Synco Industries Ltd. v. Assessing Officer (IT) & Another

299 ITR 444Supreme Court of India2008#1400 most cited

What is Synco Industries Ltd. v. Assessing Officer (IT) & Another authority for?

When computing deductions under Chapter VI-A, such as Section 80IA, losses from other business undertakings must be set off against the profits of the eligible undertaking before calculating the deduction. No deduction under Section 80IA is permissible if the overall 'Profits & Gains of Business or Profession' results in a loss.

82

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2010 to 2025.

Also referred to as

Synco Industries · Section 80IA · Section 80AB · Section 80A(2) · set off of losses · eligible undertaking profits · gross total income · Chapter VI-A deductions · inter-unit loss adjustment · business income computation · 299 ITR 444

Sections most often in play

Section 115JBSection 115PSection 143(1)Section 143(3)Section 14ASection 80ABSection 80IASection 8D

Issues it is cited on

section 80abinitial assessment yearsection 80aeligible businesstax benefitsection 80hhcdeduction under section 80iasection 80iasection 80hhsection 80ibgross total incomeunabsorbed depreciation

Judgments citing Synco Industries Ltd. v. Assessing Officer (IT) & Another

ACIT-2(1)(1), MUMBAI vs. GEECEE VENTURES LIMITED, MUMBAI

The appeal is allowed for statistical purposes

ITA 4119/MUM/2024[2018-19]Status: DisposedITAT Mumbai30 May 2025AY 2018-19

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Rahul SardaFor Respondent: Shri Bhangepatil Pushkaraj Ramesh
Section 143Section 143(1)Section 143(3)Section 14ASection 250Section 80I

…ess or Profession’ during the relevant previous year. Reliance in this regard, was placed by the Learned Departmental Representative on the judgment of Hon’ble Supreme Court in the case of Synco Industries Ltd. Vs. Assessing Officer, Income-tax, Mumbai [2008] 299 ITR 444(SC), dated 13/02/2008. Further, it was submitted by the Learned Departmental Representative, on a without prejudice basis, that since the computation under the head ‘Profits & Gains of Business or Profession’ had resulted into a loss, it cannot be said that the income of eligible undertaking was included in the Gross Total Income of the Assessee.…

GEECEE VENTURES LIMITED ,MUMBAI vs. DCIT, CIRCLE 2(1)(1), MUMBAI

The appeal is allowed for statistical purposes

ITA 3975/MUM/2024[2018-19]Status: DisposedITAT Mumbai30 May 2025AY 2018-19

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Rahul SardaFor Respondent: Shri Bhangepatil Pushkaraj Ramesh
Section 143Section 143(1)Section 143(3)Section 14ASection 250Section 80I

…ess or Profession’ during the relevant previous year. Reliance in this regard, was placed by the Learned Departmental Representative on the judgment of Hon’ble Supreme Court in the case of Synco Industries Ltd. Vs. Assessing Officer, Income-tax, Mumbai [2008] 299 ITR 444(SC), dated 13/02/2008. Further, it was submitted by the Learned Departmental Representative, on a without prejudice basis, that since the computation under the head ‘Profits & Gains of Business or Profession’ had resulted into a loss, it cannot be said that the income of eligible undertaking was included in the Gross Total Income of the Assessee.…

MEDLEY PHARMACEUTICALS LTD.,MUMBAI vs. DY.C.I.T., CENT.CIR.44, MUMBAI

In the result, the captioned appeals filed by the assessee are allowed

ITA 1387/MUM/2009[2002-2003]Status: DisposedITAT Mumbai09 Dec 2024AY 2002-2003

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri Ravi Sawana, Adv., Ms. Neha Sharma & Shri Apurva Chudhry, A/RFor Respondent: Shri Kailash C. Kanojiya, CIT, D/R
Section 80I

