“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

Kayanna Service Co-Operative Bank, Kozhikode vs. ITO, Krl-W-(32)(3), Kozhikode

In the result, both appeals of the assessee bearing ITA No

ITA 655/COCH/2025[2020-21]Status: DisposedITAT Cochin13 Nov 2025AY 2020-21

Bench: BEFORESHRI. INTURI RAMA RAO, ACCOUNTANT MEMBERAND SHRI. ANIKESH BANERJEE (Judicial Member)

For Appellant: Shri Anandakumar, AdvFor Respondent: Shri Leena Lal, (SR.AR.)

Section 143(3)Section 250Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

business is in the jurisdiction of Kayanna Panchayatha in Koyilandy Taluk, Kozhikode district in Kerala State. The assessee filed the return and declaring gross total income of Rs. 1,10,05,198/- and the total income declared Nil after claiming deduction u/s 80P(2)(a)(i). The assessee claimed deduction

The Satara Zilla Krishi Bank Karmachari Sahakari Patsanstha Ltd, Satara vs. ACIT, Satara

In the result, appeal of the Assessee is allowed

ITA 2153/PUN/2025[2018-19]Status: DisposedITAT Pune13 Nov 2025AY 2018-19

Bench: SHRI VINAY BHAMORE (Judicial Member)

Section 143(3)Section 250Section 80PSection 80P(2)Section 80P(2)(d)

records. In this case, Assessee is a Co-operative Society filed the return of income electronically for the A.Y.2018-19 on 08.10.2018 declaring gross total income at Rs.1,14,11,093/-. The Total income shown in the return of income was Rs.1,72,050/- after availing Chapter VIA deduction of Rs.1

ACIT-6(1)(1), Mumbai vs. Aditya Birla Real Estate Limited(Formerly Knowns As Century Textiles and Industries Limited), Mumbai

Appeal of the revenue is dismissed and the appeal of the assessee is allowed for statistical purposes

ITA 4359/MUM/2025[2018]Status: DisposedITAT Mumbai13 Nov 2025

Bench: Shri Pawan Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri yogesh Thar & Shri VinayakFor Respondent: Shri Rajesh Kumar Yadav, CIT-

Section 250Section 32(1)(i)

Assessment Order but has considered the impact of the intra head adjustment of INR 29,63,83,924 while computing the gross total income. 2. In view of the above, the Appellant prays that the amount of intra head adjustment of INR 29,63,83,924 be quantified

Aditya Birla Real Estate Limited (Formerly Known As Century Textiles and Industries Limited), Mumbai vs. Commissioner of Income Tax, Circle 6(1)(1), Mumbai

Appeal of the revenue is dismissed and the appeal of the assessee is allowed for statistical purposes

ITA 2979/MUM/2025[2018-19]Status: DisposedITAT Mumbai13 Nov 2025AY 2018-19

Bench: Shri Pawan Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri yogesh Thar & Shri VinayakFor Respondent: Shri Rajesh Kumar Yadav, CIT-

Section 250Section 32(1)(i)

Jambo Credit and Thrift Co-Operative Society Limited, Jaipur vs. ITO-6(1), Jaipur

ITA 1109/JPR/2025[2018-19]Status: DisposedITAT Jaipur12 Nov 2025AY 2018-19

Bench: This Appellate Tribunal Feeling Aggrieved By Order Dated 12.06.2024, Passed By Learned Cit(A), Nfac, Delhi, Relating To The Assessment Year 2018-19, As Thereby The Appeal Filed By The Appellant Has Been Dismissed.

For Appellant: Ms. Apksha Kalra, AdvFor Respondent: Shri Gaurav Awasthi, JCIT

said section deals with deductions in respect of income of co-operative societies. Section 80P(1), inter alia, states that where the gross total income of a co-operative society includes any income from one or more specified activities, then such income shall be deducted from the gross total income

Daulat Singh Haldea, Jaipur vs. ITO WD 3(3), Jaipur

The appeal is partly allowed as regards

ITA 1366/JPR/2025[2012-13]Status: DisposedITAT Jaipur11 Nov 2025AY 2012-13

Bench: SHRIGAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri Dilip Shivpuri, AdvFor Respondent: Shri Gaurav Awasthi, JCIT

