In India, the bad debts are going on increasing. Compared to any other
country, the process of resolving the insolvency is time consuming. This makes
our country to become weak in economy.
A Detailed Study on Voluntary Liquidation of Corporate Person Under The
Insolvency And Bankruptcy Code, 2016
In India, the bad debts are going on increasing. Compared to any other country,
the process of resolving the insolvency is time consuming. This makes our
country to become weak in economy. Among the total bad debts, the corporate
debts constitute 56%. These all lead to pending of thousands of litigations
before the courts for recovery of money. The existed Acts such as the Presidency
Towns Insolvency Act, 1909 and the Provincial Insolvency Act, 1920 dealing with
the insolvency in case of individuals are centuries old. These issues were
solved by the enactment of Insolvency and Bankruptcy Code, 2016. The Code mainly
focused on maximisation of the value of debtor’s assets. The Code gives a clear
idea about the insolvency resolution process. This article mainly focuses on the
concept of voluntary liquidation of company. It explains about the procedure
involved in the process of voluntary liquidation of a corporate person. This is
mainly distinguished from the voluntary winding up of companies under the
Companies Act, 2013. The main focus of the article is declaration of solvency,
general meeting for initiating voluntary winding up, intimation to other
regulatory authorities, effect of voluntary liquidation, the dissolution of
corporate debtor and finally the punishment under the code for fraudulent or
malicious initiation of proceedings.
The Insolvency and Bankruptcy Code (2016) is a significant code. The speed at
which the legislation was enacted and how it is made operational along with
detailed rules and regulations have amazed many. The code gives a clear
distinction between Insolvency and Bankruptcy. This Code deals with two
aspects. One is the Insolvency Resolution and Liquidation of Corporate Entities.
The other is the Bankruptcy of individuals and corporate firms.
This article mainly focuses on the procedures prescribed under the Insolvency
and the Bankruptcy Code, 2016 relating to the Voluntary Liquidation of corporate
The main objective of this research is to bring into the light the procedure for
voluntary liquidation of a corporate person that is mentioned under the
Insolvency and the Bankruptcy Code, 2016. This research also focuses whether the
companies are able to cope up with the procedure for voluntary liquidation
prescribed under this Code.
- Whether the procedure given under the Insolvency and Bankruptcy Code, 2016 is
simple for the companies to follow?
- Whether there is any difficulty in following the procedure for voluntary
liquidation under Section 59 of the Code?
- Whether the procedure for voluntary liquidation given under the Code is
similar to procedure for voluntary winding up of companies under the Companies
Meaning of Insolvency And Bankruptcy Under The Code
The Code gives a clear distinction between Insolvency and Bankruptcy.
The term Insolvency has not been defined under the Code. However, Insolvency
means short term inability to meet the liabilities during the normal course of
business. It can be resolved by changing the repayment plan of loans. If it
cannot be resolved, then a legal action may be taken against the insolvent. In
this case, the assets of the insolvent will be sold to pay back the outstanding
debts. Generally an official assignee or liquidator is appointed by the
Government of India. The official assignee or the liquidator will allocate the
assets of the insolvent to the insolvents creditor.
The term Bankruptcy has not been defined under the Code. However, Bankruptcy
means long term inability to meet the liabilities. It slightly differs from
insolvency. It means that a person voluntarily declares himself as an insolvent
and approaches the Court. On doing so, the Court is responsible to liquidate the
personal property of the insolvent and hand it over to his creditors. Thus it
provides a fresh lease of life to the insolvent.
Insolvency And Bankruptcy Code, 2016
The Insolvency and Bankruptcy Code have consolidated the Insolvency, Bankruptcy
and Liquidation laws for companies, partnership firms, limited liabilities
partnership and individuals in India which are contained in various enactments
into a single Code. It came into effect on 28 May 2016. The main aim of the Code
is to consolidate the law related to insolvency and bankruptcy. Thus the Code
seeks to shift the winding up process by creditors and voluntary winding by
members of the company from the Companies Act, 2013 to the Code. Another
important feature of this code is that, it does not make distinction between
international and domestic creditors. It also does not distinguish between the
classes of financial institutions.
