“gross total income”

Chapter VI - Deductions / Set-offSection 80B(5)Section 80B(5) / Rule 3D2,282 judgments

The decision most relied on for gross total income is CIT v. Andhra Pradesh State (200 Taxmann 220), cited in 348 judgments on BharatTax.

Leading authorities on gross total income

CIT v. Andhra Pradesh State

200 Taxmann 220 · 2011 · High Court

348

citing judgments

Interest earned by a Co-operative Society from investing fixed deposits in banks is entitled to a deduction under Section 80P(2)(a)(i) of the Income-tax Act.

CIT v. Yokogawa India Ltd.

391 ITR 274 · 2017 · Supreme Court

290

citing judgments

Deduction under Section 10A or 10AA of the Income-tax Act is computed on the profits of the eligible unit without first setting off losses from other units or non-eligible units. Conversely, losses incurred by an eligible unit are allowed to be set off against the assessee's other taxable business profits.

ACG Associated Capsules (P) Ltd. v. CIT

343 ITR 89 · 2012 · Supreme Court

144

citing judgments

For calculation of deduction under Section 80HHC, if total interest is netted off after adjusting interest paid and received, the 90% reduction specified in Explanation (baa) is not applicable.

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

299 ITR 444 · 2008 · Supreme Court

citing judgments

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.

CIT v. Himatasingike Seide Ltd.

286 ITR 255 · 2006 · High Court

citing judgments

Deduction under Section 10A of the Income-tax Act is to be allowed only after setting off unabsorbed depreciation and brought forward business losses against the profits of the business.

CIT v. Williamson Financial Services

165 Taxmann 638 · 2007 · Supreme Court

citing judgments

Income-tax is levied on the total income of an assessee, not on gross receipts. The tax is on income, and deductions for expenditure are permissible.

CIT v. Reliance Energy Limited

127 Taxmann.com 69 · 2021 · Supreme Court

citing judgments

Deduction under Section 80-IA or 80-IB is computed by setting it off against the gross total income to arrive at the total income of an assessee.

CIT v. Tridoss Laboratories Ltd.

328 ITR 448 · 2010 · High Court

citing judgments

Deductions under Chapter VI-A of the Income Tax Act, such as Section 80-IA, are to be calculated and allowed with reference to the assessee's gross total income, not just business income.

Judgments citing gross total income

Clover Everest World Co-Operative Housing Society Limited, Thane vs. ITO, Ward 1(1), Thane

In the result, the appeal of the assessee is allowed

ITA 6376/MUM/2025[2021-22]Status: DisposedITAT Mumbai12 Dec 2025AY 2021-22

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2021-22 Clover Everest World Ito, Ward-1(1), Co-Operative Housing Society 6Th Floor, Limited, Vs. Income Tax Department, Clover Everest Complex, Ashar It Park, Clover Everest World Chs, Wagale Estate, Dhokali, Thane, Thane Maharashtra–400607. Maharashtra-400604. [Pan: Aabac8915E] (Appellant) (Respondent) For Assessee : Shri Ruturaj Gurjar For Revenue : Shri Mahesh Shingate, Addl. Cit (Virtually Appeared) Date Of Hearing : 09-12-2025 Date Of Pronouncement : 12-12-2025 Order Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Addl/Jcit(A)-2, Visakhapatnam, Dated 25-08-2025, Pertaining To Assessment Year (Ay) 2021-22. 2. The Limited Issue For Consideration In The Present Matter Relates To Claim Of Exemption U/S 80P(2)(D) Of The Act By The Assessee Co-Operative Society In Respect Of Interest Income Earned On Deposits Placed With Co-Operative Banks.

For Appellant: Shri Ruturaj GurjarFor Respondent: Shri Mahesh Shingate, Addl. CIT

Section 143(1)Section 154Section 80Section 80PSection 80P(1)Section 80P(2)(d)

Shree Laxmi Jyot Industrial Co-Op Soc. Ltd, Mumbai vs. ACIT Cir-25(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 6371/MUM/2025[2018-19]Status: DisposedITAT Mumbai12 Dec 2025AY 2018-19

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2018-19 Shree Laxmi Jyot Industrial Acit, Circle-25(1), Premises Co-Op. Society Pratyaksha Kar Bhawan, Limited, Vs. Bandra Kurla Complex (Bkc), 29-J, Laxmi Industrial Estate, Bandra (East), New Link Road, Mumbai-400051. Andheri West, Mumbai – 400053. [Pan: Aadas7200A] (Appellant) (Respondent) For Assessee : Shri Gajendra Golchha For Revenue : Shri Vikas Chandra, Sr.Dr Date Of Hearing : 09-12-2025 Date Of Pronouncement : 12-12-2025 Order Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Addl/Jcit(A)-Mysore, Dated 12-08-2025, Pertaining To Assessment Year (Ay) 2018-19. 2. The Limited Issue For Consideration In The Present Matter Relates To Claim Of Exemption U/S 80P(2)(D) Of The Act By The Assessee Co-Operative Society In Respect Of Interest Income Earned On Deposits Placed With Co-Operative Banks.