Section 143Section 143(3)Section 271(1)(c)Section 54ESection 80C

Income from other sources Rs. 72,282/- Add: Long term Capital Gain as discussed above Rs. 1,55,00,000/- Gross total income Rs. 1,63,00,964/- Less: deduction u/s 80C Rs. 27,500/- Total taxable income Rs. 1,62,73,464/- Rounded

Moreshwar Krupa Co Op Housing Society Limited, Mumbai vs. Income Tax Officer Ward 42(1)(3), Mumbai

ITA 5026/MUM/2025[2018-19]Status: DisposedITAT Mumbai10 Nov 2025AY 2018-19

Bench: Shri Narender Kumar Choudhry

Section 143(1)Section 154Section 250Section 80PSection 80P(1)Section 80P(2)(d)

Housing Society. Thus, if any income as referred to in sub- section (2) to section 80P of the Act is included in the gross total income of the Assessee, the same shall be allowed as a deduction. It is pertinent to note that since the Assessee is registered under

DCIT Circle 4(2), New Delhi vs. Canon India Pvt. Ltd., New Delhi

In the result, to sum up and conclude:

ITA 1038/DEL/2023[2005-06]Status: DisposedITAT Delhi10 Nov 2025AY 2005-06

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Shri Vijay B. Basanta, CIT-DR

Section 10ASection 143(3)Section 254Section 92C

consistent. In Yokogawa, the Supreme Court held that section 10A income was to be excluded from the total income at the stage of gross total income, meaning such income was not chargeable to tax. The Court emphasized that relief provisions must be interpreted strictly within their statutory framework. Applying this ... Japan was generated by the Section 10A eligible unit. • In line with Yokogawa, such income is deducted at the initial stage of computing gross total income, meaning that it does not enter the taxable income base for that year. • As a result, there is no Indian tax payable on that

Canon India Pvt. Ltd, Gurugram vs. Neac, Delhi

In the result, to sum up and conclude:

ITA 585/DEL/2021[2003-04]Status: DisposedITAT Delhi10 Nov 2025AY 2003-04

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Shri Vijay B. Basanta, CIT-DR

Section 10ASection 143(3)Section 254Section 92C

Premium Tower Co Operative Housing Society, Mumbai vs. ITO Ward 24(3)(1), Mumbai

In the result, the appeal filed by the assessee stands partly allowed

ITA 2436/MUM/2025[2010-11]Status: DisposedITAT Mumbai03 Nov 2025AY 2010-11

Bench: Shri Sandeep Gosain

Section 250Section 80Section 80P(2)(d)

benefit u/s 80 P(2)(d)? 5. Section 80P provides that in case of assessee being a cooperative society, the gross total income which includes any income referred to sub-section 2 shall be deducted in accordance with subject to provision of this section. Sub-section 2 of section

Dy..C.I.T., Bangalore vs. M/S State Bank of Mysore, Bangalore

ITA 684/BANG/2015[2011-12]Status: DisposedITAT Mumbai03 Nov 2025AY 2011-12

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri Ketan Ved & Ninad PatadeFor Respondent: Shri P.C. Chhotaray, Spl. Counsel

Section 2Section 250Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)Section 41(1)

Amount for AY 2011-12 Profits and Gains of business before claiming 5,32,13,30,820 deduction u/s 36(1)(viii) [A] Gross Total Income (Schedule 13 & 14 of Profit & 45,34,25,43,685 Loss Account) [B] Interest received in respect of eligible business under

State Bank of Mysore, Bangalore vs. JCIT, Bangalore

ITA 661/BANG/2015[2011-12]Status: DisposedITAT Mumbai03 Nov 2025AY 2011-12

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri Ketan Ved & Ninad PatadeFor Respondent: Shri P.C. Chhotaray, Spl. Counsel

Section 2Section 250Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)Section 41(1)

DCIT, Circle-2(1)(1), Surat vs. The Surat Vankar Sahkari Sangh Limited, Surat

In the result, the appeal of the revenue is dismissed

ITA 77/SRT/2025[2017-18]Status: DisposedITAT Surat31 Oct 2025AY 2017-18

Bench: Ms. Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.77/Srt/2025 Assessment Year: (2017-18) (Hybrid Hearing) Dcit, Vs. The Surat Vankar Sahkari Sangh Circle – 2(1)(1), Limited, Surat Opp – Reshamwala Market, Ring Road, Surat - 395002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaat3159L (Appellant) (Respondent) Appellant By Shri Ravi Kant Gupta, Cit-Dr Respondent By Shri Hiren Vepari, Ca Date Of Hearing 19/08/2025 Date Of Pronouncement 30/10/2025

