DCIT v. Syncame Formulations (I) Ltd.

108 TTJ 105Income Tax Appellate Tribunal#6621 most cited
17

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2022 to 2025.

Sections most often in play

Section 10(38)Section 115JBSection 139(5)Section 147Section 148Section 14ASection 153ASection 37

Issues it is cited on

section 80hhc(3)section 42section 115jasection 80hhcsection 80hhsection 139(5)section 14a(2)section 24(a)book profitssection 80hsection 10(38)section 145a

Judgments citing DCIT v. Syncame Formulations (I) Ltd.

M/S GUJARAT GUARDIAN LTD.,,NEW DELHI vs. DCIT,, NEW DELHI

ITA 2539/DEL/2017[2005-06]Status: DisposedITAT Delhi16 Jul 2025AY 2005-06

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

For Appellant: Shri Ajay Vohra, Sr. A.RFor Respondent: Shri Bhopal Singh, Sr. D.R
Section 92C

…xman 236 (Mad) – CIT v. G.T.N. Textiles Limited: 248 ITR 372 (Ker) – CIT v. C. P. S. Textiles (P.) Ltd.: 340 ITR 590 (Mad) – CIT v. K.G. Denim Ltd.: 180 Taxman 590 (Mad) – CIT v. Hindustan Aeronautics Ltd.: 203 Taxman 449 (Kar) – Syncome Formulation (I) Ltd.: 108 TTJ 105 (Mum) (SB) – JT. CIT v. Kanco Enterprises Ltd.: 156 ITD 926 (Kol) – Kothari Products Ltd. v. DCIT: ITA Nos.210, 306, 348 & 408/LKW/2012 (Lucknow) – The Indian Smelting and Refining Company Ltd. v. ACIT: ITA Nos.2942 and 2941/Mum/2012 (Mum) – Wheels India Ltd., Chennai V. Assessee: ITA No.1430/Mds/2010 (Chen) – N.W. Export Limited v ITO: ITA No. 3…

GUJARAT GUARDIAN LTD.,,NEW DELHI vs. DCIT, NEW DELHI

ITA 159/DEL/2010[2003-04]Status: DisposedITAT Delhi16 Jul 2025AY 2003-04

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

Section 92C

…d.: 198 Taxman 236 (Mad) CIT v. G.T.N. Textiles Limited: 248 ITR 372 (Ker) CIT v. C. P. S. Textiles (P.) Ltd.: 340 ITR 590 (Mad) CIT v. K.G. Denim Ltd.: 180 Taxman 590 (Mad) CIT v. Hindustan Aeronautics Ltd.: 203 Taxman 449 (Kar) Syncome Formulation (I) Ltd.: 108 TTJ 105 (Mum) (SB) JT. CIT v. Kanco Enterprises Ltd.: 156 ITD 926 (Kol) Kothari Products Ltd. v. DCIT: ITA Nos.210, 306, 348 & 408/LKW/2012 (Lucknow) The Indian Smelting and Refining Company Ltd. v. ACIT: ITA Nos.2942 and 2941/Mum/2012 (Mum) Wheels India Ltd., Chennai V. Assessee: ITA No.1430/Mds/2010 (Chen) N.W. Export Limited v ITO: ITA No. 3123/Mum/20…

DCIT, NEW DELHI vs. M/S. ULFEX LTD., NEW DELHI

ITA 2811/DEL/2017[2009-10]Status: DisposedITAT Delhi26 Jul 2024AY 2009-10

Bench: Shri G.S Pannu, Hon’Ble & Shri Vimal Kumar

For Appellant: Shri M.P. Rastogi, AdvocateFor Respondent: Ms. Sarita Kumari, CIT-DR
Section 115JSection 37Section 43B

…The proceedings under section 153A is comparable to the provision of section 147/148 of Income Tax Act. The assessee has claimed the deduction at an enhanced amount as per judgment of special Bench of ITAT in DCIT vs. Syncame Formulations (I) Ltd reported as 108 TTJ 105. Hon’ble Supreme Court of India in Ajanta Pharma has observed that the provision of Sections 80HHC and 115JB of IT Act operate in different spheres. 6. Learned representative for the appellant/assessee submitted that in the following cases, once proceedings are abated and return is filed under section 153A and return is filed under section 153A,…