…the Hon’ble Delhi High Court in the case of CIT vs. Dewan Kraft System (P.) Ltd. in 297 ITR 305 (Delhi). The ld. CIT(A) was of the opinion that the decision of the Hon’ble Supreme Court in the case of Synco Industries Limited vs. AO, Income tax, Mumbai (2008) 299 ITR 444 (SC), squarely applies on the facts of the case in hand wherein the Hon’ble Supreme Court has emphatically ruled that the assessee’s contention that the profits derived from one industrial undertaking cannot be set off against the loss suffered from another industrial undertaking in view of Section 80-I(6) has no merits. The ld. CIT(A) observed t…

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1) AHMEDABAD, AHMEDABAD vs. RAJKAMAL BUILDERS INFRASTRUCTURE PRIVATE LIMITED, AHMEDABAD

ITA 1467/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad28 Oct 2024AY 2018-19

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.1466/Ahd/2024 & 1467/Ahd/2024 िनधा"रण वष" /Assessment Years : 2017-18 & 2018-19 Respectively The Acit Rajkamal Builders बनाम/ Circle-3(1)(1) Infrastrucutre Pvt.Ltd. V/S. Ahmedabad – 380 015 54, Park Hill Nr.Heaven Park Ramdevnagar, Ahmedabad (Gujarat) – 380 015 "थायी लेखा सं./Pan: Aabcr 0326 A अपीलाथ%/ (Appellant) &' यथ%/ (Respondent) Assessee By : Shri Mehul K. Patel, Ar Revenue By : Shri Ritesh Parmar, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 25/10/2024 घोषणा की तारीख /Date Of Pronouncement: /10/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

For Appellant: Shri Mehul K. Patel, ARFor Respondent: Shri Ritesh Parmar, CIT-DR
Section 143(3)Section 144BSection 80I

…total income. The CIT(A) relied on the decision of the Co-ordinate Bench in assessee’s own case of earlier year. The Co-ordinate Bench relied on the judicial precedent set by the Supreme Court in the case of Synco Industries Ltd. v. Assessing Officer [(2008) 299 ITR 444 (SC)], where it was held that losses must indeed be set off against profits when computing the deduction under Section 80A(2) of the ITA Nos.1466 & 1467/Ahd/2024 ACIT vs. Rajkamal Builders Infrastructure Pvt.Ltd. Asst. Years : 2017-18 & 2018-19 respectively 14 Act. Since the overall profits remained positive even after adjusting for these losse…

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1) AHMEDABAD, AHMEDABAD vs. RAJKAMAL BUILDERS INFRASTRUCTURE PRIVATE LIMITED, AHMEDABAD

ITA 1466/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad28 Oct 2024AY 2017-18

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.1466/Ahd/2024 & 1467/Ahd/2024 िनधा"रण वष" /Assessment Years : 2017-18 & 2018-19 Respectively The Acit Rajkamal Builders बनाम/ Circle-3(1)(1) Infrastrucutre Pvt.Ltd. V/S. Ahmedabad – 380 015 54, Park Hill Nr.Heaven Park Ramdevnagar, Ahmedabad (Gujarat) – 380 015 "थायी लेखा सं./Pan: Aabcr 0326 A अपीलाथ%/ (Appellant) &' यथ%/ (Respondent) Assessee By : Shri Mehul K. Patel, Ar Revenue By : Shri Ritesh Parmar, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 25/10/2024 घोषणा की तारीख /Date Of Pronouncement: /10/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

For Appellant: Shri Mehul K. Patel, ARFor Respondent: Shri Ritesh Parmar, CIT-DR
Section 143(3)Section 144BSection 80I

…total income. The CIT(A) relied on the decision of the Co-ordinate Bench in assessee’s own case of earlier year. The Co-ordinate Bench relied on the judicial precedent set by the Supreme Court in the case of Synco Industries Ltd. v. Assessing Officer [(2008) 299 ITR 444 (SC)], where it was held that losses must indeed be set off against profits when computing the deduction under Section 80A(2) of the ITA Nos.1466 & 1467/Ahd/2024 ACIT vs. Rajkamal Builders Infrastructure Pvt.Ltd. Asst. Years : 2017-18 & 2018-19 respectively 14 Act. Since the overall profits remained positive even after adjusting for these losse…

PR. COMMISSIONER OF INCOME TAX -7 vs. PRAGATI POWER CORPORATION LTD.