Section 143(2)Section 194A(3)(v)Section 250Section 80PSection 80P(1)Section 80P(2)(a)Section 80P(2)(d)Section 80P(4)

facts of the case in brief are that the assessee e-filed its return of income for AY 2017-18 on 27.10.2017, declaring gross total income of Rs.5,01,77,346/- and after claiming deduction under Chapter VIA of Rs.4,36,53,155/- and total income of Rs.65

Dindoshi Onkar Co-Operative Housing Society Limited, Mumbai vs. Income Tax Officer, Ward 41(3)(1), Mumbai

In the result, both the appeals are under consideration are allowed on the same terms noted above

ITA 5179/MUM/2025[2014-15]Status: DisposedITAT Mumbai30 Oct 2025AY 2014-15

Bench: Shri Narender Kumar Choudhryassessment Year: 2014-15 & Assessment Year: 2015-16 Dinodoshi Onkar Co- Centralised Processing Operative Housing Society Centre/Income Tax Limited Officer, Ward 41(3)(1), Building No. 17, Dindoshi Onkar Mumbai Vs. Co-Operative Housing Society Kautilya Bhavan, Bandra Limited, Gen. A.K. Vaidya Marg, Kurla Complex (East), Shivdham, Malad (East), Mumbai – 400051. Mumbai- 400097 Pan: Aaaad2593A (Appellant) (Respondent) Present For: Assessee By : Shri Rajesh Athavale Revenue By : Shri Praveen K. Srivastav, Ld. Sr.D.R. Date Of Hearing : 09.10.2025 Date Of Pronouncement : 30.10.2025 O R D E R Per : Narender Kumar Choudhry: These Appeals Have Been Preferred By The Assessee Against The Order Dated 24.06.2025, Impugned Herein, Passed By The National Faceless Appeal Center (Nfac)/ Ld. Additional Joint Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Ys. 2014-15 & 2015-16. 2. Both The Appeals Are Having Involved Identical Facts & Issue, Therefore, For The Sake Of Brevity, The Same Were Heard Together Dindoshi Onkar Co-Operative Housing Society Limited & Are Being Disposed Of By This Composite Order, By Taking Into Consideration The Ita No. 5179/M/2025 (A.Y. 2014-15) As The Lead Case & Result Of The Same Should Be Applicable Mutatis Mutandis To Both The Appeals Under Consideration.

For Appellant: Shri Rajesh AthavaleFor Respondent: Shri Praveen K. Srivastav, Ld. Sr.D.R

Section 143(1)Section 2(19)Section 250Section 80PSection 80P(1)Section 80P(2)(d)

Housing Society. Thus, if any income as referred to in sub-section (2) to section 80P of the Act is included in the gross total income of the Assessee, the same shall be allowed as a deduction. It is pertinent to note that since the Assessee is registered under

Dindoshi Co-Operative Housing Society Limited, Mumbai vs. Income Tax Officer, Ward 41(3)(1), Mumbai

ITA 5178/MUM/2025[2015-16]Status: DisposedITAT Mumbai30 Oct 2025AY 2015-16

Bench: Shri Narender Kumar Choudhry

For Appellant: Shri Rajesh AthavaleFor Respondent: Shri Praveen K. Srivastav, Ld. Sr.D.R

Section 143(1)Section 250Section 80PSection 80P(1)Section 80P(2)(d)

IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “SMC”, MUMBAI BEFORE SHRI NARENDER KUMAR CHOUDHRY, JUDICIAL MEMBER ITA No.5179/M/2025 Assessment

Bhupinder Singh Sidhu(HUF), Mohali vs. ITO, Ward 4(1), Chandigarh

In the result, appeal of the Assessee is allowed

ITA 1024/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh29 Oct 2025AY 2020-21