DCIT, NEW DELHI vs. M/S. ULFEX LTD., NEW DELHI

ITA 2810/DEL/2017[2008-09]Status: DisposedITAT Delhi26 Jul 2024AY 2008-09

Bench: Shri G.S Pannu, Hon’Ble & Shri Vimal Kumar

For Appellant: Shri M.P. Rastogi, AdvocateFor Respondent: Ms. Sarita Kumari, CIT-DR
Section 115JSection 37Section 43B

…The proceedings under section 153A is comparable to the provision of section 147/148 of Income Tax Act. The assessee has claimed the deduction at an enhanced amount as per judgment of special Bench of ITAT in DCIT vs. Syncame Formulations (I) Ltd reported as 108 TTJ 105. Hon’ble Supreme Court of India in Ajanta Pharma has observed that the provision of Sections 80HHC and 115JB of IT Act operate in different spheres. 6. Learned representative for the appellant/assessee submitted that in the following cases, once proceedings are abated and return is filed under section 153A and return is filed under section 153A,…

DCIT, NEW DELHI vs. M/S. ULFEX LTD., NEW DELHI

ITA 2809/DEL/2017[2007-08]Status: DisposedITAT Delhi26 Jul 2024AY 2007-08

Bench: Shri G.S Pannu, Hon’Ble & Shri Vimal Kumar

For Appellant: Shri M.P. Rastogi, AdvocateFor Respondent: Ms. Sarita Kumari, CIT-DR
Section 115JSection 37Section 43B

…The proceedings under section 153A is comparable to the provision of section 147/148 of Income Tax Act. The assessee has claimed the deduction at an enhanced amount as per judgment of special Bench of ITAT in DCIT vs. Syncame Formulations (I) Ltd reported as 108 TTJ 105. Hon’ble Supreme Court of India in Ajanta Pharma has observed that the provision of Sections 80HHC and 115JB of IT Act operate in different spheres. 6. Learned representative for the appellant/assessee submitted that in the following cases, once proceedings are abated and return is filed under section 153A and return is filed under section 153A,…

DCIT, NEW DELHI vs. M/S. ULFEX LTD., NEW DELHI

ITA 2808/DEL/2017[2006-07]Status: DisposedITAT Delhi26 Jul 2024AY 2006-07

Bench: Shri G.S Pannu, Hon’Ble & Shri Vimal Kumar

For Appellant: Shri M.P. Rastogi, AdvocateFor Respondent: Ms. Sarita Kumari, CIT-DR
Section 115JSection 37Section 43B

…The proceedings under section 153A is comparable to the provision of section 147/148 of Income Tax Act. The assessee has claimed the deduction at an enhanced amount as per judgment of special Bench of ITAT in DCIT vs. Syncame Formulations (I) Ltd reported as 108 TTJ 105. Hon’ble Supreme Court of India in Ajanta Pharma has observed that the provision of Sections 80HHC and 115JB of IT Act operate in different spheres. 6. Learned representative for the appellant/assessee submitted that in the following cases, once proceedings are abated and return is filed under section 153A and return is filed under section 153A,…

DCIT, NEW DELHI vs. M/S. ULFEX LTD., NEW DELHI

ITA 2807/DEL/2017[2005-06]Status: DisposedITAT Delhi26 Jul 2024AY 2005-06

Bench: Shri G.S Pannu, Hon’Ble & Shri Vimal Kumar

For Appellant: Shri M.P. Rastogi, AdvocateFor Respondent: Ms. Sarita Kumari, CIT-DR
Section 115JSection 37Section 43B

…The proceedings under section 153A is comparable to the provision of section 147/148 of Income Tax Act. The assessee has claimed the deduction at an enhanced amount as per judgment of special Bench of ITAT in DCIT vs. Syncame Formulations (I) Ltd reported as 108 TTJ 105. Hon’ble Supreme Court of India in Ajanta Pharma has observed that the provision of Sections 80HHC and 115JB of IT Act operate in different spheres. 6. Learned representative for the appellant/assessee submitted that in the following cases, once proceedings are abated and return is filed under section 153A and return is filed under section 153A,…

DCIT, NEW DELHI vs. M/S. ULFEX LTD., NEW DELHI

ITA 2806/DEL/2017[2004-05]Status: DisposedITAT Delhi26 Jul 2024AY 2004-05

Bench: Shri G.S Pannu, Hon’Ble & Shri Vimal Kumar

For Appellant: Shri M.P. Rastogi, AdvocateFor Respondent: Ms. Sarita Kumari, CIT-DR
Section 115JSection 37Section 43B