ITA/469/2024HC Delhi30 Aug 2024

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE RAVINDER DUDEJA

Section 80Section 80A

…t submitted that the question of adjustment / setting off of the loss of one unit as against the profit of the other unit stands covered by the decision of the Supreme Court in the case of Synco Industries Ltd v. Assessing Officer (Income-tax) and Another: 299 ITR 444 (SC). The learned counsel for the appellant, however, fairly submitted that there is a decision of a Division Bench of this court in the case of Commissioner of Income-tax v. Dewan Kraft Systems P. Ltd: 297 ITA Nos. 1279/08, 194/09, 416/09, 761/ 09 & 788/ 09 Page No.4 of 11 ITR 305 (Delhi) which has considered the pari materia provisions of…

PR. COMMISSIONER OF INCOME TAX -7 vs. PRAGATI POWER CORPORATION LTD.

ITA - 469 / 2024HC Delhi30 Aug 2024
Section 80Section 80A

…t submitted that the question of adjustment / setting off of the loss of one unit as against the profit of the other unit stands covered by the decision of the Supreme Court in the case of Synco Industries Ltd v. Assessing Officer (Income-tax) and Another: 299 ITR 444 (SC). The learned counsel for the appellant, however, fairly submitted that there is a decision of a Division Bench of this court in the case of Commissioner of Income-tax v. Dewan Kraft Systems P. Ltd: 297 ITA Nos. 1279/08, 194/09, 416/09, 761/ 09 & 788/ 09 Page No.4 of 11 ITR 305 (Delhi) which has considered the pari materia provisions of…

PRAGATI POWER CORPORATION LTD.,NEW DELHI vs. ACIT, CIRCLE-20(1), NEW DELHI

ITA 1168/DEL/2018[2013-14]Status: DisposedITAT Delhi05 Jan 2024AY 2013-14

Bench: Sh. C. N. Prasaddr. B. R. R. Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Sh. P. N. Barnwal, CIT-DR
Section 35Section 40Section 43BSection 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH `F', NEW DELHI Before Sh. C. N. Prasad, Judicial Member Dr. B. R. R. Kumar, Accountant Member ITA No. 1168/Del/2018 : Asstt. Year: 2013-14 Pragati Power Corporation Ltd., Himadari, Rajghat Power House Office Complex, Rajghat, New Delhi-110002 (APPELLANT) Vs ACIT, Circle-20(1), New Delhi (RESPONDENT) PAN No. AACCP8035F Assessee by : Sh. Ved Jain, Adv. & Ms. Supriya Mehta, CA Revenue by : Sh. P. N. Barnwal, CIT-DR Date of Hearing: 03.01.2024 Date of Pronouncement: 05.01.2024 ORDER Per Dr. B. R. R. Kumar, Accountant Member: The present appeal has been filed by the ass…

HINDUSTAN UNILEVER LTD,MUMBAI vs. ITO CIR 1(1)(4), MUMBAI

In the result, both the appeal of the assessee and the revenue are partly allowed

ITA 5431/MUM/2011[2001-02]Status: DisposedITAT Mumbai18 Aug 2023AY 2001-02

Bench: Shri Vikas Awasthy () & Ms. Padmavathy S. ()

Section 10BSection 80HSection 80I

…ing both the parties, we find that this issue is also covered by the decision of Tribunal in assessment year 1988-89 (supra). In that year, the Revenue had relied on the judgment of Hon'ble Supreme Court in case of Synco Industries Ltd. vs. Assessing Officer (299 ITR 444), to argue that the brought forward losses and unabsorbed depreciation have to be adjusted before allowing claim of deduction u/s 80HH & 80I. The Tribunal distinguished the said case on the ground that brought forward losses/depreciation of the new unit had already been set off against other income of the assessee and nothing was brought forward…

