Case of Satyanarayan Gupta vs Shivangan Realestate Pvt Ltd, NCLAT Delhi Judgement Dated 12th September 2025. The appellate tribunal ruled that section 89 non-disclosure attracts penalties but is not grounds for oppression claims, and that private MoUs cannot enforce disguised loan/share issues in company petitions. Thus, reinforcing that Section 89 non-compliance is a regulatory violation, not a trigger for oppression remedies.