IBBI Suspends Insolvency Professional Harish Taneja for Two Years Over CIRP Process Lapses

What has changed

The Insolvency and Bankruptcy Board of India has suspended the registration of insolvency professional Harish Taneja for two years after a disciplinary committee found shortcomings in the conduct of the corporate insolvency resolution process of BCC Infrastructures Private Limited.

The order, numbered IBBI/DC/339/2026 and dated 17 August 2026, is significant for insolvency professionals and committee of creditors members because it focuses on two recurring process risks: whether appointments of professionals and valuers are demonstrably transparent, and whether a resolution professional has actually prepared a meaningful marketing strategy when Regulation 36C requires one.

Background of the BCC Infrastructures CIRP

According to the disciplinary order, the CIRP of BCC Infrastructures Private Limited was admitted by the National Company Law Tribunal, New Delhi, on 17 January 2024 on an application filed under section 7 of the Insolvency and Bankruptcy Code by Catalyst Trusteeship Limited. Taneja was appointed as the interim resolution professional and later continued as the resolution professional.

IBBI issued a show-cause notice dated 11 November 2025. Taneja submitted his response on 2 December 2025 and was granted a personal hearing on 9 April 2026, followed by further submissions during April to July 2026.

Appointments and quotations came under scrutiny

One part of the disciplinary examination concerned the process followed for engaging professionals and a valuer. The order records issues around appointments including Gurpreet Singh, Dhawan & Co., M/s Gulati Dinesh & Associates and valuer Vishal Gambhir.

The disciplinary committee noted that the record did not establish a sufficiently objective and transparent process for obtaining and comparing quotations in every case. In particular, where quotations were said to have been obtained telephonically, the committee observed that such a process was not verifiable through documentary evidence.

This matters because insolvency professionals are expected to be able to demonstrate, not merely assert, that professional appointments and related costs were handled transparently and objectively. For practitioners, the practical lesson is to preserve emails, written proposals, fee comparisons, evaluation notes and the basis for final selection so the decision can be independently reconstructed later.

Regulation 36C marketing strategy was a major issue

The order also examined compliance with Regulation 36C of the CIRP Regulations. The provision requires a resolution professional, where the corporate debtor's total assets exceed Rs 100 crore, to prepare a marketing strategy in consultation with the committee of creditors, with implementation subject to the committee's approval.

IBBI's order records that BCC Infrastructures had assets exceeding Rs 600 crore. The disciplinary committee did not accept a brief teaser and basic asset-liability information as a substitute for the marketing strategy contemplated by the regulation.

The committee indicated that a meaningful strategy should address matters such as the target pool of prospective resolution applicants, the platforms or channels to be used, the manner and timeline of marketing, estimated costs and the basis of consultation with the CoC. The order also noted that the CoC minutes did not demonstrate the required consultation and approval process.

The disciplinary committee therefore held that Taneja had failed to prepare a comprehensive marketing strategy as required under Regulation 36C.

Two-year suspension and transition consequences

IBBI ordered suspension of Taneja's insolvency professional registration for two years. The suspension is to take effect after expiry of 30 days from the date of issuance of the order.

The order also directs that copies be sent to the committees of creditors of corporate debtors where Taneja is providing services. Those CoCs are required to replace him with another resolution professional in accordance with section 27 of the Code. A copy is also to be forwarded to the ICSI Institute of Insolvency Professionals and the Principal Bench of the NCLT at New Delhi.

Practical compliance lessons for insolvency professionals

- Document vendor and professional selection: preserve written quotations, comparisons and reasons for appointment instead of relying on conversations that cannot later be verified.

- Treat Regulation 36C as a substantive obligation: where the asset threshold applies, a basic teaser is not enough; the strategy should explain who will be targeted, where the opportunity will be marketed, the timeline, expected costs and the consultation process.

- Record CoC consultation clearly: meeting minutes should capture deliberation and approval where the regulations require CoC involvement.

- Maintain an audit-ready file: disciplinary review often happens much later, so contemporaneous documentation is critical.

For CAs and insolvency professionals working on CIRPs, the order is a reminder that procedural transparency must be visible in the record. Decisions that may appear commercially reasonable can still create regulatory exposure if the supporting process, comparison and CoC consultation are not properly documented.

Useful official links

IBBI Disciplinary Committee Order No. IBBI/DC/339/2026 dated August 17, 2026

Key takeaway

A fresh, detailed IBBI disciplinary order gives insolvency professionals, CAs and restructuring teams concrete guidance on documentation, transparent appointment processes and Regulation 36C marketing strategy compliance.