M/S. ACIT 1(1), MUMBAI vs. THE HINDUSTAN UNILEVER LTD, MUMBAI

In the result, the appeal of the assesse is partly allowed and the appeal of the revenue stand dismissed

ITA 4033/MUM/2008[2000-2001]Status: DisposedITAT Mumbai16 May 2023AY 2000-2001

Bench: Shri Vikas Awasthy & Shri Amarjit Singhm/S Hindustan Unilever Vs. Addl. Commissioner Of Ltd., Hindustan Lever Income Tax, Range 1(1) House, 165/166 Backbay Mumbai Reclamation Mumbai – 400 020 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaach1004N Appellant .. Respondent Acit-1(1), Vs. M/S Hindustan Unilever Room No. 579, Ltd., 165/166, Backbay Aayakar Bhavan, Reclamation Mumbai – 400 020 Mumbai – 400 020 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaach1004N Appellant .. Respondent Appellant By : Nishant Thakkar & Ms. Jasmin Amalsadvala Respondent By : Chandip Singh Date Of Hearing 09.03.2023 Date Of Pronouncement 16.05.2023 आदेश / O R D E R Per Amarjit Singh (Am): Both These Appeals Filed By The Assesse & The Revenue Are Pertained To Assessment Year 2000-01 Based On Similar Fact & P A G E | 2

For Appellant: Nishant Thakkar &For Respondent: Chandip Singh
Section 80Section 80ASection 80H

…ing both the parties, we find that this issue is also covered by the decision of Tribunal in assessment year 1988-89 (supra). In that year, the Revenue had relied on the judgment of Hon'ble Supreme Court in case of Synco Industries Ltd. vs. Assessing Officer (299 ITR 444), to argue that the brought forward losses and unabsorbed depreciation have to be adjusted before allowing claim of deduction u/s 80HH & 80I. The Tribunal distinguished the said case on the ground that brought forward losses/depreciation of the new unit had already been set off against other income of the assessee and nothing was brought forward…

M/S. HINDUSTAN UNILEVER LTD,MUMBAI vs. THE ACIT (TDS)-1(1), MUMBAI

In the result, the appeal of the assesse is partly allowed and the appeal of the revenue stand dismissed

ITA 3951/MUM/2008[2000-2001]Status: DisposedITAT Mumbai16 May 2023AY 2000-2001

Bench: Shri Vikas Awasthy & Shri Amarjit Singhm/S Hindustan Unilever Vs. Addl. Commissioner Of Ltd., Hindustan Lever Income Tax, Range 1(1) House, 165/166 Backbay Mumbai Reclamation Mumbai – 400 020 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaach1004N Appellant .. Respondent Acit-1(1), Vs. M/S Hindustan Unilever Room No. 579, Ltd., 165/166, Backbay Aayakar Bhavan, Reclamation Mumbai – 400 020 Mumbai – 400 020 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaach1004N Appellant .. Respondent Appellant By : Nishant Thakkar & Ms. Jasmin Amalsadvala Respondent By : Chandip Singh Date Of Hearing 09.03.2023 Date Of Pronouncement 16.05.2023 आदेश / O R D E R Per Amarjit Singh (Am): Both These Appeals Filed By The Assesse & The Revenue Are Pertained To Assessment Year 2000-01 Based On Similar Fact & P A G E | 2

For Appellant: Nishant Thakkar &For Respondent: Chandip Singh
Section 80Section 80ASection 80H

…ing both the parties, we find that this issue is also covered by the decision of Tribunal in assessment year 1988-89 (supra). In that year, the Revenue had relied on the judgment of Hon'ble Supreme Court in case of Synco Industries Ltd. vs. Assessing Officer (299 ITR 444), to argue that the brought forward losses and unabsorbed depreciation have to be adjusted before allowing claim of deduction u/s 80HH & 80I. The Tribunal distinguished the said case on the ground that brought forward losses/depreciation of the new unit had already been set off against other income of the assessee and nothing was brought forward…

