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“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
82
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
73
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
67
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
47
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
35
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

Dy. Commissioner of Income Tax, Mumbai vs. Tata Social Welfare Trust, Mumbai

In the result, appeals are dismissed

ITA 2484/MUM/2025[2010-11]Status: DisposedITAT Mumbai10 Oct 2025AY 2010-11

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Appellant: Shri P.J. Pardiwala a/w ShriFor Respondent: Shri Ritesh Mishra, CIT DR
Section 10Section 10(34)Section 11Section 13(1)(d)Section 143(3)Section 147Section 164(2)Section 3Section 7

notification dated 15th December, 1993. Therefore, the deduction under Section 80G of the Act was not restricted to 10% of the gross total income as deduction granted to the specified entities and therefore, 50% of the above amount was allowed. The learned CIT (A) has restored the matter back ... statutory limit prescribed under Section 80G(4) of the Act. As per Section 80G(4), the aggregate deduction cannot exceed 10% of Gross Total Income, and the restriction made by the AO was in accordance 12 ITA 2483 to 2486/Mum/2025 ITA 2475, 3441 and 3442/Mum/2025 Tata Social Welfare Trust, with

Dy. Commissioner of Income Tax 26(1), Mumbai, Kautilya Bhawan, Bkc vs. Tata Social Welfare Trust, Mumbai

In the result, appeals are dismissed

ITA 2483/MUM/2025[2008-09]Status: DisposedITAT Mumbai10 Oct 2025AY 2008-09

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Appellant: Shri P.J. Pardiwala a/w ShriFor Respondent: Shri Ritesh Mishra, CIT DR
Section 10Section 10(34)Section 11Section 13(1)(d)Section 143(3)Section 147Section 164(2)Section 3Section 7

notification dated 15th December, 1993. Therefore, the deduction under Section 80G of the Act was not restricted to 10% of the gross total income as deduction granted to the specified entities and therefore, 50% of the above amount was allowed. The learned CIT (A) has restored the matter back ... statutory limit prescribed under Section 80G(4) of the Act. As per Section 80G(4), the aggregate deduction cannot exceed 10% of Gross Total Income, and the restriction made by the AO was in accordance 12 ITA 2483 to 2486/Mum/2025 ITA 2475, 3441 and 3442/Mum/2025 Tata Social Welfare Trust, with

Tata Social Welfare Trust, Mumbai vs. ACIT-17(3), Mumbai

In the result, appeals are dismissed

ITA 2475/MUM/2025[2015-16]Status: DisposedITAT Mumbai10 Oct 2025AY 2015-16

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Appellant: Shri P.J. Pardiwala a/w ShriFor Respondent: Shri Ritesh Mishra, CIT DR
Section 10Section 10(34)Section 11Section 13(1)(d)Section 143(3)Section 147Section 164(2)Section 3Section 7

notification dated 15th December, 1993. Therefore, the deduction under Section 80G of the Act was not restricted to 10% of the gross total income as deduction granted to the specified entities and therefore, 50% of the above amount was allowed. The learned CIT (A) has restored the matter back ... statutory limit prescribed under Section 80G(4) of the Act. As per Section 80G(4), the aggregate deduction cannot exceed 10% of Gross Total Income, and the restriction made by the AO was in accordance 12 ITA 2483 to 2486/Mum/2025 ITA 2475, 3441 and 3442/Mum/2025 Tata Social Welfare Trust, with

Assistant Commissioner of Income Tax, Kautilya Bhavan, Bkc, Mumbai vs. Tata Education Trust, Mumbai

In the result, Revenue’s appeal is dismissed

ITA 4852/MUM/2024[2013-14]Status: DisposedITAT Mumbai10 Oct 2025AY 2013-14

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Appellant: Shri P.J. Pardiwala a/w ShriFor Respondent: Shri Ritesh Mishra, CIT DR
Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 234B

considering assessee’s claim, the AO observed that as per Section 80G(4) of the Act donation made in excess of 10% of gross total income has to be ignored for the purpose of computation of aggregate of sum in respect of which deduction is to be allowed ... Accordingly, he restricted assessee’s claim of deduction u/s. 80G of the Act to the extent of 10% of gross total income or the actual claim whichever is less. 43. In so far as claim of deduction u/s. 80GGA of the Act, the AO observed that such claim

Tata Education Trust, Mumbai vs. Assistant Commissioner of Income Tax-17(3), Mumbai

In the result, Revenue's appeal is dismissed

ITA 4835/MUM/2024[2017-18]Status: DisposedITAT Mumbai10 Oct 2025AY 2017-18

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 234B

considering assessee's claim, the AO observed that as per Section 80G(4) of the Act donation made in excess of 10% of gross total income has to be ignored for the purpose of computation of aggregate of sum in respect of which deduction is to be allowed u/s.80G ... Accordingly, he restricted assessee's claim of deduction u/s.80G of the Act to the extent of 10% of gross total income or the actual claim whichever is less. 43. In so far as claim of deduction u/s.80GGA of the Act, the AO observed that such claim was not made