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 1024/Chd/2025 "नधा"रण वष" / Assessment Year : 2020-21 Bhupinder Singh Sidhu Huf, The Ito, बनाम House No. 1114, Sector 69, Ward 4(1) Mohali Chandigarh Vs. Punjab160069 "थायी लेखा सं./ Pan No: Aaghb9562C अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. M.R. Sharma, Advocate राज"व क" ओर से/ Revenue By : Sh. Vivek Vardhan, Add. Cit Dr, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 15.10.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 29.10.2025 आदेश/Order Per Krinwant Sahay, Am: Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 4.7.2025 Passed By The Ld. Commissioner Of Income Tax, National Faceless Appeal Centre (Nfac), Delhi For A.Y. 2020-21. 2. Grounds Of Appeal Are As Under:

For Appellant: Sh. M.R. Sharma, AdvocateFor Respondent: Sh. Vivek Vardhan, Add. CIT DR, Sr.DR

Section 143

onwards has been placed in the paper book. A copy of the return filed for the year under consideration shows that the gross total income of the appellant was Rs. 6000000/-and after deducting expenses of RS23 00000/- net agricultural income has been declared at Rs. 3700000/-. During the course

Yedapadavu Vyavasaya Seva Sahakara Sangha Niyamitha, Yedapadavu vs. Income Tax Officer, Mangaluru

In the result, both the appeals filed by the assessee are allowed

ITA 1919/BANG/2025[2018-19]Status: DisposedITAT Bangalore29 Oct 2025AY 2018-19

Bench: Shri Prashant Maharishi

For Appellant: Shri Sriram V. Rao, CA

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

facts of the case show that assessee is a co-operative society who filed its return of income on 24.10.2018 showing gross total income of Rs.36,73,878 and claimed deduction u/s. 80P of the same amount. The return was selected for limited scrutiny for verifying the investments

Yedapadavu Vyvasaya Sahakara Sangha Niyamitha, Yedapadavu vs. Income Tax Officer, Ward-2(2), Mangaluru

ITA 1878/BANG/2025[2020-21]Status: DisposedITAT Bangalore29 Oct 2025AY 2020-21

Bench: Shri Prashant Maharishi

For Appellant: Respondent byFor Respondent: Shri Sriram V. Rao, CA

Section 143(3)Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

facts of the case show that assessee is a co-operative society who filed its return of income on 24.10.2018 showing gross total income of Rs.36,73,878 and claimed deduction u/s.80P of the same amount. The return was selected for limited scrutiny for verifying the investments etc. and deduction

Vazhakkad Service Co-Operative Bank Limited, Malappuram vs. ITO, Ward-3, Tirur

In the result, the appeal filed by the assessee bearing ITA No

ITA 652/COCH/2025[2017-18]Status: DisposedITAT Cochin28 Oct 2025AY 2017-18

Bench: Shri Inturi Rama Rao & Shri Anikesh Banerjee

For Appellant: Shri Ramkumar Menon, CAFor Respondent: Smt. Leena Lal, Snr AR

Section 139Section 143(3)Section 250Section 80PSection 80P(2)(a)Section 80P(4)

deposit and pays interest for the same. The assessee filed the return under section 139 (1) of the Act. The assessee declared the gross total income in the return of income Rs 1,89,01,249/-. Also claim deduction under section 80P of the Act and declared the total income

Palas Gram Sewa Sahkari Samiti Limited, Sikar vs. ITO, Sikar

In the result, the appeal of the assessee is allowed for statistical

ITA 1017/JPR/2025[2020-2021]Status: DisposedITAT Jaipur28 Oct 2025AY 2020-2021

For Appellant: Sh. Jitendra Kumar, CAFor Respondent: Sh. Gajendra Singh, Addl. CIT

Section 144Section 250Section 253(5)Section 80A(2)Section 80PSection 80P(2)(a)

order under Section 144 ex parte, without adjudicating on the legal question of whether deduction under Section 80P could exceed the assessee's Gross Total Income. The CIT(A) failed to examine the contents of the return or consider the legal bar under Section 80A(2), resulting in a mechanically ... sustained addition of 34,49,015/- by disallowing Deduction under section 80P against Gross total income of Rs.21479/- and thereby breaching the principles of reasoned and just appellate adjudication. 2. That on the facts and circumstances of the case, the Learned Assessing Officer erred in disallowing the entire deduction