TMI Blog2011 (10) TMI 19X X X X Extracts X X X X X X X X Extracts X X X X ..... .1,56,33,719/- for computing book profit under Section 115JA was not admissible. - Held that:- Following the view taken by the Special Bench in Syncome Formulations (2007 -TMI - 59552 - ITAT BOMBAY-H ), the Tribunal in the present case came to the conclusion that deduction claimed by the assessee under Section 80HHE has to be worked out on the basis of adjusted book profit under Section 115JA and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and loss account amounting to Rs.3,07,84,105/- to arrive at the book profit of Rs.1,51,50,386/- under Section 115JA of the Income-tax Act, 1961 [See: Vol.R/1 of I.A. paper book page 6]. This claim for deduction made by the assessee was rejected by the A.O. saying that since in normal computation there is no profit after carry-forward loss, deduction under Section 80HHE to the extent of Rs.1,56,33 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... HHE. The said judgment of the Special Bench was with regard to computation of deduction under Section 80HHC which, like Section 80HHE, falls under Chapter VI-A of the Income Tax Act, 1961. In the said judgment of Special Bench, which squarely applies to the facts of the present case, the Tribunal held that the deduction under Section 80HHC (Section 80HHE also falls in Chapter VI-A) is to be worked ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f the judgment of the Tribunal in Syncome Formulations (supra)]. 2. In the present case we are concerned with Section 80HHE which is referred to in the Explanation to Section 115JA, clause (ix). In our view, the judgment of the Special Bench of the Tribunal in Syncome Formulations (supra) squarely applies to the present case. Following the view taken by the Special Bench in Syncome Formulation ..... X X X X Extracts X X X X X X X X Extracts X X X X
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