In this regard, the Ministry of Corporate Affairs (MCA) on March 30, 2017
notified Section 59 of the Code, 2016 as Voluntary winding up of a corporate
person. In furtherance of this the Insolvency and Bankruptcy Board of India
issued the Insolvency and Bankruptcy Board of India (Voluntary Liquidation)
Regulations, 2017. The Insolvency and Bankruptcy Code repeals the Presidency
Towns Insolvency Act, 1909 and Provincial Insolvency Act, 1920. In spite
of this the Code amended the 11 legislations. The important legislations amended
by this Code are:
- Indian Partnership Act, 1932
- The Companies Act, 2013
- Securitisation and Reconstruction of Financial Assets and Enforcement of
Security Interest Act, 2002
- Limited Liability Partnership Act, 2008
- Sick Industrial Companies (Special Provisions) Repeal Act, 2003
Voluntary Liquidation of Companies Under The Code
Under Chapter V, Section 59 of the Insolvency and Bankruptcy Code, 2016 deals
with voluntary liquidation of corporate persons. Section 59(1) of the Code
explains that, a corporate person who is intending to liquidate it voluntarily
and has not committed any default may initiate voluntary liquidation proceedings
under the provisions of this chapter. Section 59(2) states that the voluntary
liquidation in case of corporate person under sub-section (1) shall follow the
procedural requirements and meet the conditions as may be prescribed by the
Insolvency and Bankruptcy Board.
Provisions required to be referred for Voluntary Winding Up of a company:
- Section 59 of Insolvency and Bankruptcy Code, 2016
- Insolvency and Bankruptcy Board of India (Voluntary Liquidation Process)
- Section 35 to 53 of the Insolvency and Bankruptcy Code, 2016 read with
- Bankruptcy (Liquidation Process) Regulations, 2016
- Insolvency and Bankruptcy Board of India (Insolvency Professionals)
The Regulatory authorities for dealing with Voluntary Winding Up of companies:
The Insolvency and Bankruptcy Board of India
Registrar of Companies
National Company Law Tribunal (NCLT)
Procedure For Voluntary Liquidation of A Company
Declaration of Solvency:
Section 59(3)(a)(i) of the Insolvency and Bankruptcy Code, 2016 says that a
declaration from majority of the Directors stating that they have made a full
enquiry about the affairs of the company and they have formed the opinion that
the company has no debt or in case it has debts it will be able to pay its debts
completely from the value obtained from the assets to be sold in the voluntary
liquidation. Section 59(3)(a)(ii) states that in case of voluntary winding up of
a company, the company must state that it is not being liquidated to defraud any
person. In this case, an affidavit verifying the above must be submitted from
the majority of the directors.
The declaration under sub-section (a) must be accompanied with the following
documents. They are specified under Section 59(3)(b) of the Code.
The documents are:
i) Audited financial statements and record of business operations of the company
for previous two years or for a period since its incorporation, whichever is
ii) A report of valuation of the assets of the company, in case if it is
prepared by a registered valuer.
After the declaration is filed, a board meeting shall be held to approve the
declaration and proposal for winding up of the company. Then the company’s bank
account shall be closed and a liquidation account will be opened. There is no
provision under the Code for filing a declaration with the authority like the
Companies Act, 1956 which gives the prescribed provision for this. However,
it is recommended to file the same with RoC in Form GNL-2.
General Meeting for initiating Voluntary Winding Up:
Section 59(3)(c) explains about the general meeting for initiating voluntary
winding up of corporate persons. Within four weeks of the declaration under
i) There shall be a special resolution by the members of the company in a
general meeting requiring the company to be liquidated voluntarily and also it
empowers the appointment of insolvency professional to act as a liquidator.
ii) There shall also be a resolution of the members of the company in a general
meeting requiring that the company to be voluntarily liquidated as a result of
expiry of the period of its duration if it is fixed by the articles of
association of the company or on the occurrence of any event which the
articles provide, that the company shall be dissolved and if it is dissolved,
the company may appoint an insolvency professional to act as the liquidator.
It also provides that, if a company owes any debts to any person, creditors
representing two-thirds in value of the debts of the company, then the company
shall approve the resolution passed under sub-clause (c) and such approval must
be made within seven days of such resolution.