M/S. HINDUSTAN LEVER LTD vs. THE DY CIT 1(1),

ITA 1039/MUM/2005[1999-2000]Status: DisposedITAT Mumbai02 Dec 2022AY 1999-2000
For Appellant: Shri Nishant Thakkar &For Respondent: Shri Sandeep Raj
Section 143(3)Section 80Section 80HSection 80I

…ing both the parties, we find that this issue is also covered by the decision of Tribunal in assessment year 1988-89 (supra). In that year, the Revenue had relied on the judgment of Hon'ble Supreme Court in case of Synco Industries Ltd. vs. Assessing Officer (299 ITR 444), to argue that the brought forward losses and unabsorbed depreciation have to be adjusted before allowing claim of deduction u/s 80HH & 80I. The Tribunal distinguished the said case on the ground that brought forward losses/depreciation of the new unit had already been set off against other income of the assessee and nothing was brought forward…

M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD.,,AHMEDABAD vs. THE DCIT., CIRCLE-3(1)(2),, AHMEDABAD

In the result, assessee’s appeal is partly allowed

ITA 417/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad10 Oct 2022AY 2014-15

Bench: Shri Pramod M. Jagtap & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 417/Ahd/2018 ("नधा"रण वष" / Assessment Year : 2014-15) M/S. Rajkamal Builders The D.C.I.T. बनाम/ Infrastructure Pvt. Ltd. Circle – 3(1)(2), Vs. Ahmedabad 54, Park Hill Society, Opp: Karnavati Club Nr. Heaven Park, Ramdevnagar, Ahmedabad "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabcr0326A .. (अपीलाथ" /Appellant) (""यथ" / Respondent) Shri Mehul K. Patel, Advocate अपीलाथ" ओर से /Appellant By : ""यथ" क" ओर से/Respondent By : Shri Vijay Kumar Jaiswal, Cit. D.R. सुनवाई क" तार"ख / Date Of 13/07/2022 Hearing घोषणा क" तार"ख /Date Of 10/10/2022 Pronouncement O R D E R Per Ms. Madhumita Roy - Jm: The Instant Appeal Filed By The Assessee Is Directed Against The Order Dated 20.12.2017 Passed By The Ld. Commissioner Of Income Tax (Appeals) – 9, Ahmedabad Arising Out Of The Order Dated 17.10.2016 Passed By The Dcit, Circle-3(1)(2), Ahmedabad Under Section 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred As To ‘The Act’) For Assessment Year 2014-15, Whereby & Whereunder Mainly The Claim Under Section 80Ia(4) Of The Act Made By The

For Respondent: Shri Vijay Kumar Jaiswal, CIT. D.R
Section 143(3)Section 234ASection 36(1)Section 80Section 80I

…off loss from 8 sites aggregating Rs.67,23,899/-. As per the provisions of Section 80A(2) r.w. section 80B(5) as well as the ratio of decision laid down by Hon'ble Supreme Court in the case of Synco Industries Ltd. Vs. Assessing Officer (IT) & Another, (2008) 299 ITR 444 (SC), in order to claim the deduction under Chapter- VI-A, first of all the gross total income is to be worked out and this has to be worked out after setting-off loss in one unit /division against profit of another unit and thereafter the gross total income is to be worked out for working of deduction u/s.80-IA of the Act. In the case of the ass…

THE DY.CIT.,CIRCLE-1(1)(2), SURAT vs. GUJARAT JHM HOTELS LTD.,, SURAT

In the result, the grounds of appeal raised by the revenue are dismissed

ITA 27/SRT/2017[2010-11]Status: DisposedITAT Surat25 Jul 2022AY 2010-11

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) D.C.I.T. M/S Gujarat Jhm Hotels Ltd., Circle-1(1)(2), Hotel Holiday In, Near Ambica Vs. Surat. Niketan, Athwalines, Surat- 395001. Pan : Aaacg 8562 E Appellant Respondednt C.O. No. 02/Srt/2022 (Arising Out Of Ita No. 27/Srt/2017)(Ay: 2010-11) M/S Gujarat Jhm Hotels Ltd., D.C.I.T. Hotel Holiday In, Near Bharti Circle-1(1)(1), Vs. Park, Ambikaniketan, Surat. Athwalines, Surat-395007. Pan : Aaacg 8562 E Appellant Respondednt