…The proceedings under section 153A is comparable to the provision of section 147/148 of Income Tax Act. The assessee has claimed the deduction at an enhanced amount as per judgment of special Bench of ITAT in DCIT vs. Syncame Formulations (I) Ltd reported as 108 TTJ 105. Hon’ble Supreme Court of India in Ajanta Pharma has observed that the provision of Sections 80HHC and 115JB of IT Act operate in different spheres. 6. Learned representative for the appellant/assessee submitted that in the following cases, once proceedings are abated and return is filed under section 153A and return is filed under section 153A,…

UFLEX LTD.,,NEW DELHI vs. ACIT,, NEW DELHI

ITA 1732/DEL/2017[2009-10]Status: DisposedITAT Delhi26 Jul 2024AY 2009-10

Bench: Shri G.S Pannu, Hon’Ble & Shri Vimal Kumar

For Appellant: Shri M.P. Rastogi, AdvocateFor Respondent: Ms. Sarita Kumari, CIT-DR
Section 115JSection 37Section 43B

…The proceedings under section 153A is comparable to the provision of section 147/148 of Income Tax Act. The assessee has claimed the deduction at an enhanced amount as per judgment of special Bench of ITAT in DCIT vs. Syncame Formulations (I) Ltd reported as 108 TTJ 105. Hon’ble Supreme Court of India in Ajanta Pharma has observed that the provision of Sections 80HHC and 115JB of IT Act operate in different spheres. 6. Learned representative for the appellant/assessee submitted that in the following cases, once proceedings are abated and return is filed under section 153A and return is filed under section 153A,…

UFLEX LTD.,,NEW DELHI vs. ACIT,, NEW DELHI

ITA 1731/DEL/2017[2008-09]Status: DisposedITAT Delhi26 Jul 2024AY 2008-09

Bench: Shri G.S Pannu, Hon’Ble & Shri Vimal Kumar

For Appellant: Shri M.P. Rastogi, AdvocateFor Respondent: Ms. Sarita Kumari, CIT-DR
Section 115JSection 37Section 43B

…The proceedings under section 153A is comparable to the provision of section 147/148 of Income Tax Act. The assessee has claimed the deduction at an enhanced amount as per judgment of special Bench of ITAT in DCIT vs. Syncame Formulations (I) Ltd reported as 108 TTJ 105. Hon’ble Supreme Court of India in Ajanta Pharma has observed that the provision of Sections 80HHC and 115JB of IT Act operate in different spheres. 6. Learned representative for the appellant/assessee submitted that in the following cases, once proceedings are abated and return is filed under section 153A and return is filed under section 153A,…

UFLEX LTD.,,NEW DELHI vs. ACIT,, NEW DELHI

ITA 1730/DEL/2017[2007-08]Status: DisposedITAT Delhi26 Jul 2024AY 2007-08

Bench: Shri G.S Pannu, Hon’Ble & Shri Vimal Kumar

For Appellant: Shri M.P. Rastogi, AdvocateFor Respondent: Ms. Sarita Kumari, CIT-DR
Section 115JSection 37Section 43B

…The proceedings under section 153A is comparable to the provision of section 147/148 of Income Tax Act. The assessee has claimed the deduction at an enhanced amount as per judgment of special Bench of ITAT in DCIT vs. Syncame Formulations (I) Ltd reported as 108 TTJ 105. Hon’ble Supreme Court of India in Ajanta Pharma has observed that the provision of Sections 80HHC and 115JB of IT Act operate in different spheres. 6. Learned representative for the appellant/assessee submitted that in the following cases, once proceedings are abated and return is filed under section 153A and return is filed under section 153A,…

UFLEX LTD.,,NEW DELHI vs. ACIT,, NEW DELHI

ITA 1729/DEL/2017[2006-07]Status: DisposedITAT Delhi26 Jul 2024AY 2006-07

Bench: Shri G.S Pannu, Hon’Ble & Shri Vimal Kumar

For Appellant: Shri M.P. Rastogi, AdvocateFor Respondent: Ms. Sarita Kumari, CIT-DR
Section 115JSection 37Section 43B

…The proceedings under section 153A is comparable to the provision of section 147/148 of Income Tax Act. The assessee has claimed the deduction at an enhanced amount as per judgment of special Bench of ITAT in DCIT vs. Syncame Formulations (I) Ltd reported as 108 TTJ 105. Hon’ble Supreme Court of India in Ajanta Pharma has observed that the provision of Sections 80HHC and 115JB of IT Act operate in different spheres. 6. Learned representative for the appellant/assessee submitted that in the following cases, once proceedings are abated and return is filed under section 153A and return is filed under section 153A,…

