# S. Rajendran v. The Deputy Commissioner of Income Tax (Benami Prohibition) & Others

> SC judgment dated 2026-02-24. Citation: TCN-2026-SC-00072. This batch of appeals originated from orders by the NCLAT, Chennai bench, which upheld the NCLT's…

- **Court:** SC
- **Order date:** 24 Feb 2026
- **Citation:** TCN-2026-SC-00072
- **Category:** IBC
- **Source page:** https://caseease.in/cases/ibc/supreme-court-of-india/s-rajendran-vs-the-deputy-commissioner-of-income-tax-tcvvf

## Summary

### Background

This batch of appeals originated from orders by the NCLAT, Chennai bench, which upheld the NCLT's decision to decline jurisdiction over challenges to provisional attachment orders issued under the Prohibition of Benami Property Transactions Act, 1988 (Benami Act). The case involves corporate debtors, M/s Padmaadevi Sugars Ltd. and M/s Senthil Papers and Board Pvt. Ltd., whose promoters allegedly engaged in benami transactions by transferring 100% shareholding to V.K. Sasikala for Rs. 450 Crores in demonetised currency. Following investigations, provisional attachment orders were issued under the Benami Act. Subsequently, the corporate debtors entered Corporate Insolvency Resolution Proceedings (CIRP) and later liquidation. The appellant-liquidators challenged these

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## Facts

The present batch of appeals arises out of impugned judgments and orders dated 18.08.2022 and 13.03.2023 passed by the National Company Law Appellate Tribunal, Chennai bench (NCLAT).

The NCLAT declined to interfere with the decision of the National Company Law Tribunal (NCLT) and refused to adjudicate the appellant-liquidators' applications challenging provisional attachment orders under the Benami Act.

The NCLT and NCLAT concurrently held that the NCLT lacks jurisdiction to entertain such challenges and that the remedy lies exclusively before the competent forum constituted under the Benami Act.

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## Issues and analysis

### Issue 1: Whether the legality and validity of an order of attachment under Benami Act can be challenged …

**Ratio:** The Benami Act is a special, self-contained code for identifying, attaching, and

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**Reasoning:** The NCLT and NCLAT correctly held that the Benami Act is a special legislation with its

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**Interpretation:** The court interpreted the Benami Act as a self-contained, special legislation

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**Application:** The court applied these interpretations to dismiss the appeals, holding that

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## Parties

- **Judges:** Pamidighantam Sri…; ATUL S. CHA…
- **Appellants:** S. RAJE…
- **Respondents:** M/s Padmaadevi…; M/s Senthil…; +1 more
- **Other parties:** 8th Edition…; Benami Pr…; +15 more
- **Advocates:** S. Sen…; Krishnan Ve…; +3 more

## Timeline

- **2016-11-01 — Demonetisatio…**: Asset purchases made during November-December 2016, which were later investigated for…
- **2017-11-01 — Search and Seizure…**: Search and seizure operation conducted under Section 132 of the Income Tax Act, 1961,…

## Legal provisions

- [Insolvency and Bankruptcy Code, 2016, Section 14 — Moratorium](https://caseease.in/legal-provisions/insolvency-and-bankruptcy-code-2016/section-14)

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