ORDER : 1. These three writ petitions involve identical questions of facts and law and hence, are being decided by this common order. 2. Mr. Mahaveer Bishnoi, learned Additional Advocate General has put in appearance on behalf of the respondents. 3. The Commercial Taxes Officer, Works and Leasing Taxes, Bhilwara passed the assessment orders dated 21.03.2017, 05.03.2018 and 28.03.2019 for the assessment years 2014-2015, 2015-2016 and 2016-2017 respectively by which the respondents held the petitioner-company liable to pay the amount of Rs.10,06,266/-, 43,073/- and 1,75,55,035/- on account of non-payment of the entry tax for the goods purchased by the petitioner from outside the State of Rajasthan. In furtherance of the aforesaid assessment orders, notice for payment of demand were also issued. 4. The respondent-Department, in order to recover the aforesaid due amount from the petitioner-company, issued a notice/communication dated 17.07.2019 to the Manager SBI, Agoocha, District Bhilwara (respondent No.2), invoking special mode of recovery under Section 50 of RVAT, 2003 read with Section 9 CST Act whereby it had directed the respondent No.2 to recover the outstanding amount of Rs.1,86,04,374/- from the Bank account of the petitioner-company. 5. The petitioner-company has filed the present writ petitions challenging the action of respondents, directing the respondent No.2 to recover the outstanding amount from its Bank account. 6. Mr. Vinay Kothari, learned counsel for the petitioner-company submits that the petitioner is not raising its grievance against the assessment orders which were passed by the respondents in these writ petitions, as it has availed appropriate legal remedy available to it under the law against the same. The petitioner is only challenging the impugned notice/communication dated 17.07.2019 sent to the respondent No.2 - Bank. 7. Learned counsel for the petitioner further submits that During the pendency of these writ petitions, the petitioner-company became sick. Accordingly, Corporate Insolvency Resolution Process (CIRP) was initiated under the Insolvency and Bankruptcy Code, 2016. 8. It was also submitted that the National Company Law Tribunal (NCLT), Kolkata Bench, Kolkata passed a final order dated 19.12.2023 under Section 31(1) of the IBC accepting the resolution plan, duly approved by the Committee of Creditors (CoC). Accordingly, Corporate Insolvency Resolution Process (CIRP) was initiated under the Insolvency and Bankruptcy Code, 2016. 8. It was also submitted that the National Company Law Tribunal (NCLT), Kolkata Bench, Kolkata passed a final order dated 19.12.2023 under Section 31(1) of the IBC accepting the resolution plan, duly approved by the Committee of Creditors (CoC). The order of NCLT mandates that the CIRP shall be binding on the Corporate Debtors, McNally Bharat Engineering Company Ltd., its employees, members, creditors, guarantors including the Central Government, any State Government or any local authority to whom a debt in respect of payment of dues arising under any law for the time being in force, such authorities to whom statutory dues are owed and other stakeholders involved in the Resolution Plan. 9. It was emphasized by the learned counsel for the petitioner that approval of the Resolution Plan by the NCLT with effect from 19.12.2023 waived and/or extinguished and/or settled all tax dues of whatever nature of Central, State and local authorities pertaining to the period prior to the effective date. It was contended that the assessment orders pertains to the years 2014-2015, 2015-2016 and 2016-2017 and for the recovery of the amount in pursuance of the same, communication was issued to the Bank in the year 2019, all liabilities of the petitioner which became a sick unit and went for CIRP stood extinguished on account of the acceptance of the Resolution Plan w.e.f. 19.12.2023 (date of order passed by NCLT). As a consequence, The impugned communication/notice dated 17.07.2019 (Annex.5) issued in pursuance of the assessment orders dated 21.03.2017, 05.03.2018 and 28.03.2019 for the assessment years 2014-2015, 2015-2016 and 2016-2017 respectively are no more legally tenable. 10. Learned counsel for the petitioner placed reliance on the Division Bench judgment of this court in the case of Ultra Tech Nathdwara Cement Ltd. Vs. Union of India & Ors. [MANU/RH/0283/2020] and the judgment dated 18.01.2023, passed in the case of M/S EMC Ltd. Vs. State of Rajasthan & Ors. (D.B. Civil Writ Petition No.6048/2020). 11. He urged that in light of the judgment in the case of Ultra Tech Nathdwara Cement Ltd. (supra), all claims of the Corporate Creditors and Statutory Creditors stood extinguished upon approval of the Resolution Plan by the NCLT. He, thus, urged that the impugned communication/notice dated 17.07.2019 deserves to be quashed and the writ petitions be allowed with exemplary cost. 12. Mr. He, thus, urged that the impugned communication/notice dated 17.07.2019 deserves to be quashed and the writ petitions be allowed with exemplary cost. 12. Mr. Mahaveer Bishnoi, learned Additional Advocate General appearing for the respondents, is not in a position to dispute the fact that pursuant to approval of the Resolution Plan by the NCLT, all demands of the Department for the period prior to the effective date stood extinguished. It is also not in dispute that the petitioner-company became sick and undergone the Corporate Insolvency Resolution Process (CIRP), which attained finality after receiving the seal of approval from the NCLT, Kolkata vide order dated 19.12.2023. It is also an admitted position that the demands raised by effect of the impugned assessment orders and impugned communication/notice dated 17.07.2019 which pertain to the Assessment Years 2014-2015, 2015-2016 and 2016-2017, which are much earlier to the date of approval of the Resolution Plan by the NCLT. 13. Learned Additional Advocate General has referred the judgment of the Hon’ble Supreme Court rendered in the case of State Tax Officer Vs. Rainbow Papers Ltd. (Civil Appeal No.1661/2020) : (2023) 9 SCC 545 and the judgment rendered in the case of Paschimanchal Vidyut Vitran Nigam Ltd. Vs. Raman Ispat Private Ltd. & Ors. (Civil Appeal No.7976/2019) : (2023) 10 SCC 60 . 