UFLEX LTD.,,NEW DELHI vs. ACIT,, NEW DELHI

ITA 1728/DEL/2017[2005-06]Status: DisposedITAT Delhi26 Jul 2024AY 2005-06

Bench: Shri G.S Pannu, Hon’Ble & Shri Vimal Kumar

For Appellant: Shri M.P. Rastogi, AdvocateFor Respondent: Ms. Sarita Kumari, CIT-DR
Section 115JSection 37Section 43B

…The proceedings under section 153A is comparable to the provision of section 147/148 of Income Tax Act. The assessee has claimed the deduction at an enhanced amount as per judgment of special Bench of ITAT in DCIT vs. Syncame Formulations (I) Ltd reported as 108 TTJ 105. Hon’ble Supreme Court of India in Ajanta Pharma has observed that the provision of Sections 80HHC and 115JB of IT Act operate in different spheres. 6. Learned representative for the appellant/assessee submitted that in the following cases, once proceedings are abated and return is filed under section 153A and return is filed under section 153A,…

UFLEX LTD.,,NEW DELHI vs. ACIT,, NEW DELHI

ITA 1727/DEL/2017[2004-05]Status: DisposedITAT Delhi26 Jul 2024AY 2004-05

Bench: Shri G.S Pannu, Hon’Ble & Shri Vimal Kumar

For Appellant: Shri M.P. Rastogi, AdvocateFor Respondent: Ms. Sarita Kumari, CIT-DR
Section 115JSection 37Section 43B

…The proceedings under section 153A is comparable to the provision of section 147/148 of Income Tax Act. The assessee has claimed the deduction at an enhanced amount as per judgment of special Bench of ITAT in DCIT vs. Syncame Formulations (I) Ltd reported as 108 TTJ 105. Hon’ble Supreme Court of India in Ajanta Pharma has observed that the provision of Sections 80HHC and 115JB of IT Act operate in different spheres. 6. Learned representative for the appellant/assessee submitted that in the following cases, once proceedings are abated and return is filed under section 153A and return is filed under section 153A,…

ADDL CIT RG 7(1), MUMBAI vs. PIRAMAL ENTERPRISES LTD (FORMERLY KNWON AS PIRAMAL HEALTHCARE LTD) (AS ULTIMATE SUCCESSOR TO NICHOLAS PIRAMAL INDIA LTD), MUMBAI

ITA 5091/MUM/2010[2005-06]Status: DisposedITAT Mumbai11 Jan 2024AY 2005-06

Bench: Shri Kuldip Singh & Shri S Rifaur Rahmanassessment Year: 2005-06 M/S. Piramal Enterprises Dy. Commissioner Of Limited (Formerly Known Income Tax, As Piramal Healthcare Range-8(2)(1), Limited) (Earlier Known As Mumbai. Nicholas Piramal India Ltd.), Vs. Piramal Tower, Agastya Corporate Park, Lbs Marg, Kamani Junction, Kurla (West), Mumbai – 400 070 Pan: Aaacn4538P (Appellant) (Respondent) Assessment Year: 2005-06 Dy. Commissioner Of M/S. Piramal Enterprises Income Tax, Limited (Formerly Known Circle-8(2)(1), As Piramal Healthcare [Erstwhile Dcit Circle- Ltd.) (As Ultimate 7(1)], Successor To Nicholas Vs. Mumbai. Piramal India Ltd.), Piramal Tower, Ganpatrao Kadam Marg, Lower Parel, Mumbai – 400 013 Pan: Aaacn4538P (Appellant) (Respondent)

For Appellant: Shri Priyank Gala, A.RFor Respondent: Shri P.D. Chogule, (Addl. CIT) Sr. A.R
Section 28Section 40Section 45

…and in law, the Ld.CIT(A) erred in deciding that the deduction u/s.80HHC for the purpose of section 115JB is to be worked out on the basis of adjusted book profit following the decision of Mumbai ITAT in the case of Syncome Formulations India Ltd. reported in 108 TTJ 105 (SB) although the ITAT's decision has been overruled by the Bombay High Court in the case of Ajanta Pharma Ltd. 180 Taxman 494. 6. The appellant prays that the order of CIT(A) on the above grounds be set aside and that of the AO restored. The appellant craves leave to amend or alter any ground or add a new ground that may be necessary.” ITA No.3…

