On 6 September 2022 a two-judge bench of the Supreme Court, in State Tax Officer (1) v. Rainbow Papers Ltd, read Section 48 of the Gujarat Value Added Tax Act 2003 — which creates a first charge on the dealer's property in respect of VAT dues — as creating a 'security interest' by operation of law within Section 3(31) of the Insolvency and Bankruptcy Code, with the consequence that the State became a 'secured creditor' under Section 3(30) and a resolution plan that wholly ignored the statutory dues was non-compliant with Section 30(2). A coordinate bench in Paschimanchal Vidyut Vitran Nigam v. Raman Ispat then confined the holding to its facts. A close reading of the GVAT-IBC architecture, the Section 53 waterfall analysis, the doctrinal arc that has followed, and what practitioners advising resolution applicants and statutory authorities should take from the case.