For Appellant: Shri Gajendra GolchhaFor Respondent: Shri Vikas Chandra, Sr.DR

Section 80Section 80PSection 80P(1)Section 80P(2)(d)

Prestigious Enterprises Pvt Ltd, New Delhi vs. ACIT CC-18, New Delhi

In the result, appeal of the assessee is dismissed

ITA 9271/DEL/2019[2007-08]Status: DisposedITAT Delhi10 Dec 2025AY 2007-08

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh[Assessment Year: 2007-08] Prestigious Enterprises P. Ltd. Acit, Cc-18, New Delhi (Formerly Known As Aeren R Enterprises P. Ltd. & A R Developers Vs Merged With Aeren R Enterprises P. Ltd.) 618, 6Th Floor, Devika Tower, Nehru Place, New Delhi 110019 Pan- Aadcs-7613-K Assessee Revenue

Section 142(1)Section 143(3)Section 254Section 271(1)(c)Section 68

been established by the appellant. The acknowledgement for filing IT Return for A.Y. 2007-08 shows gross total income NIL and total income also NIL. Thus, it is clear that the creditor has no worth to advance a sum of Rs. 50,00,000/- to the appellant. No proof regarding ... assessee which included the acknowledgment of the return of M/s Treatwell Investments Pvt. Ltd. for Asst. Year 2007-08 wherein the gross total income was Nil and observed that the creditor had no worth to advance the sum of Rs.50 lakhs to the assessee. The Ld. CIT(A) also noted

Sree Maruthi Cooperative Housing Society, Bengaluru vs. Income Tax Officer, Ward-7(2)(3), Bengaluru

In the result, the appeal filed by the assessee is allowed

ITA 1895/BANG/2024[2016-17]Status: DisposedITAT Bangalore09 Dec 2025AY 2016-17

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2016-17

For Appellant: Shri Ravishankar, AdvocateFor Respondent: Shri Subramanian .S, JCIT-DR

Section 142(1)Section 143(1)Section 143(2)Section 234BSection 250Section 801Section 80P(2)(a)Section 80P(4)Section 8o

same is an income from other sources. The Ld.CIT(A) had partly allowed the appeal by deleting the gross total income added by the AO and confirmed the net income of Rs. 31,41,854/- on the ground that the interest income was earned from co-operative banks and therefore

Bombay Mercantile Co-Op Bank Ltd Employees Co-Op Credit Society Ltd, Mumbai vs. ITO-17(1)(3), Mumbai

ITA 6453/MUM/2025[2013-14]Status: DisposedITAT Mumbai09 Dec 2025AY 2013-14

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Vijay JoshiFor Respondent: Shri Leyaqat Ali Aafaqui

Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)

loans given and investments made are of Rs.10,51,95,000/- and Rs.2,00,70,433/- respectively as on 31.03.2010. The gross total income was in sum of Rs.85,63,511/-. The assessee claimed the deduction u/s 80P(2)(a)(i) of the Income ... unnecessary to probe any further as to whether the co-operative society is classified as X or Y. 29. Thirdly, the gross total income must include income that is referred to in sub-section (2). xx xx Assessment Year 2013-2014 & 2014-2015 35. Eighthly, sub-clause (d) also points

Bombay Mercantile Co-Op Bank Ltd Empoyees Co-Op Credit Society Ltd, Mumbai vs. ITO-17(1)(3), Mumbai

ITA 6452/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Dec 2025AY 2014-15

For Appellant: Shri Vijay JoshiFor Respondent: Shri Leyaqat Ali Aafaqui

Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)

Vyavasaya Seva Sahakari Bank Limited, Halkusagal vs. Income Tax Officer, Ward-1, Gadag

In the result, appeal of the Assessee is allowed

ITA 1475/BANG/2024[2020-21]Status: DisposedITAT Bangalore08 Dec 2025AY 2020-21

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year: 2020-21 M/S. Vyavasaya Seva Sahakari The Income Tax Officer, Bank Limited, Ward 1, Halkusagal. Vs. Gadag Pan: Aaaav1081D Appellant Respondent