PIRAMAL HEALTHCARE LTD ( EARLIER KNOWNAS NICHOLAS PIRAMAL INDIA LTD),MUMBAI vs. ADDL CIT 7(1), MUMBAI

ITA 3706/MUM/2010[2005-06]Status: DisposedITAT Mumbai11 Jan 2024AY 2005-06

Bench: Shri Kuldip Singh & Shri S Rifaur Rahmanassessment Year: 2005-06 M/S. Piramal Enterprises Dy. Commissioner Of Limited (Formerly Known Income Tax, As Piramal Healthcare Range-8(2)(1), Limited) (Earlier Known As Mumbai. Nicholas Piramal India Ltd.), Vs. Piramal Tower, Agastya Corporate Park, Lbs Marg, Kamani Junction, Kurla (West), Mumbai – 400 070 Pan: Aaacn4538P (Appellant) (Respondent) Assessment Year: 2005-06 Dy. Commissioner Of M/S. Piramal Enterprises Income Tax, Limited (Formerly Known Circle-8(2)(1), As Piramal Healthcare [Erstwhile Dcit Circle- Ltd.) (As Ultimate 7(1)], Successor To Nicholas Vs. Mumbai. Piramal India Ltd.), Piramal Tower, Ganpatrao Kadam Marg, Lower Parel, Mumbai – 400 013 Pan: Aaacn4538P (Appellant) (Respondent)

For Appellant: Shri Priyank Gala, A.RFor Respondent: Shri P.D. Chogule, (Addl. CIT) Sr. A.R
Section 28Section 40Section 45

…and in law, the Ld.CIT(A) erred in deciding that the deduction u/s.80HHC for the purpose of section 115JB is to be worked out on the basis of adjusted book profit following the decision of Mumbai ITAT in the case of Syncome Formulations India Ltd. reported in 108 TTJ 105 (SB) although the ITAT's decision has been overruled by the Bombay High Court in the case of Ajanta Pharma Ltd. 180 Taxman 494. 6. The appellant prays that the order of CIT(A) on the above grounds be set aside and that of the AO restored. The appellant craves leave to amend or alter any ground or add a new ground that may be necessary.” ITA No.3…

M/S. NICHOLAS PIRAMAL INDIA LTD,MUMBAI vs. THE ACIT CUR 7(1),

In the result, the appeal filed by the revenue is dismissed and the appeal filed by the assessee is partly allowed for statistical purposes

ITA 769/MUM/2008[2004-2005]Status: DisposedITAT Mumbai28 Jun 2022AY 2004-2005

Bench: Shri Pavan Kumar Gadale & Shri S Rifaur Rahmanpiramal Enterprises Ltd Vs. Acit, Circle – 7(1) (Formerly Known As Aayakar Bhavan Piramal Healthcare Ltd) Mumbai – 400020. (Before Known As Nicholas Piramal Ind) Piramal Tower, Ganpatrao Kadam Marg, Lower Parel, Mumbai – 400013. Pan/Gir No. : Aaacn4538P Appellant .. Respondent Dcit, Circle – 7(1) Vs. Piramal Enterprises Ltd Aayakar Bhyavan (Formerly Known As Mumbai – 400 020. Piramal Healthcare Ltd) (Before Known As Nicholas Piramal Ind) Piramal Tower, Ganpatrao Kadam Marg, Lower Parel, Mumbai – 400 013. Pan/Gir No. : Aaacn4538P Assessee By : Mr.Ronak Doshi & Ms.Manshi Padhiyar.Ar Revenue By : Mr.S.N.Kabra.Dr

For Appellant: Mr.Ronak Doshi &For Respondent: Mr.S.N.Kabra.DR
Section 143(3)Section 145Section 32Section 35Section 80

…115JB of the Act. The CIT(A) has dealt at page 37 Para 13 as under: My predecessor had decided the similar issue in earlier year A.Y. 2003-04 wherein he had followed the decision of the Special Bench in case of Syncome Formulations India Limited and others (108 TTJ 105) (MUM) (SB) and has directed the AO to deduct profits eligible u/s 80HHC and not the deduction u/s 80HHC from book profit for the calculation of book profit u/s 115JB of the Act. Following appellate order for the earlier year, I allow this ground of Appeal. 20. Further we find that in the assessee’s own case for the A.Y 2003-04, the Hon’ble Tribu…