This is from New York's website and it essentially states that if we have an Indian passport with a "canceled due to to acquisition of US nationality" stamp, we don't have to get a surrender certificate. This now matches what SF consulate also states.
Q3 My Indian passport has already been cancelled by an Indian Mission but I was not issued a Surrender Certificate. Do I need to obtain one?
Even though your passport has a cancelled stamp, you need to formally renounce your citizenship as per the prescribed format and obtain a Surrender Certificate as a proof of having done so. However, if your passport was cancelled due to acquisition of foreign nationality and has an endorsement to this effect, no Surrender Certificate is required.
Q3 My Indian passport has already been cancelled by an Indian Mission but I was not issued a Surrender Certificate. Do I need to obtain one?
Even though your passport has a cancelled stamp, you need to formally renounce your citizenship as per the prescribed format and obtain a Surrender Certificate as a proof of having done so. However, if your passport was cancelled due to acquisition of foreign nationality and has an endorsement to this effect, no Surrender Certificate is required.