For Appellant: Shri Anil Kumar, CA

Section 143Section 80Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

primary credit society engaged in business of providing credit facilities to its members. It filed its return of income on 28.01.2021 at a gross total income of Rs. 10,20,139/- and claimed the same as deduction u/s. 80P of the Act determining total income at Rs. Nil/-. The return ... considered with respect to the respective sister legislations. It further states that the deduction is to be allowed to the Assessee from the gross total income. Thus, it is irrespective of the fact whether it is business income or income from other sources. The specific character of the deduction

Rayat Sahakari Sakhar Karkhana Ltd, Satara vs. ITO Ward-5, Satara

In the result, the appeal filed by the assessee is allowed

ITA 373/PUN/2025[2015-16]Status: DisposedITAT Pune05 Dec 2025AY 2015-16

Bench: Dr.Manish Borad

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Ajitesh Meena

Section 143(1)(a)Section 143(2)Section 143(3)Section 250

record placed before me. The grievance of the assessee is that ld.CIT(A) erred in affirming the action of the AO treating the gross total income of ₹26,86,106 as ‘Income from Other Sources and not allowing the set off of brought losses and also the claim of deduction ... authorities and further the alleged claim 7 Rayat Sahakari Sakhar Karkhana Ltd. of set off of brought forward business loss against current year gross total income at ₹26,86,106 is hereby allowed. Finding of ld.CIT(A) is reversed. Grounds of appeal raised by the assessee are allowed

Cambridge Construction (Delhi) Private Limited, New Delhi vs. Income Tax Officer, New Delhi

The appeal is allowed

ITA 4939/DEL/2025[2013-14]Status: DisposedITAT Delhi05 Dec 2025AY 2013-14

Bench: Shri Anubhav Sharma & Shri Naveen Chandracambridge Construction Vs. Ito, Ward 5(3) (Delhi) Private Limited New Delhi – 110002 11, Monnet House, Masjid Moth, New Delhi – 110048 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaacc0295N Appellant .. Respondent

For Appellant: Sh. VK Jain, CAFor Respondent: Sh. Om Prakash, Sr. DR

Section 115JSection 143(3)Section 144BSection 154Section 250Section 271(1)(c)

Allowed by Hon’ble Delhi High Court) 9,88,27,609 Gross Total Income Nil (b) The Ld. AO on Page 30 of the assessment order u/s 143(3) r.w.s. 260 has not initiated any penalty u/s 271(1)(c) of Income Tax Act. 8. Since both the disallowances

Deputy Commissioner of Income Tax, Ghaziabad vs. Mahalakshmi Light House, Hapur

In the result, Cross Objection filed by the Assessee is allowed

ITA 3513/DEL/2024[2015-16]Status: DisposedITAT Delhi05 Dec 2025AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Deputy Commissioner Of Vs. Mahalakshmi Light House, Income Tax 285, Avas Vikas Vihar, Room No. 201, First Floor, Hapur, Uttar Pradesh Cgo Complex, Hapur Chungi, Pan: Aatfm3627N Ghaziabad, Uttar Pradesh Appellant Respondent

Section 147Section 69C

which includes bogus purchase from Vrindavan International Trade Private Limited for Rs. 41,82,341/-. In addition to this, as per 26AS, the gross total income is Rs. 14,60,45,404/- whereas as per ITR, the gross total income is 11,62,66,741/-. Hence, the assessee has declared

ACIT, Circle - 3 3 1, Mumbai vs. Jamnagar Utilities and Power Pvt Ltd, Mumbai

In the result, both the appeals of the Revenue are allowed

ITA 5312/MUM/2024[2019-20]Status: DisposedITAT Mumbai04 Dec 2025AY 2019-20

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Nimesh Vora/For Respondent: Mr. Vivek Perampurna, CIT-DR

Section 115JSection 135Section 139(1)Section 143(3)Section 144BSection 43ASection 80G

accordingly not 'voluntary donation to be allowable under section 80G - Whether section 80G falls in Chapter VIA, which comes into play only after gross total income has been computed by applying computation provisions under various heads of income, including Explanation 2 to section 37(1) and, thus, there

ACIT, Circle - 3 3 1, Mumbai vs. Jamnagar Utilities and Power Pvt Ltd, Mumbai

In the result, both the appeals of the Revenue are allowed

ITA 5310/MUM/2024[2020-21]Status: DisposedITAT Mumbai04 Dec 2025AY 2020-21

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Respondent: Mr. Nimesh Vora/

