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

299 ITR 444Supreme Court of India2008#1392 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 366,005 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

Issues it is cited on

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

ACIT, Chennai vs. M/S. Tvs Motor Company Limited, Chennai

In the result, appeal of the revenue is dismissed

ITA 1782/CHNY/2012[2008-09]Status: DisposedITAT Chennai13 Apr 2022AY 2008-09

Bench: S/Shri Shri Chandra Mohan Garg, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaassessment Year : 2008-09 The The Asst. Asst. Commissioner Commissioner Of Of Vs. M/S. Tvs Motor Company Ltd., M/S. Tvs Motor Company Ltd., Income Tax, Company Circle Income Tax, Company Circle- Jayalakshmi Estates, 29 (Old Jayalakshmi Estates, 29 (Old Iii(2), New Block, 4Th Floor, 121, Iii(2), New Block, 4 No.8), Haddows Road, Chennai No.8), Haddows Road, Chennai Mahatma Mahatma Gandhi Gandhi Road, Road, Nungambakkam, Chennai Nungambakkam, Chennai Pan/Gir No.Aaacs 7032 B Aaacs 7032 B (Appellant) (Appellant .. ( Respondent Respondent) Assessee By : Shri Vikram Vijayaraghavan, Vikram Vijayaraghavan, Ar Revenue By : Dr. S.Palanikumar, Cit ( Cit (Dr) Date Of Hearing : 24 /2/ 2022 2 Date Of Pronouncement : 13/4/20 /2022 O R D E R Per C.M.Garg, Jm , Jm

For Appellant: Shri Vikram VijayaraghavanFor Respondent: Dr. S.Palanikumar, CIT (
Section 80Section 80HSection 80I

…f income. I have considered the rival contentions. Benefit of deduction under Chapter VI-A can be given to the assessee if the claim is in accordance with law and not otherwise. The decisions of Hon'ble Supreme Court in Synco Industries Ltd. vs. AO & Another (299 ITR 444), A.MMoosa vs. CIT (294 ITR I) and CIT Vs. Shirke Construction Equipment Ltd. (291 ITR) are directly on the subject issue. The Hon'ble Supreme Court in the case of Synco Industries Ltd (supra) has clearly held that gross total income should include both profit and loss of different units and if the result is nil, assessee is not entitled to speci…