The Adjudicating Authority observed that the CIRP against the Corporate Debtor commenced vide Order dated 09.04.2018, all the three Assessment Orders passed by the Income Tax Department on the subsequent dates (i.e., during the moratorium period), relate to the pre-CIRP period from 2012-13 to 2017-18. Hence, it is amply clear that through these Assessment Orders, the Income Tax Department has been attempting to recover their dues pertaining to the period prior to the initiation of CIRP of the Corporate Debtor. From the plain reading of the Section 32A of the Code, it can be inferred that the Corporate Debtor, on approval of the Resolution Plan by the Adjudicating Authority and on change in management, is immune from the proceedings which pertain to the pre-CIRP period.