“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

Diamines & Chemicals Limited, Vadodara vs. The ACIT, Circle-1(1)(1), Vadodara

In the result, both the issues relating to disallowance of deduction

ITA 1543/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad07 Oct 2025AY 2017-18

Bench: S/Shri Sanjay Garg

For Appellant: Shri Vimal Desai, ARFor Respondent: Shri Rameshwar P. Meena, Sr.DR

Section 115JSection 142(1)Section 143(3)Section 270ASection 80I

same rendered the case liable for penalty proceedings under section 270A of the Act. 2.5 On the above adjustments, the AO computed the gross total income at Rs.7,06,46,336/-, allowed deduction u/s 80IA at Rs.1,64,53,971/-, assessed total income at Rs.5,41,92,370/-, and determined

JCIT OSD Circle 2(3)(1), Mumbai vs. Hdfc Bank Limited, Mumbai

In the result, both the above stated appeals of the

ITA 2260/MUM/2025[2021-22]Status: DisposedITAT Mumbai06 Oct 2025AY 2021-22

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Yogesh Thar, ARFor Respondent: Shri Ritesh Misra, (CIT-DR)

Section 143(3)Section 144Section 14A

JCIT(OSD) Circle 2(3)(1), Mumbai vs. Hdfc Bank Limited, Mumbai

In the result, both the above stated appeals of the

ITA 2259/MUM/2025[2019-20]Status: DisposedITAT Mumbai06 Oct 2025AY 2019-20

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

Section 143(3)Section 144Section 14A

JCIT(OSD) Circle 2(3)(1), Mumbai vs. Hdfc Bank Limited, Mumbai

In the result, both the above stated appeals of the

ITA 2258/MUM/2025[2020-21]Status: DisposedITAT Mumbai06 Oct 2025AY 2020-21

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Yogesh Thar, ARFor Respondent: Shri Ritesh Misra, (CIT-DR)

Section 143(3)Section 144Section 14A

suns on which deduction shall be allowed to the assessee. Section 80G falls in Chapter VIA, which comes into play only after the gross total income has been computed by applying the computation provisions under various heads of income, including the Explanation 2 to section ... suns on which deduction shall be allowed to the assessee. Section 80G falls in Chapter VIA, which comes into play only after the gross total income has been computed by applying the computation provisions under various heads of income, including the Explanation 2 to section

Hdfc Bank Limited, Mumbai vs. DCIT - 2 (3) (1), Mumbai

In the result, both the above stated appeals of the

ITA 1573/MUM/2025[2020-21]Status: DisposedITAT Mumbai06 Oct 2025AY 2020-21

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Yogesh Thar, ARFor Respondent: Shri Ritesh Misra, (CIT-DR)

Section 143(3)Section 144Section 14A

Hdfc Bank Limited, Mumbai vs. The Deputy Commissioner of Income Tax - 2 (3) (1), Mumbai

ITA 1555/MUM/2025[2019-20]Status: DisposedITAT Mumbai06 Oct 2025AY 2019-20

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Yogesh Thar, ARFor Respondent: Shri Ritesh Misra, (CIT-DR)

Section 143(3)Section 144Section 14A

Asst. Commissioner of Income Tax -7(1)(1), Mumbai vs. Horizon Packs Pvt. Ltd., Mumbai

In the result, appeals by the revenue are dismissed

ITA 6096/MUM/2024[2020-21]Status: DisposedITAT Mumbai06 Oct 2025AY 2020-21

Bench: Shri Saktijit Dey, Hon'Ble & Shri Narendra Kumar Billaiya, Hon'Ble

For Appellant: Shri Nitesh Joshi, A/RFor Respondent: Shri Ritesh Mishra, CIT D/R

Section 143(2)Section 32Section 801A

opinion that Section 80G of the Act falls in Chapter VIA which comes into action only after the gross total income has been computed by applying the computation provisions under various heads of income and there is no co-relation between Section 37 r.w. Explanation 2 and Section

Assistant Commissioner of Income Tax -7(1)(1), Mumbai vs. Horizon Packs Pvt. Ltd., Mumbai

In the result, appeals by the revenue are dismissed

ITA 5950/MUM/2024[2018]Status: DisposedITAT Mumbai06 Oct 2025

Bench: Shri Saktijit Dey, Hon'Ble & Shri Narendra Kumar Billaiya, Hon'Ble

For Appellant: Shri Nitesh Joshi, A/RFor Respondent: Shri Ritesh Mishra, CIT D/R

Section 143(2)Section 32

Vasai Urban Cooperative C Redit Society Ltd, Vasai vs. PCIT-1, Thane

In the result, the appeal by the assessee allowed

ITA 2622/MUM/2025[2020-21]Status: DisposedITAT Mumbai01 Oct 2025AY 2020-21

Bench: SHRI OM PRAKASH KANT (Accountant Member), MS. KAVITHA RAJAGOPAL (Judicial Member)

