Case of Patanjali Foods Limited, vs AC CGST, HC Delhi Judgement Dated 11th December 2025. HC held that for the purposes of Section 31(1) of the IBC, the effective date of approval of the Resolution Plan is 4 September 2019, when the NCLT granted final approval, and not any earlier or later date reflected in website extracts or interim orders. It quashed all GST demands relating to periods prior, reiterating that a successful resolution applicant takes over the corporate debtor on a “clean slate”.