Section 115JSection 135Section 139(1)Section 143(3)Section 144BSection 43ASection 80G

accordingly not 'voluntary donation to be allowable under Section 80G - Whether Section 80G falls in Chapter VIA, which comes into play only after gross total income has been computed by applying computation provisions under various heads of income, including Explanation 2 to Section 37(1) and, thus, there

Msl Fish Traders Private Limited, Bhubaneswar vs. Dy.CIT, Central Circle-2, Bhubaneswar

In the result, both the appeals of the assessee stand allowed

ITA 333/CTK/2025[2018-2019]Status: DisposedITAT Cuttack03 Dec 2025AY 2018-2019

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita Nos.332 & 333/Ctk/2025 ("नधा"रण वष" / Assessment Years: 2017-18 & 2018-19) Msl Fish Traders Private Limited, Vs Dcit, Central Circle-2, Rooom No.14, Fish Market, Unit-4, Bhubaneswar. Bhubaneswar. Pan No. : Aajcm 1080 E (अपीलाथ" /Appellant) .. (""यथ" / Respondent) "नधा"रती क" ओर से /Assessee By : Shri D.Parida, Ca & Shri Chitrasen Parida, Adv राज"व क" ओर से /Revenue By : Shri Ashim Kumar Chakraborty, Ld Cit Dr सुनवाई क" तार"ख / Date Of Hearing : 3 /12/2025 घोषणा क" तार"ख/Date Of Pronouncement : 3 /12/2025 आदेश / O R D E R Per Bench : These Are Appeals Filed By The Assessee Against The Separate Orders Dated 31.3.2025 Passed By Ld Cit(A), Bhubaneswar-2 In Appeal No.Cit(A), Bhubaneswar-2/11252/2017-18 For The Assessment Years 2017-18 & 2018-19, Respectively. 2. Shri D.Parida & Shri Chitrasen Parida, Ld Ars Appeared For The Assessee & Shri Ashim Kumar Chakraborty, Ld Cit Dr Appeared For The Revenue. 3. It Was Submitted By Ld Ar That The Assessee Has Filed Written Submission, Which Reads As Follows:

For Appellant: Shri D.Parida, CA and Shri ChitrasenFor Respondent: Shri Ashim Kumar Chakraborty, ld CIT

Section 132Section 153ASection 246ASection 250Section 69

Company engaged in the business of fish trading, e-filed the return of income for the aforesaid A.Y. 2017-18 on 30.10.2017 with gross total income of Rs.12,43,250/-. 2. That, a search & seizure operation u/s 132 of the Income Tax Act, 1961 was carried out at the business

Msl Fish Traders Private Limited, Bhubaneswar vs. Dy.CIT, Central Circle-2, Bhubaneswar

In the result, both the appeals of the assessee stand allowed

ITA 332/CTK/2025[2017-2018]Status: DisposedITAT Cuttack03 Dec 2025AY 2017-2018

For Appellant: Shri D.Parida, CA and Shri ChitrasenFor Respondent: Shri Ashim Kumar Chakraborty, ld CIT

Section 132Section 153ASection 246ASection 250Section 69

Bhavana Co-Op Credit Society Niyamita, Sirsi vs. Income Tax Officer, Ward-1, Sirsi

In the result the appeal filed by the assessee is allowed

ITA 1074/BANG/2025[2020-21]Status: DisposedITAT Bangalore03 Dec 2025AY 2020-21

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21

For Appellant: Sri V. Srinivasan, A.RFor Respondent: Sri Shivanand H Kalakeri, D.R

Section 142(1)Section 143(2)Section 143(3)Section 263Section 80P(2)(a)Section 80P(2)(i)

business of banking or providing credit facilities to its members by a co-operative society and is liable to be deducted from the gross total income under Section 80P of the Act. 11. In this context when we look at the judgment of the Apex Court in Totgars Co- operative

Gonikoppal Primary Rural Agricultural Credit Co-Operative Society Limited, Kodagu vs. Pr. Commissioner of Income Tax, Bengaluru-3, Bengaluru

In the result the appeal filed by the assessee is allowed

ITA 1072/BANG/2025[2020-21]Status: DisposedITAT Bangalore03 Dec 2025AY 2020-21

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21

For Appellant: Sri V. Srinivasan, A.RFor Respondent: Sri Shivanand H Kalakeri, D.R

Section 142(1)Section 143(2)Section 143(3)Section 263Section 80P(2)(a)Section 80P(2)(i)

Income Tax Officer, Mumbai vs. Nariman Bhavan Premises Co Op Society Ltd, Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 3659/MUM/2023[2015-16]Status: DisposedITAT Mumbai02 Dec 2025AY 2015-16