14. Learned Additional Advocate General submits that the State Government was exempted by virtue of the aforesaid precedent law. However, he could not refute that as per the precedent law itself, it was in pre 2018 position, whereas the 2019 amendment included Section 31 itself whereby, the approved Resolution Plan has been made binding on the Corporate Debtors -McNally Bharat Engineering Company Ltd., its employees, members, creditors, guarantors including the Central Government, any State Government or any local authority and other stakeholders involved in the Resolution Plan, to whom a debt in respect of payment of dues arising under any law for the time being in force, is owed. 15. 15. Section 31 of the Insolvency and Bankruptcy Code, 2016 reproduced hereunder:- “31.Approval of resolution plan.- (1) If the Adjudicating Authority is satisfied that the resolution plan as approved by the committee of creditors under sub-section (4) of Section 30 meets the requirements as referred to in sub-section (2) of Section 30, it shall by order approve the resolution plan which shall be binding on the corporate debtor and its employees, members, creditors, including the Central Government, any State Government or any local authority to whom a debt in respect of the payment of dues arising under any law for the time being in force, such as authorities to whom statutory dues are owed, guarantors and other stakeholders involved in the resolution plan: Provided that the adjudicating authority shall, before passing an order for approval of resolution plan under this sub-section, satisfy that the resolution plan has provisions for its effective implementation. (2) Where the adjudicating authority is satisfied that the resolution plan does not confirm to the requirements referred to in sub-section (1), it may, by an order, reject the resolution plan. (3) After the order of approval under sub-section (1),— (a) the moratorium order passed by the adjudicating authority under Section 14 shall cease to have effect; and (b) the resolution professional shall forward all records relating to the conduct of the corporate insolvency resolution process and the resolution plan to the Board to be recorded on its database. (4) The resolution applicant shall, pursuant to the resolution plan approved under sub-section (1), obtain the necessary approval required under any law for the time being in force within a period of one year from the date of approval of the resolution plan by the Adjudicating Authority under sub-section (1) or within such period as provided for in such law, whichever is later: Provided that where the resolution plan contains a provision for combination, as referred to in section 5 of the Competition Act, 2002 (12 of 2003), the resolution applicant shall obtain the approval of the Competition Commission of India under that Act prior to the approval of such resolution plan by the committee of creditors.” 16. As per Sections 31 and 238 of the IBC, the approved Resolution Plan has been made binding on the Corporate Debtors - McNally Bharat Engineering Company Ltd., its employees, members, creditors, guarantors including the Central Government, any State Government or any local authority and other stakeholders involved in the Resolution Plan, to whom a debt in respect of payment of dues arising under any law for the time being in force, is owed. Section 238 of the IBC provides that the Code will prevail in case of inconsistency between two laws. This proposition of law has been crystallized by Hon'ble Supreme Court in the case of Committee of Creditors of Essar Steel India Ltd. Through Authorised Signatory Vs. Satish Kumar Gupta & Ors. [ 2019 (16) SCALE 319 ]. This court also examined similar controversy in the case of Ultra Tech Nathdwara Cement Ltd. (supra) and held that any demands made by the Statutory Creditor, i.e. Commercial Taxes Department, for the period prior to the effective date stand extinguished with the approval of the Resolution Plan by the NCLT. 17. Law is well-settled that with the finalization of insolvency resolution plan and the approval thereof by the NCLT, all dues of creditors, Corporate, Statutory and others stand extinguished and no demand can be raised for the period prior to the specified date. 18. The assessment orders pertain to the years 2014-2015, 2015-2016 and 2016-2017 and for the recovery of the amount in pursuance of the same, communication was issued to the Bank in the year 2019, which are much prior to the date of finalization of the Resolution Plan, i.e. 19.12.2023. 19. The impugned communication/notice dated 17.07.2019 (Annex.5) issued in pursuance to the assessment orders dated 21.03.2017, 05.03.2018 and 28.03.2019 for the assessment years 2014-2015, 2015-2016 and 2016-2017 respectively do not stand to test of law, i.e. mandate of Section 31 read with Section 238 of the IBC and the interpretation thereof as made by Hon'ble the Supreme Court in the case of Committee of Creditors of Essar Steel India Ltd. (supra). Hence, the same is declared to be invalid and quashed. 20. These writ petitions are allowed, accordingly. 21. No order as to costs.