Section 143Section 254(1)Section 80I

…n is to be computed with respect to each unit independently taking into consideration the profit of each unit without clubbing loss of others. The ld. CIT(A) by referring the decision of Hon'ble Supreme Court in the case of Synco Industries Ltd. Vs ITO (2008) 299 ITR 444 (SC) held that deduction under Chapter VIA of the Act would be available only if the computation of gross total income as per the provisions of the Act after setting of different carries forward losses and unabsorbed depreciation of earlier year is not NIL. The ld. CIT(A) also noted that after adjusting the losses of Rs. 5.953 crores of DCIT Vs M…

THE JCIT(OSD), CIRCLE-3(1)(2),, AHMEDABAD vs. M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD.,, AHMEDABAD

In the result, the appeal filed by the Revenue is dismissed

ITA 90/AHD/2019[2012-13]Status: DisposedITAT Ahmedabad08 Jun 2022AY 2012-13

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalassessment Year : 2012-13 Jcit, Cir.3(1)(2) Shri Rajkamal Builders Ahmedabad. Vs Infrastructure P.Ltd. Pan : Aabcr 0326 A 54, Park Hill, Nr.Heaven Park Ramdevnagar Ahmedabad 380 015. अपीलाथ"/ (Appellant) "त् यथ"/ (Respondent) Assessee By : Shri M.K. Patel, Ar Revenue By : Shri Vijay Kumar, Jaiswal,Cit- Dr सुनवाई क" तार"ख/Date Of Hearing : 19/05/2022 घोषणा क" तार"ख /Date Of Pronouncement: 8/06/2022 आदेश/O R D E R Per Waseem Ahmed, Accounant Member: This Is Revenue’S Appeal Against The Order Of Ld.Cit(A)-9, Ahmedabad Dated 19.11.2018 Vide Which The Ld.Cit(A) Has Deleted Penalty Of Rs.1,05,74,312/- Imposed Under Section 271(1)(C) Of The Income Tax Act, 1961 ("The Act" For Short) For The Asst.Year 2012-13. 2. Sole Ground Raised By The Revenue Reads As Under: “1. The Ld.Cit(A) Has Erred In Law & On Facts In Deleting The Penalty Of Rs.1,05,74,312/- Imposed U/S.271(1)(C) Of The Act On Issue Of Disallowance Of Losses Set Off & Deduction Under Section 80Ia Of The Act Of Rs.3,11,10,071/-.”

For Appellant: Shri M.K. Patel, ARFor Respondent: Shri Vijay Kumar, Jaiswal,CIT-
Section 143(3)Section 271(1)(c)Section 274Section 80Section 80I

…off loss from 8 sites aggregating Rs.67,23,899/-. As per the provisions of Section 80A(2) r.w. section 80B(5) as well as the ratio of decision laid down by Hon'ble Supreme Court in the case of Synco Industries Ltd. Vs. Assessing Officer (IT) & Another, (2008) 299 ITR 444 (SC), in order to claim the deduction under Chapter-VI-A, first of all the gross total income is to be worked out and this has to be worked out after setting-off loss in one unit /division against profit of another unit and thereafter the gross total income is to be worked out for working of deduction u/s.80-IA of the Act. In the case of the asse…

M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD.,,AHMEDABAD vs. THE DCIT, CIRCLE-3(1)(2),, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 2202/AHD/2018[2016-17]Status: DisposedITAT Ahmedabad13 May 2022AY 2016-17

