Seem to remember AA's CVA doesn't cater for relegation either... they're in huge trouble regardless if HMRC appeal because they won't be able to compete in the Championship. It's doubtful that they can afford that CVA as it is, even at such a low rate, and relegation would all but comfirm they can't keep up repayments. They miss one payment and the HMRC will just put in a winding up petition straight away again.
Also what's good for us is bad for them... with Leeds, Norwich and Millwall getting promoted, the NPC is a more difficult league this year.