Tata Education Trust, Mumbai vs. Assistant Commissiioner of Income Tax Circle 17(3), Mumbai

In the result, Revenue’s appeal is dismissed

ITA 4727/MUM/2024[2016-17]Status: DisposedITAT Mumbai10 Oct 2025AY 2016-17

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Appellant: Shri P.J. Pardiwala a/w ShriFor Respondent: Shri Ritesh Mishra, CIT DR
Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 234B

considering assessee’s claim, the AO observed that as per Section 80G(4) of the Act donation made in excess of 10% of gross total income has to be ignored for the purpose of computation of aggregate of sum in respect of which deduction is to be allowed ... Accordingly, he restricted assessee’s claim of deduction u/s. 80G of the Act to the extent of 10% of gross total income or the actual claim whichever is less. 43. In so far as claim of deduction u/s. 80GGA of the Act, the AO observed that such claim

Tata Education Trust, Mumbai vs. Assistant Commissioner of Income Tax Circle -17(3), Mumbai

In the result, Revenue's appeal is dismissed

ITA 4496/MUM/2024[2016-17]Status: DisposedITAT Mumbai10 Oct 2025AY 2016-17

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Appellant: Shri P.J. Pardiwala a/w ShriFor Respondent: Shri Ritesh Mishra, CIT DR
Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 234B

considering assessee's claim, the AO observed that as per Section 80G(4) of the Act donation made in excess of 10% of gross total income has to be ignored for the purpose of computation of aggregate of sum in respect of which deduction is to be allowed u/s.80G ... Accordingly, he restricted assessee's claim of deduction u/s.80G of the Act to the extent of 10% of gross total income or the actual claim whichever is less. 43. In so far as claim of deduction u/s.80GGA of the Act, the AO observed that such claim was not made

Assistant Commissioner of Income Tax- 26(1), Mumbai vs. Tata Education Trust, Mumbai

In the result, Revenue's appeal is dismissed

ITA 4419/MUM/2024[2014-15]Status: DisposedITAT Mumbai10 Oct 2025AY 2014-15

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 234B

considering assessee's claim, the AO observed that as per Section 80G(4) of the Act donation made in excess of 10% of gross total income has to be ignored for the purpose of computation of aggregate of sum in respect of which deduction is to be allowed u/s.80G ... Accordingly, he restricted assessee's claim of deduction u/s.80G of the Act to the extent of 10% of gross total income or the actual claim whichever is less. 43. In so far as claim of deduction u/s.80GGA of the Act, the AO observed that such claim was not made

Tata Education Trust, Mumbai vs. Deputy Commissioner of Income Tax (Exeption) -Circle 2(1), Mumbai

In the result, Revenue's appeal is dismissed

ITA 4283/MUM/2024[2013-14]Status: DisposedITAT Mumbai10 Oct 2025AY 2013-14

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 234B

considering assessee's claim, the AO observed that as per Section 80G(4) of the Act donation made in excess of 10% of gross total income has to be ignored for the purpose of computation of aggregate of sum in respect of which deduction is to be allowed u/s.80G ... Accordingly, he restricted assessee's claim of deduction u/s.80G of the Act to the extent of 10% of gross total income or the actual claim whichever is less. 43. In so far as claim of deduction u/s.80GGA of the Act, the AO observed that such claim was not made

Tata Education Trust, Mumbai vs. Deputy Commissioner of Income Tax (Exemption)-Circle 2(1), Mumbai

In the result, Revenue’s appeal is dismissed

ITA 4282/MUM/2024[2014-15]Status: DisposedITAT Mumbai10 Oct 2025AY 2014-15

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Appellant: Shri P.J. Pardiwala a/w ShriFor Respondent: Shri Ritesh Mishra, CIT DR
Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 234B

considering assessee’s claim, the AO observed that as per Section 80G(4) of the Act donation made in excess of 10% of gross total income has to be ignored for the purpose of computation of aggregate of sum in respect of which deduction is to be allowed ... Accordingly, he restricted assessee’s claim of deduction u/s. 80G of the Act to the extent of 10% of gross total income or the actual claim whichever is less. 43. In so far as claim of deduction u/s. 80GGA of the Act, the AO observed that such claim