Intimation to other regulatory authorities:
Under sub-section (4), it is held that the company shall inform to the
Registrar of Companies and the Board about the resolution under sub-section (3)
to liquidate the company within seven days of such resolution or on the
subsequent approval by the creditors. If the creditors approved under
sub-section (3), then the voluntary liquidation shall be commenced from the date
of passing of the resolution under sub-section (3)(c) which is explained under
Application of Sections 35 to 53 of the Code:
Sub-section (6) of Section 59 says that, Sections 35 to 53 of Chapter III
and VII shall apply to voluntary liquidation proceedings of corporate persons.
Chapter III deals about liquidation process of a corporate person in case of
incompletion of insolvency resolution process and the NCLT orders for
liquidation of corporate persons. Chapter VII deals with offences and penalties.
It is also provided that the liquidator in case of voluntary winding up of
companies shall prepare a report on quarterly basis and submit the report to the
Registrar of Companies or to the Board.
Sub-section (7) of Section 59 explains that where the affairs of the company
have been completely wound up and the company’s assets are completely
liquidated, then the liquidator shall make an application to the
Adjudicating authority for the dissolution of such corporate person.
Dissolution of Corporate debtor:
Under sub-section (8) of Section 59 deals about the dissolution of corporate
debtor. This sub-section says that, the Adjudicating Authority, on the
application filed by the liquidator under the sub-section (7), shall pass an
order that the corporate debtor shall be dissolved from the date of the issuance
of the order and the corporate debtor shall be dissolved accordingly. A copy of
the order issued by the Adjudicating authority under this sub-section, within
fourteen days from the date of such order, shall be forwarded to the authority
with which the corporate person is registered.
Public announcements and claims:
Regulation 14(1) of the Insolvency and Bankruptcy Board of India (Voluntary
Liquidation Process) Regulations, 2017, deals about the public announcements and
claims. The liquidator shall make a public announcement in Form A of Schedule
within five days from his appointment about the liquidation of the company.
Sub-regulation (2) states that the Public announcement shall call upon the
stakeholders to submit their claims as on the liquidation commencement date
and he must provide the last date for submission of claim, that is thirty days
from the commencement of liquidation date. Sub-regulation (3) states that the
announcement shall be published in the official Gazette, in one English and one
regional language newspaper, on the website of the corporate person if it is
available and on the website, if any, designated by the board for this purpose.
Chapter V of Insolvency and Bankruptcy Board of India (Voluntary Liquidation
Process) Regulations, 2017 deals about various claims which includes;
· Claims by operational creditors – Regulation16
· Claims by financial creditors – Regulation 17
· Claims by workmen and employees – Regulation 18
· Claims by other stakeholders – Regulation 19
Realisation of Assets:
Chapter VI of the Regulation 2017 deals with the realisation of assets under
regulations 31 to 33. The liquidator may value the property of the
corporate person and sell it in any manner and through any mode that is approved
by the corporate person. Chapter VII deals with Proceeds of liquidation and
distribution of proceeds under regulations 34, 35 and 36. The
liquidator shall distribute the proceeds to the stakeholders within six
months from the receipt of amount.
Registers and books of accounts:
Regulation 10 of the Insolvency and Bankruptcy Board of India (Voluntary
Liquidation Process), 2017 explains about the Registers and books of accounts to
be maintained by the Liquidator. Regulation 10(2) states that the liquidator
shall maintain the books and registers in case of voluntary liquidation of the
corporate person. The liquidator must preserve the books and the registers for a
period of eight years after the dissolution of the corporate person. The books
and registers to be maintained are as follows:
c) Bank Ledger
d) Register of fixed assets and inventories
e) Securities and Investment Register
f) Register of Book Debts and Outstanding Debts
g) Tenants Ledger
h) Suits Ledger
i) Decree Register
j) Register of Claims and Dividends
k) Contributories Ledger
l) Distributions Register
m Fee Register
n) Suspense Register
o) Documents Register
p) Books Register
q) Register of unclaimed dividends and undistributed properties deposited in
accordance with Regulation 39 and
r) Such other books or registers as may be necessary to account for transactions
entered into by him in relation to the corporate person.
Sub-regulation (3) states that the registers and books under the sub-regulation
(2) may be maintained in the forms which are given under the Schedule II, which
certain modifications as the liquidator may think fit in the facts and
circumstances of the voluntary liquidation. Sub-regulation (4) states that the
liquidator shall keep receipts of all the payments or expenses made by him.
