JUDGMENT Order assessee filed its return of income for assessment year 2000-01. assessee claimed deduction under section 80HHE to extent of Rs.1,56,33,719 against net profit as per profit and loss account amounting to Rs. 3,07,84,105 to arrive at book profit of Rs. 1,51,50,386 under section 115JA of Income-tax Act, 1961 [See: Vol.R/1 of I.A. paper book A- page 6]. This claim for deduction made by assessee was rejected by Assessing Officer saying that since in normal computation there is no profit after carry forward loss, deduction under section 80HHE to extent of Rs. 1,56,33,719 for computing book profit under section 115JA was not admissible. According to Assessing Officer, since in present case in normal computation no net profit was left after brought forward losses of earlier years got adjusted against current year's profit, assessee was not entitled to deduction under section 80HHE to extent of Rs. 1,56,33,719. In appeal, Commissioner of Income-tax (Appeals) upheld order of Assessing Officer. assessee went in appeal, against order of Commissioner of Income-tax (Appeals), before Tribunal which, following judgment of Special Bench of Tribunal in case of Deputy CIT v. Syncome Formulations (I) Ltd. [2007] 106 ITD 193, took view that MAT scheme which includes section 115JA did not take away benefits given under section 80HHE. said judgment of Special Bench was with regard to computation of deduction under section 80HHC which, like section 80HHE, falls under Chapter VI-A of Income-tax Act, 1961. In said judgment of Special Bench, which squarely applies to facts of present case, Tribunal held that deduction under section 80HHC (section 80HHE also falls in Chapter VI-A) is to be worked out not on basis of regular income-tax profits but it has to be worked out on basis of adjusted book profits in case where section 115JA is applicable. In said judgment, dichotomy between regular income-tax profits and adjusted book profits under section 115JA is clearly brought out. Tribunal in said judgment rightly held that in section 115JA relief has to be computed under section 80HHC(3)/(3A). According to Tribunal, once law itself declares that adjusted book profit is amenable for further deductions on specified grounds, in case where section 80HHC (80HHE in present case) is operational, it becomes clear that computation for deduction under those sections needs to be worked out on basis of adjusted book profit [See: para 61 of judgment of Tribunal in Syncome Formulations.] [2007] 292 ITR (AT) 144 (Mum) [SB] In present case, we are concerned with section 80HHE which is referred to in Explanation to section 115JA, clause (ix). In our view, judgment of Special Bench of Tribunal in Syncome Formulations squarely applies to present case. Following view taken by Special Bench in Syncome Formulations, Tribunal in present case came to conclusion that deduction claimed by assessee under section 80HHE has to be worked out on basis of adjusted book profit under section 115JA and not on basis of profits computed under regular provisions of law applicable to computation of profits and gains of business. judgment of Tribunal has been upheld by High Court. We see no reason to interfere with impugned judgment. We agree with view taken by Special Bench of Tribunal in case of Syncome Formulations1 vide para 61 of judgment. Accordingly, special leave petition filed by Department stands dismissed with no order as to costs. [2007] 292 ITR (AT) 144 (Mum) [SB] *** Commissioner of Income-tax v. Bhari Information Tech. Sys. P. Ltd