Tata Education Trust, Mumbai vs. ACIT-17(3), Mumbai

In the result, Revenue's appeal is dismissed

ITA 4156/MUM/2024[2015-16]Status: DisposedITAT Mumbai10 Oct 2025AY 2015-16

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Appellant: Shri P.J. Pardiwala a/w Shri Sukhsagar & Shri Atul SuraiyaFor Respondent: Shri Ritesh Mishra, CIT DR
Section 10(34)Section 10(35)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 13(2)(h)Section 143(3)Section 234B

considering assessee's claim, the AO observed that as per Section 80G(4) of the Act donation made in excess of 10% of gross total income has to be ignored for the purpose of computation of aggregate of sum in respect of which deduction is to be allowed u/s.80G ... Accordingly, he restricted assessee's claim of deduction u/s.80G of the Act to the extent of 10% of gross total income or the actual claim whichever is less. 43. In so far as claim of deduction u/s.80GGA of the Act, the AO observed that such claim was not made

Sh. Rajesh Narendrabhai Patel, Vadodara vs. Income Tax Officer, Ward 1(2)(2), Vadodara

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

ITA 1592/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad09 Oct 2025AY 2012-13

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokarasstt.Year : 2012-13 Shri Rajesh Narendrabhai Patel Ito, Ward-1(2)(2) Baroda Bolt & Engineering Works Vadodara. Opp: Lalbaug Atitigruh Pratapnagar Vadodara Pan : Acqpp 6089 C (Applicant) (Responent) Assessee By : None : Shri B.P. Srivastava, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 06/10/2025 घोषणा क" तारीख /Date Of Pronouncement: 09/10/2025 आदेश आदेश/O R D E R आदेश आदेश

For Appellant: None
Section 143(3)Section 147Section 148Section 50C(2)Section 54Section 80C

Particulars Amount (Rs.) Income from House Property 15,54,000/- Long Term Capital Gain 62,60,142/- Income from Other Sources 91,168/- Gross Total Income 79,05,310/- Less: Deduction u/s 80C 30,000/- Total Income Assessed 78,75,310/- 2.8 Penalty proceedings under sections 271F

S M Associates, Taloja vs. Income Tax Officer, Panvel

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 1748/PUN/2025[2018-19]Status: DisposedITAT Pune09 Oct 2025AY 2018-19

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1748/Pun/2025 िनधा"रण वष" / Assessment Year : 2018-19 S. M. Associates, Vs. Ito, National E- Shop No.6, S.M. Plaza, Assessment Centre, Sector- 23, Taloja, Delhi. Raigad- 410208. Pan : Adjfs7283H Appellant Respondent Assessee By : Shri Shridhar Achari Revenue By : Shri Bharat Andhale Date Of Hearing : 07.10.2025 Date Of Pronouncement : 09.10.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 18.06.2025 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2018-19. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. The A.O. Has Erred In Law & On Facts In Making Additions To Gross Total Income By Rs.3,02,00,000/- Which Capital Contribution By Partners To The Partnership Firm. 2. The A.O. Has Erred In Law & On Facts In Initiating Penalty U/S.271(1)(C) & U/S.271Aac(1). 3. The Order Appealed Against Is Illegal, Invalid & Void-Ab- Initio.”

For Appellant: Shri Shridhar AchariFor Respondent: Shri Bharat Andhale
Section 143(2)Section 143(3)Section 271(1)(c)Section 271ASection 68

appellant has raised the following grounds of appeal :- “1. The A.O. has erred in law and on facts in making additions to Gross Total Income by Rs.3,02,00,000/- which Capital Contribution by partners to the Partnership firm. 2. The A.O. has erred in law and on facts

Padmanaban Sukhumaran, Bangalore vs. ACIT, Circle-5(3)(1), Bangalore

In the result, the appeal filed by the assessee towards the interest claimed u/s

ITA 950/BANG/2025[2017-18]Status: DisposedITAT Bangalore09 Oct 2025AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri Ravishankar, AdvocateFor Respondent: Shri Subramanian S, JCIT-DR
Section 234ASection 24Section 250

issue on merits. 3. Briefly stated the facts of the case are that the assessee filed revised return of income on 21/07/2017 declaring gross total income at Rs. 83,48,789/- and claimed the deduction under Chapter VIA of Rs. 1,77,398/-. The gross total income shown

ITO-19(2)(4), Mumbai vs. Narpatchand Devichandji Mehta HUF, Grant Road

In the result, appeal filed by the Revenue Department stands dismissed

ITA 4251/MUM/2025[2022]Status: DisposedITAT Mumbai09 Oct 2025

Bench: Shri Narender Kumar Choudhry & Shri Omkareshwar Chidaraito, Ward-19(2)(4), Narpatchand Devichandji Mumbai. Mehta Huf, Shop No. 5, 21 R.K. Building No.2 Co-Op. Vs. Housing Society Ltd., 9Th Khetwadi, Lane Grant Road, Mumbai-400 004 Pan: Aaahm 0640 L (Appellant) (Respondent)

