with the aim to deliver specialised and deep level learning through a classroom, non-residential mode. It organised several Workshops for the IPs during the quarter through online mode. The details of the workshops conducted till June 30, 2025, is given in Table 34. Table 34: Capacity Building Programmes for IPs till June 30, 2025 Year / Period Workshops Webinars Roundtables Trainings Total 2016 - 17 1

8 9 2017 - 18 6

44 50 2018 - 19 7

22 29 2019 - 20 15 1 22

38 2020 - 21 9 29 18 2 58 2021 - 22 14 21 12 3 50 2022 - 23 18 6 6 6 36 2023 - 24 29 17 5 1 52 2024 - 25 22 3 2 1 28 Apr-Jun, 2025 3

3 Total 124 77 139 13 353

9 7

22 29 2019 - 20 15 1 22

38 2020 - 21 9 29 18 2 58 2021 - 22 14 21 12 3 50 2022 - 23 18 6 6 6 36 2023 - 24 29 17 5 1 52 2024 - 25 22 3 2 1 28 Apr-Jun, 2025 3

3 Total 124 77 139 13 353

26 Online IP Workshop The IBBI organised a Workshop for IPs on June 16, 2025 through online mode focusing on building and strengthening capacity of IPs and to make them aware of their responsibilities under the Code. The Workshop was inaugurated by Mr. Ravinder Maini, ED, IBBI by delivery of opening remarks. The expert faculty for the sessions included Ms. Namisha Singh, Manager, IBBI and CA Vikram Kumar, IP. Online IP Workshop, on June 16, 2025 IP Workshop in Chandigarh and Kochi The IBBI organised a workshop for IPs in Chandigarh and Kochi on April 30, 2025, and June 20, 2025 respectively. The workshops were inaugurated by Mr. Ravinder Maini, ED, IBBI by delivery of opening remarks. The expert faculty for the workshops included Mr. Keshav Kumar Giridhari, DGM, IBBI, Ms. Namisha Singh, Manager, IBBI, Mr. Sandeep Goel, IP and CMA Mr. Sankar P. Panicker, IP. IP Workshop, Chandigarh, April 30, 2025 IP Workshop, Kochi, June 20, 2025 G.2 Advocacy and Awareness Capacity Building Workshop for the Officers of Income Tax The Insolvency and Bankruptcy Board of India (IBBI) conducted a comprehensive capacity-building workshop for the officers stationed at CCIT, New Delhi, on 25th June 2025.

r the Officers of Income Tax The Insolvency and Bankruptcy Board of India (IBBI) conducted a comprehensive capacity-building workshop for the officers stationed at CCIT, New Delhi, on 25th June 2025. The workshop aimed to enhance the professional expertise, operational efficiency, and domain-specific knowledge of the participants, fostering a deeper understanding of insolvency and bankruptcy processes. This initiative reflects IBBI’s commitment to promoting excellence and continuous learning among its stakeholders. Capacity Building Workshop at CCIT, New Delhi, June 25, 2025 G.3 Other Programmes Senior officers of IBBI participated as guests and faculty in several programmes during the quarter, the details of which are presented in Table 35. Table 35: Participation of Senior Officers in Programmes Sl. Date Organiser Subject Participation No. 1 10.05.2025 Confederation of CII Insolvency & Mr. Jithesh John, Indian Industry Bankruptcy Code Executive Director, Conclave, ITC Sonar, IBBI Kolkata 2 25.05.2025 IPA ICMAI Session on Mr. Shiv Anant Opportunities for Shanker, CGM CMAs in the Evolving IBC Ecosphere in National CMA Convention

de Executive Director, Conclave, ITC Sonar, IBBI Kolkata 2 25.05.2025 IPA ICMAI Session on Mr. Shiv Anant Opportunities for Shanker, CGM CMAs in the Evolving IBC Ecosphere in National CMA Convention