Effect of Voluntary Liquidation of status of Corporate Person:
Regulation 6 of Insolvency and Bankruptcy Board of India (Voluntary Liquidation
Process) Regulations, 2017 states the effect of Voluntary Liquidation of status
of corporate person. The Corporate person from the voluntary liquidation
commencement date shall cease to carry on its business except in case of the
beneficial winding up of the business.
Completion of Liquidation:
Regulation 37 of Insolvency and Bankruptcy Board of India (Voluntary Liquidation
Process) Regulation, 2017 deals with completion of liquidation. The liquidator
shall aim to wind up the affairs of the corporate person within one year from
the voluntary liquidation commencement date. If the voluntary liquidation is
continuing for more than one year, then the liquidator shall call a meeting of
the contributories of the corporate person. He shall call for a meeting within
15 days from the end of the year in which he is appointed as a liquidator and
also at the end of each succeeding year. The liquidator shall also present a
status report indicating the progress in the liquidation. It shall include
settlement of list of stakeholders, details of any property that remains to be
sold and realized, distribution made to the stakeholders, development in any
material litigation etc. The Status Report shall be enclosed with an audited
account of the voluntary liquidation and the report must show the receipts and
payments relating to liquidation from the liquidation commencement date.
Final Report prior to dissolution:
Regulation 38 of Insolvency and Bankruptcy Board of India (Voluntary Liquidation
Process), 2017 deals with the final report prior to dissolution. The
Sub-regulation (1) states that, when the affairs of the corporate person are
fully wound up, the liquidator shall prepare a final report consisting of an
audited account of voluntary liquidation showing the receipts and payment
relating to liquidation from the date of commencement of liquidation and
also a statement demonstrating that the assets of the corporate person have been
disposed of, the debt of the corporate person has been discharged which
satisfies the creditors and also to demonstrate that no litigation is pending
against the corporate person. Along with this, the liquidator shall also give a
final report regarding a sale statement in respect of all the assets containing
the realized value, cost of realization if it is there, the manner and mode of
sale, the person to whom the sale is made and any other details of the sale. The
sale statement shall also include a report if the value realized is less than
the value assigned by the registered valuer in the report of valuation of assets
prepared in accordance with Section 59(3)(b) of the Code, 2016 or Regulation
3(2)(b) of 2017 Regulation.
Sub-regulation (2) states that, the liquidator shall send the final report to
the contributories of the corporate person, the Registrar and the Board. The
liquidator shall send the report by registered post at their registered address
and by electronic means. Sub-regulation (3) states that, the liquidator shall
submit the final report to the Adjudicating Authority along with the application
under Section 59(7) of Insolvency and Bankruptcy Code, 2016.
National Company Law Tribunal:
Section 60 of the Act deals with Adjudicating Authority for corporate persons.
As per sub-section (1) of Section 60, the Adjudicating Authority shall be
National Company Law Tribunal (NCLT), in relation to insolvency resolution and
liquidation for corporate persons including the corporate debtors and personal
guarantors. It is to be noted that the NCLT will have territorial jurisdiction
over the place where the registered office of the corporate person is located.
Sub-section (4) of section 60 says that, the National Company Law Tribunal shall
have all the powers of the Debt Recovery Tribunal.
Section 65 of the Code deals about the fraudulent or malicious initiation of
proceedings. Sub-section (2) of Section 65 deals mainly about the punishment
imposed fraudulent voluntary liquidation proceedings. It explains that, if any
person initiates voluntary liquidation proceedings with the intent to defraud
any person, the Adjudicating Authority may impose upon such person, a penalty
which shall not be less than one lakh rupees but may extend to one crore rupees.
· From the above research, it is clear that the procedure given under the
Insolvency and the Bankruptcy Code, 2016 regarding the Voluntary Liquidation of
Corporate person is simple procedure and not too complicated and the companies
must follow this procedure in case the company is to wind up due to insolvency.
· The procedure given for voluntary liquidation of a corporate person under this
Code is simple and thus there is no difficulty in following the procedure and
non-compliance of the procedure is a punishable offence under Section 65 of the
· It is also noted that, the procedure for voluntary liquidation of the
Corporate Person under the Code is different from the procedure for Voluntary
winding up of companies as enumerated in the Companies Act of 2013. The
Companies Act, 2013 deals with voluntary liquidation of companies under Sections
304 to 325.