For Appellant: Shri Nishit Gandhi &For Respondent: Shri Leyaqat Ali Aafaqui, Ld. Sr.D.R
Section 250Section 68

High liabilities as compared to low income/receipts (ii) Substantial loans given by the Assessee as per Form 3CD of debtors in comparison to Gross Total Income shown in the ITR 2.1 The Assessing Officer (AO) observed that during the assessment proceedings, the Assessee had taken various loans from the following

Kca Cooperative Credit Society Ltd, Mumbai vs. ITO Ward 22(2)(1), Piramal Chambers

ITA 3368/MUM/2025[2020-21]Status: DisposedITAT Mumbai09 Oct 2025AY 2020-21

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am

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

Vitp Private Limited, Hyderabad vs. DCIT., Circle8(1), Hyderabad

In the result, the appeal of the assessee in ITA

ITA 574/HYD/2024[AY 2017-18]Status: DisposedITAT Hyderabad08 Oct 2025

Bench: Shri Ravish Sood (Judicial Member), Shri Madhusudan Sawdia (Accountant Member)

For Appellant: Advocates Percy Perdiwala and Mahima GoudFor Respondent: : Shri Shahnawaz-ul-Rahman
Section 115JSection 143(3)Section 263Section 43(6)Section 80I

assessee demonstrated the eligibility for deduction of Rs.22,80,95,375/- u/s 80IA of the Act from eligible units. However, the gross total income of the assessee was Rs.15,96,77,696/-, which is less than the eligible deduction of Rs.22,80,95,375/-. As per the provisions of section ... only restriction is that the deduction cannot exceed gross total income of the assessee. There is no restriction provided under the Act, that the gross total income should only consist of business income. In support of their submission, reliance was placed on the decision of the Hon’ble Supreme Court

Vitp Private Limited, Hyderabad vs. DCIT., Circle8(1), Hyderabad

ITA 573/HYD/2024[AY 2017-18]Status: DisposedITAT Hyderabad08 Oct 2025

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं / Ita Nos.573 & 574/Hyd/2024 (निर्धारण वर्ष/Assessment Year: 2017-18) Vitp Private Limited Vs. Dy. Cit Hyderabad Circle 8 (1) Pan:Aaccv2672G Hyderabad (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Advocates Percy Perdiwala & Mahima Goud राजस्व द्वारा / Revenue By:: Shri Shahnawaz-Ul-Rahman, Cit(Dr) सुनवाई की तारीख / Date Of Hearing: 23/09/2025 घोषणा की तारीख / Pronouncement: 08/10/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: These Two Appeals Are Filed By Vitp Private Limited (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Principal Commissioner Of Income Tax-2, Hyderabad, (“Ld.Pcit”), Dated 30/03/2024 For The A.Y.2017-18. As Both The Appeals Are Interrelated & Belongs To The Same, Both Are Heard Together & One Consolidated Order Is Being Passed For The Sake Of Brevity.

For Appellant: Advocates Percy Perdiwala andFor Respondent: : Shri Shahnawaz-ul-Rahman
Section 143(3)Section 144BSection 144C(3)Section 263Section 80Section 801A

without appreciating the fact that the Company has restricted its claim of deduction under Section 801A of the Act to the extent of Gross Total Income ("GTI") declared by the Company in its revised ROI for AY 2017-18. 9.5 The learned PCIT has erred in law and on facts ... assessee demonstrated the eligibility for deduction of Rs.22,80,95,375/- u/s 80IA of the Act from eligible units. However, the gross total income of the assessee was Rs.15,96,77,696/-, which is less than the eligible deduction of Rs.22,80,95,375/-. As per the provisions of section

Jagdish Solanki, Jhabua vs. Income Tax Officer Jhabua, Jhabua

ITA 169/IND/2025[2017-18]Status: DisposedITAT Indore07 Oct 2025AY 2017-18

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

आयकर अपीलीय अधिकरण, इंदौर न्यायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT

Chiloda Seva Sahakari Mandali Limited, Gandhinagar vs. The ITO, Ward-1 (Previously Ward-5), Gandhinagar

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

ITA 837/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad07 Oct 2025AY 2017-18

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2017-18

For Appellant: Shri Rameshchandra B. Patel, A.RFor Respondent: Shri Kamal Deep Singh, Sr. D.R
Section 139Section 139(1)Section 142(1)Section 144Section 250Section 80ASection 80A(5)Section 80PSection 80P(2)

return filed on 17-10-2019 as nonest. The assessee society derived total income at nil in their computation sheet after claiming entire gross total income as deduction u/s. Chapter 6A of the Act. The Assessing Officer held that the assessee neither filed the return of 2 I.T.A No. 837/Ahd/2025