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

…off loss from 8 sites aggregating Rs.67,23,899/-. As per the provisions of Section 80A(2) r.w. section 80B(5) as well as the ratio of decision laid down by Hon'ble Supreme Court in the case of Synco Industries Ltd. Vs. Assessing Officer (IT) & Another, (2008) 299 ITR 444 (SC), in order to claim the deduction under Chapter-VI-A, first of all the gross total income is to be worked out and this has to be worked out after setting-off loss in one unit /division against profit of another unit and thereafter the gross total income is to be worked out for working of deduction u/s.80-IA of the Act. In the case of the asse…

M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD.,,AHMEDABAD vs. THE DCIT, CIRCLE-3(1)(2),, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 2201/AHD/2018[2015-16]Status: DisposedITAT Ahmedabad13 May 2022AY 2015-16

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

…off loss from 8 sites aggregating Rs.67,23,899/-. As per the provisions of Section 80A(2) r.w. section 80B(5) as well as the ratio of decision laid down by Hon'ble Supreme Court in the case of Synco Industries Ltd. Vs. Assessing Officer (IT) & Another, (2008) 299 ITR 444 (SC), in order to claim the deduction under Chapter-VI-A, first of all the gross total income is to be worked out and this has to be worked out after setting-off loss in one unit /division against profit of another unit and thereafter the gross total income is to be worked out for working of deduction u/s.80-IA of the Act. In the case of the asse…

M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD.,,AHMEDABAD vs. THE ACIT, CIRCLE-3(1)(2),, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 1499/AHD/2018[2011-12]Status: DisposedITAT Ahmedabad13 May 2022AY 2011-12

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

…off loss from 8 sites aggregating Rs.67,23,899/-. As per the provisions of Section 80A(2) r.w. section 80B(5) as well as the ratio of decision laid down by Hon'ble Supreme Court in the case of Synco Industries Ltd. Vs. Assessing Officer (IT) & Another, (2008) 299 ITR 444 (SC), in order to claim the deduction under Chapter-VI-A, first of all the gross total income is to be worked out and this has to be worked out after setting-off loss in one unit /division against profit of another unit and thereafter the gross total income is to be worked out for working of deduction u/s.80-IA of the Act. In the case of the asse…

M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD.,,AHMEDABAD vs. THE ACIT., CIRCLE-3(1)(2),, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 2917/AHD/2016[2010-11]Status: DisposedITAT Ahmedabad13 May 2022AY 2010-11

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

…off loss from 8 sites aggregating Rs.67,23,899/-. As per the provisions of Section 80A(2) r.w. section 80B(5) as well as the ratio of decision laid down by Hon'ble Supreme Court in the case of Synco Industries Ltd. Vs. Assessing Officer (IT) & Another, (2008) 299 ITR 444 (SC), in order to claim the deduction under Chapter-VI-A, first of all the gross total income is to be worked out and this has to be worked out after setting-off loss in one unit /division against profit of another unit and thereafter the gross total income is to be worked out for working of deduction u/s.80-IA of the Act. In the case of the asse…

M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD.,,AHMEDABAD vs. THE ACIT., CIRCLE-3(1)(2),, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

ITA 2916/AHD/2016[2013-14]Status: DisposedITAT Ahmedabad13 May 2022AY 2013-14

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri A.P. Singh, CIT-DR and Shri V.K. Singh, Sr.DR
Section 271(1)(c)Section 36(1)(iii)Section 80I

…off loss from 8 sites aggregating Rs.67,23,899/-. As per the provisions of Section 80A(2) r.w. section 80B(5) as well as the ratio of decision laid down by Hon'ble Supreme Court in the case of Synco Industries Ltd. Vs. Assessing Officer (IT) & Another, (2008) 299 ITR 444 (SC), in order to claim the deduction under Chapter-VI-A, first of all the gross total income is to be worked out and this has to be worked out after setting-off loss in one unit /division against profit of another unit and thereafter the gross total income is to be worked out for working of deduction u/s.80-IA of the Act. In the case of the asse…

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