Bench: Hon‟Ble Justice (Retd.) C. V. Bhadang & Shri Vikram Singh Yadavassessment Year : 2015-16 Income Tax Officer, Mumbai Nariman Bhavan Premises Co Op Room No. 118, 1St Floor, Society Ltd. G Block, Kautilya Bhavan, Vs. 227 Backbay Reclamation, Bandra Kurla Complex (E), Nariman Point, Mumbai – 400021. Mumbai – 400051. [Pan: Aajn0320J] (Appellant) (Respondent) For Assessee : Shri K. Gopal / Om Kandalkar For Revenue : Ms. Nidhi Agarwal, Sr. Dr (Virtually Present) Date Of Hearing : 02-12-2025 Date Of Pronouncement : 02-12-2025 Order Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals) - National Faceless Appeal Centre (Nfac), Delhi [„Ld. Cit(A)‟], Dated 14-08-2023, Pertaining To Assessment Year (Ay) 2015-16. 2. At The Outset, It Is Noted That This Is A Recalled Matter Wherein Co-Ordinate Bench Vide Its Order Dated 22.09.2025 In Ma No. 244/M/2024 Has Recalled The Earlier Order Dated 08.05.2024 & The Matter Has Now Come Up For Adjudication Before Us.

For Appellant: Shri K. Gopal / Om KandalkarFor Respondent: Ms. Nidhi Agarwal, Sr. DR

Section 3Section 80Section 80PSection 80P(1)Section 80P(2)(d)

ACIT, Chennai vs. Sri Balaji Educational Amd Trust Charitable Public Trust, Chenna

In the result, the appeal of the Assessee and that of the Department are dismissed

ITA 1471/CHNY/2025[2017-18]Status: DisposedITAT Chennai01 Dec 2025AY 2017-18

Bench: Shri Aby T Varkey & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 1249/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 M/S. Sri Balaji Educational & Acit, Charitable Public Trust, Vs. Central Circle 3(4), No. 60, First Avenue, Chennai. Jai Durga Complex, Ashok Nagar, Chennai – 600 083. Tamil Nadu. (&'थ"/Respondent) [Pan: Aacts-1386-D] (अपीलाथ"/Appellant) आयकर अपील सं./Ita Nos.:1471/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 Acit, M/S. Sri Balaji Educational & Central Circle 3(4), Vs. Charitable Public Trust, Chennai. No. 60, First Avenue, Jai Durga Complex, Ashok Nagar, Chennai – 600 083. Tamil Nadu. (अपीलाथ"/Appellant) [Pan: Aacts-1386-D] (&'थ"/Respondent) िनधा$)रती की ओर से/Assessee By : Shri. Y.Sridhar, Fca राज4 की ओर से /Revenue By : Ms. E. Pavuna Sundari, Cit सुनवाई की तारीख/Date Of Hearing : 08.09.2025 घोषणा की तारीख/Date Of Pronouncement : 01.12.2025

For Appellant: Shri. Y.Sridhar, FCAFor Respondent: Ms. E. Pavuna Sundari, CIT

Section 132Section 132(4)Section 143(3)Section 245D(4)Section 250

pass necessary orders. As a consequence, the Interim Board of Settlement-2 in the order dtd.14.06.2023 passed a final order in which the gross total income for the four assessment years was fixed at Rs.246.50 crores. At the stage of the proceedings before IBS, the ld.PCIT requested for enhancement

M/S. Sri Balaji Educational and Charitable Public Trust, Chennai vs. ACIT, Central Circle-3(4), Chennai

In the result, the appeal of the Assessee and that of the Department are dismissed

ITA 1249/CHNY/2025[2017-18]Status: DisposedITAT Chennai01 Dec 2025AY 2017-18

For Appellant: Shri. Y.Sridhar, FCAFor Respondent: Ms. E. Pavuna Sundari, CIT

Section 132Section 132(4)Section 143(3)Section 245D(4)Section 250

Kaiga Project Employees Thrift and Credit Society, Karwar vs. Income Tax Officer, Ward - 2, Karwar

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 62/PAN/2025[2015-16]Status: DisposedITAT Panaji28 Nov 2025AY 2015-16

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

adjudication of the issue before us. "80P(2) (d) (1). Where in the case of an assessee being a co- operative society, the gross total income includes any income referred to in sub- section (2), there shall be deducted, in accordance with and subject to the provisions of this section ... officer to allow the claim of deduction u/sec 80P(2)(d) of the Act to the extent of interest income included in the gross total income and such deduction under this chapter VIA should be restricted to the gross total income. And we allow the grounds of appeal in favour