· The voluntary winding up of companies under the Companies Act, 2013 is
segregated into 2 categories. They are
i) Members voluntary winding up
ii) Creditors voluntary winding up
This distinction is eliminated under the Insolvency and Bankruptcy Code, 2016.
Under Section 59 of the Code, only a corporate person is allowed to initiate
voluntary liquidation process, which has not committed any default.
The Insolvency and Bankruptcy Code, 2016 gives a clear cut distinction between
insolvency and bankruptcy. The details discussed in this article relates to
Voluntary winding up of corporate person under the Code. The Code gives a
crystal clear procedure in case of voluntary liquidation of corporate person
under Section 59. Together with the Code, the Insolvency and Bankruptcy Board of
India (Voluntary Liquidation Process) Regulation, 2017 also explains about the
process involved in the voluntary winding up of the companies. Starting from the
declaration of solvency to the final report is explained in a detailed manner in
the Code and the Regulation. Even though the Code does not define the terms
“Insolvency” and “Bankruptcy”, it explains about the process of winding up of
insolvent and bankrupt corporate persons evidently. The Code has given more
responsibility to the liquidator to comply with the provisions of the Code. Thus
the liquidator should be well versed in this Code. The Regulation also explains
about the realisation of assets and the distribution of the proceeds, effect of
voluntary liquidation and also the books and the registers to be maintained by
the liquidator in case of voluntary liquidation.
1) Insolvency and Bankruptcy Code, 2016
2) Insolvency and Bankruptcy Board of India (Voluntary Liquidation Process)
3) The Companies Act, 2013
4) Insolvency and Bankruptcy (Liquidation Process) Regulations, 2016
5) Insolvency and Bankruptcy Board of India (Insolvency Professionals)
6) Presidency Towns Insolvency Act, 1909
7) Provincial Insolvency Act, 1920
 General meaning of Insolvency is the state of being unable to pay the money
owed, by a person or company on time; those in a state of insolvency are said to
be insolvent. There are two forms of insolvency. They are cash-flow insolvency
and balance-sheet insolvency.
 General meaning of Bankruptcy is a legal status of a person or other entity
that cannot repay the debts it owes to creditors. Bankruptcy is not the only
legal status that an insolvent person may have, and thus the term bankruptcy is
therefore not a synonym for insolvency. In most jurisdictions, bankruptcy is
imposed by a court order, often initiated by the debtor.
 In exercise of the powers conferred by sections 59, 196 and 208 read with
section 240 of the Insolvency and Bankruptcy Code, 2016 (31 of 2016), the Board
made the Insolvency and Bankruptcy Board of India (Voluntary Liquidation)
Regulations, 2017. These Regulations shall apply to the voluntary liquidation of
corporate persons under Chapter V of Part II of the Insolvency and Bankruptcy
 Act No. 3 of 1909 1 [12th March, 1909]. An Act to amend the law of
insolvency in the Presidency-towns 2.
 Act No. 5 of 1920 [25th February, 1920]. An Act to consolidate and amend the
law relating to Insolvency 1 as administered by Courts having jurisdictions
outside the Presidency-towns.
 Act No. 9 of 1932. [8th April, 1932]. An Act to define and amend the law
relating to Partnership.
 Act No. 18 of 2013. [29th August, 2013]. An Act to consolidate and amend the
law relating to companies.
 Act No. 54 of 2002. An Act to regulate securitisation and reconstruction of
financial assets and enforcement of security interest and matters connected
therewith or incidental thereto.
 Act No. 6 of 2009. [7th January, 2009], Act of Parliament. An Act to make
provisions for the formation and regulation of limited liability partnerships
and for matters connected therewith or incidental thereto.
 Act No. 1 of 2004. [1st January, 2004]. An Act to repeal the sick
industrial companies (Special Provisions) Act, 1985.
 The Insolvency and Bankruptcy Board of India (IBBI) is the most important
institutional arrangement for the new insolvency and bankruptcy regime. It was
created as a referring institution with multiple tasks including creation of
regulations and control of agencies and professionals involved in the insolvency
and bankruptcy business. The IBBI was established on October 1, 2016 in
accordance with the provisions of the Insolvency and Bankruptcy Code, 2016. It
was constituted as a technical committee under the IBBI regulations, 2017.
