The Revenue challenged the Tribunal’s order deleting the disallowance of subcontract charges made in the assessment completed under section 143(3). During the pendency of the proceedings, the assessee underwent Corporate Insolvency Resolution Process, and a Resolution Plan was approved by the NCLT under section 31 of the Insolvency and Bankruptcy Code. The income-tax demand arising from the assessment order was never lodged before the Committee of Creditors nor formed part of the approved Resolution Plan. The Bombay High Court, following the decisions of the Supreme Court in Samarth Lifters Pvt. Ltd. v. DBM Geotechnics & Construction Pvt. Ltd., Vaibhav Goel v. Deputy Commissioner of Income-tax, Ghanshyam Mishra & Sons Pvt. Ltd. v. Edelweiss Asset Reconstruction Co. Ltd., and Committee of Creditors of Essar Steel India Ltd., held that all statutory dues not included in the approved Resolution Plan stand extinguished and cannot thereafter be enforced. Even if the Revenue were to succeed in the appeal, no recoverable tax demand could survive outside the Resolution Plan. Accordingly, the questions proposed by the Revenue were held to be purely academic, no substantial question of law arose for consideration, and the appeal was dismissed. (ITA No. 230 of 2024, , dt. 17-07-2026. )(AY. 2012-13 )