27 List of Abbreviations AA Adjudicating Authority AFA Authorisation for Assignment AR Authorised Representative BIFR Board for Industrial and Financial Reconstruction BSE Bombay Stock Exchange BT/BTs Bankruptcy Trustee/Trustees CA Chartered Accountants CD Corporate Debtor CDSL Central Depository Services (India) Limited CEO Chief Executive Officer CIRP Corporate Insolvency Resolution Process CIRP Regulations IBBI (Insolvency Resolution Process for Corporate Persons) Regulations, 2016 CMA Cost and Management Accountants CoC Committee of Creditors CPE Continuing Professional Education CPGRAMS Centralised Public Grievance Redress and Monitoring System DRP Debt Realignment Plan DRT Debt Recovery Tribunal CS Company Secretary CSR Corporate Social Responsibility ED Executive Director ED Enforcement Directorate EOW Economic Offences Wing FC/FCs Financial Creditor / Creditors FIR First Information Report FiSP/FiSPs Financial Service Provider/ Financial Service Providers HC High Court IBBI / Board Insolvency and Bankruptcy Board of India IBC / Code Insolvency and Bankruptcy Code, 2016 ICAI Institute of Chartered Accountants of India ICAI RVO ICAI Registered Valuers Organisation ICD Insolvency Commencement Date ICLS Indian Corporate Law Service ICMAI Institute of Cost and Management Accountants of India ICSI Institute of Company Secretaries of India ICSI IIP

ers Organisation ICD Insolvency Commencement Date ICLS Indian Corporate Law Service ICMAI Institute of Cost and Management Accountants of India ICSI Institute of Company Secretaries of India ICSI IIP ICSI Institute of Insolvency Professionals IIIP ICAI Indian Institute of Insolvency Professionals of ICAI IIVC Indonesia International Valuation Conference IIM Indian Institute of Management IP/IPs Insolvency Professional/ Professionals IPA/IPAs Insolvency Professional Agency/ Agencies IPA ICAI Insolvency Professional Agency of Institute of Cost Accountants of India IPE/IPEs Insolvency Professional Entity/Entities IRP/IRPs Interim Resolution Professional/Professionals IVSC International Valuation Standards Council. ITD Income Tax Department IU/IUs Information Utility/Utilities LCD Liquidation Commencement Date Liquidation Regulations IBBI (Liquidation Process) Regulations, 2016 LLA Leave and License Agreement MCA Ministry of Corporate Affairs MD Managing Director MPID Act Maharashtra Protection of Interest of Depositors (in Financial Establishments) Act MSME Micro, Small and Medium Enterprise NCLAT National Company Law Appellate Tribunal NCLT National Company Law Tribunal NeSL National e- Governance Services Limited NI Act The Negotiable Instruments Act NITI Aayog National Institution for Transforming India NPA Non-Performing Asset NSDL National Securities Depository Limited NSE National Stock Exchange of India Limited NSEL National Spot Exchange Limited OC/OCs Operational Creditor/ Creditors Panel Guidelines Insolvency Professionals to act as Interim Resolution

Limited NSE National Stock Exchange of India Limited NSEL National Spot Exchange Limited OC/OCs Operational Creditor/ Creditors Panel Guidelines Insolvency Professionals to act as Interim Resolution Professionals, Liquidators, Resolution Professionals and Bankruptcy Trustees (Recommendation) Guidelines, 2024 PAO Provisional attachment order PG/PGs Personal Guarantor/Guarantors PGIP Post Graduate Insolvency Programme PIRP Personal Insolvency Resolution Process PMLA The Prevention of Money Laundering Act, 2002 PMO Prime Minister’s Office PPIRP Pre-Packaged Insolvency Resolution Process PRA Prospective Resolution Applicant RBI Reserve Bank of India RDB Act, 1993 The Recovery of Debts and Bankruptcy Act, 1993 RERA Real Estate Regulatory Authority RoD Record of Default RP/RPs Resolution Professional/Professionals RV/RVs Registered Valuer/Registered Valuers RVO/RVOs Registered Valuer Organisation/Registered Valuer Organisations SARFAESI Act Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002 SBFL Shakti Bhog Foods Limited SBSL Shakti Bhog Snacks Limited SC Supreme Court of India SCN Show Cause Notice SCRA Act Securities Contracts (Regulation) Act, 1956 SEBI Securities and Exchange Board of India SFIO Serious Fraud Investigation Office SLP Special Leave Petition SRA Successful Resolution Applicant Valuation Rules The Companies (Registered Valuers and Valuation) Rules, 2017 WP Writ Petition WTM Whole Time Member

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