(Aug. 16, 2017, 10:06:10)
 Registrars of Companies (ROC) appointed under Section 609 of the Companies
Act covering the various States and Union Territories are vested with the
primary duty of registering companies and LLPs floated in the respective states
and the Union Territories and ensuring that such companies and LLPs comply with
statutory requirements under the Act. Refer http://www.mca.gov.in. (Aug. 17,
 The National Company Law Appellate Tribunal (NCLAT) is a quasi-judicial
body in India that adjudicates issues relating to companies in India. The NCLAT
was established under the Companies Act 2013 and was constituted on 1 June 2016.
 Act No. 1 of 1956. An Act to consolidate and amend the law relating to
companies and certain other associations.
 It is a form for submission of documents with the Registrar of Companies.
 Section 19 of the Insolvency and Bankruptcy Code, 2016 defines an
Insolvency Professional. It means a person enrolled under section 206 with an
insolvency professional agency as its member and registered with the Board as an
insolvency professional under section 207.
 As per Section 2(5) of the Companies Act, 2013, “articles” means the
articles of association of a company as originally framed or as altered from
time to time or applied in pursuance of any previous company law or of this Act.
Section 5 of the Companies Act, 2013 deals with AOA. The articles of a company
shall contain the regulations from management of the company. The articles shall
also contain such matters, as may be prescribed. It shall not prevent a company
from including such additional matters in its articles as may be considered
necessary for its management.
 Under this Code, the term “Liquidator” has been defined under Section
5(18). A liquidator means an insolvency professional appointed as a liquidator
in accordance with the provisions of Chapter III or Chapter V of this part, as
the case may be.
 An “Adjudicating authority” is defined under Section 5(1) of this Code. An
Adjudicating officer for the purposes of this Part, means National Company Law
Tribunal constituted under section 408 of the Companies Act, 2013.
 According to Section 3(8) of the Insolvency and Bankruptcy Code, 2016,
“Corporate debtor” means a corporate person who owes a debt to any person.
 Dealt under Section 59(9) of the Insolvency and Bankruptcy Code, 2016.
 Section 5(17) of the Insolvency and Bankruptcy Code, 2016 defines
"liquidation commencement date" means the date on which proceedings for
liquidation commence in accordance with section 33 or section 59, as the case
 With wide circulation at the location of the registered office and
principal office, if any, of the corporate person and any other location where
in the opinion of the liquidator, the corporate person conducts material
 Regulation 31 of 2017 regulation deals with manner of sale.
 Regulation 32 and 33 deals with Recovery of monies due and Liquidator to
realize uncalled capital or unpaid capital contribution.
 Regulation 34 of Insolvency and Bankruptcy Board of India (Voluntary
Liquidation Process), Regulations, 2017 explains about all money to be paid in
to bank account.
 Regulation 35 of 2017 regulation deals with distribution of proceeds.
 Regulation 36 of 2017 regulation deals with Return of money.
 A person, group or organization that has interest or concern in an
organization. Stakeholders can affect or be affected by the organization’s
actions, objectives and policies. Some examples of key stakeholders are
creditors, directors, employees, government (and its agencies), owners
(shareholders), suppliers, unions and the community from which the business
draws its resources. Refer http://www.businessdictionary.com/definition/stakeholder.html.
 A cash book is a financial journal that contains all cash receipts and
payments, including bank deposits and withdrawals. Entries in the cash book are
then posted into the general ledger. Refer http://www.investopedia.com/terms/c/cash-book.asp
(Aug. 17, 2017,08:15:00).
 It's a record kept by landlords to keep track of tenants, lease dates,
rental amount, security deposits, dates that rent is due, last rent increases,
other comments about tenants.
 It says about the unclaimed proceeds of liquidation or undistributed
 Regulation 38(1)(a) of Insolvency and Bankruptcy Board of India (Voluntary
Liquidation Process) Regulation,2017.
 Explanation: For the purpose of this Regulation, ‘assets’ include an asset,
all assets, a set of assets or parcel of assets, as the case may be, which are
 Section 3(1) of Recovery of Debts Due to Banks and Financial Institutions
Act, 1993 deals about the establishment of tribunal. The section is as follows;
The Central Government shall, by notification, establish one or more Tribunals,
to be known as the Debts Recovery Tribunal, to exercise the jurisdiction, powers
and authority conferred on such Tribunal by or under this Act.
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