19-ITXA-1163-2019 (OS).DOC Mayur IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX APPEAL(IT) NO. 1163 OF 2019 WITH IA(L)/19476/2025 IN ITXA/1163/2019 The Principal Commissioner Of Income Tax-3, Mumbai …Appellant Versus Doshi Holdings Pvt. Ltd. Through Ms. Kanak Jani, Resolution Professional …Respondents Mr. P.C. Chhotaray for the Appellant. Mr Prathamesh M. Nirkhe, i/b. Asahi Legal for Respondent. CORAM: SUMAN SHYAM & ADVAIT M. SETHNA, JJ. DATED: 17th AUGUST 2026. PC:- 1. Mr. Prathamesh Nirkhe, learned counsel for the Respondent, submits that the amount of tax involved in these proceedings is Rs. 1,27,77,150/-, and in view of Circular No. 09/2024 of the Central Board of Direct Taxes dated 17th September 2024, issued by the Government of India, Ministry of Finance, Department of Revenue, Central Board of Direct Taxes, this appeal would not be maintainable only on the ground of low tax effect. However, it is also the submission of the learned counsel for the Respondent that MAYUR KONDIRAM ADANE Digitally signed by MAYUR KONDIRAM ADANE Date: 2026.08.24 11:33:03 +0530 19-ITXA-1163-2019 (OS).DOC since the corporate resolution plan pertaining to the Respondent has already been finalized and the same has been implemented, nothing survives in this appeal since there are no dues from the Respondent payable to the Appellant at this point of time. 2. Responding to the above, Mr. Chhotaray, learned Department counsel, has opposed the submission suggesting withdrawal of the appeal on the ground of low tax effect as the same would fall within the exceptions carved out in the CBDT Circulars. However, he submits that, based on instructions obtained from the official, it can be stated that there are no dues from the Respondent to the Appellant at this stage, in view of the finalization of the resolution plan. If that be so, we are of the view that there is no live issue for adjudication by this Court in the present matters. 3. The appeals are accordingly, disposed of. (ADVAIT M. SETHNA, J.) (SUMAN SHYAM, J.) {