For Appellant: Shri Bhupendra ShahFor Respondent: Shri Vivek Perampurna (CIT-DR)

Section 143(3)Section 263Section 56Section 80P(2)Section 80P(2)(d)

members only. 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

Bsel Tech Park Premisies Co Operative Society Ltd, Mumbai vs. Commissioner of Income Tax (Appeal), Mumbai

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

ITA 4458/MUM/2025[2018-19]Status: DisposedITAT Mumbai30 Sept 2025AY 2018-19

Bench: Shri Om Prakash Kant & Shri Narender Kumar Choudhryassessment Year: 2018-19 M/S. Bsel Tech Park Commissioner Of Income Premisies Co-Operative Tax, Society Ltd., 4Th Floor, Tower 6, Bsel Tech Park, Vs. Vashi Station Complex, Opp Infotech Park, Vashi Vashi Maharashtra – 400 075 Navi Mumbai – 400 703 Pan: Aacab1755G (Appellant) (Respondent) Present For: Assessee By : Ms. Naina Chaurasia, Ld. C.A. Revenue By : Shri Leyaqaat Ali Aafaqui, Ld. Sr. Dr Date Of Hearing : 01.09.2025 Date Of Pronouncement : 30.09.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 26.05.2025, Impugned Herein, Passed By The National Faceless Appeal Center (Nfac)/ Ld. 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.Y. 2018-19. 2. In The Instant Case, The Assessing Officer (Ao) Disallowed The Deduction Claimed U/S 80P(2)(D) Of The Act On Account Of Interest Income Earned From Co-Operative Banks To The Tune Of Rs.28,30,300/- As Detailed Below:

For Appellant: Ms. Naina Chaurasia, Ld. C.AFor Respondent: Shri Leyaqaat Ali Aafaqui, Ld. Sr. DR

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

Anuh Pharma Limited, Mumbai vs. Principal Commissioner of Income Tax, Circle -5, Mumbai

ITA 2911/MUM/2025[2020-21]Status: DisposedITAT Mumbai30 Sept 2025AY 2020-21

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant ()

Section 143(3)Section 263Section 80Section 80GSection 80I

made in computing total income 80A. (1) In computing the total income of an assessee, there shall be allowed from his gross total income, in accordance with and subject to the provisions of this Chapter, the deductions specified in sections 80C to 80U. 1.7 Further, section ... states, expenses will not be allowed in computation of business income. Whereas section 80G of the Act state of deduction from the gross total income (i.e. aggregate of all five head of income). Thus, the meaning of "expenses" and "deduction" are different. Expenses are allowed from the business income. While

Suthakar Selvaraj, Mysuru vs. Income Tax Officer, Ward-1(2), Mysuru

In the result appeal filed by the assessee is allowed

ITA 1656/BANG/2025[2017-18]Status: DisposedITAT Bangalore29 Sept 2025AY 2017-18

Bench: Shri Prashant Maharishiassessment Year : 2017-18

For Appellant: Shri Vageesh Hegde, CAFor Respondent: Shri Ganesh R. Ghale, Advocate

Section 143Section 154Section 69A

been sanctioned a housing loan from IDBI Bank. Assessee submitted F.No.16, promotion letter. As per the letter the annual gross total income of the assessee is ₹ 930,817. After claiming deduction, it was shown as ₹ 806,320/-. The increase in salary was also explained. The learned assessing officer examined

Income Tax Officer, Ward-1, Hassan vs. Prathamika Krushi Pattina Sahakara Sanga Niyamitha Kenchammanahosakote, Hosakorte Post, Alur Taluk

In the result, the appeal filed by the revenue as well as the cross objection filed by the assessee are dismissed

ITA 2382/BANG/2024[2018-19]Status: DisposedITAT Bangalore29 Sept 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2018-19

For Appellant: Shri Tharun Kothari, CAFor Respondent: Shri Subramanian .S, JCIT-DR

Section 148Section 148ASection 69A

issued. Subsequently, the assessee filed Page 4 of 10 ITA No. 2382/Bang/2024 & C.O. No. 06/Bang/2025 their return of income on 18/08/2022 declaring a gross total income of Rs. 3,71,446/-. The assessee had declared a Nil total income on the ground that the entire gross total income is eligible

Colgate Palmolive (India) Limited, Mumbai vs. Principal Commissioner of Income Tax -6, Mumbai

In the result, appeal of the assessee is allowed

ITA 3293/MUM/2025[2018-19]Status: DisposedITAT Mumbai29 Sept 2025AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

For Appellant: Shri J D Mistry, Sr. AdvocateFor Respondent: Shri R A Dhyani, CIT DR

Section 143(3)Section 144Section 263Section 37(1)Section 80G

term capital gain on maturity of a Bond Long term capital Gain on sale - - by way of Slump Sale Less: Brought forward loss - - GROSS TOTAL INCOME 9,94,67,32,883 Chapter VI A deduction: Section 80G(2)-Donations 1,50,00,000 Section 80JJAA – Workmen

ACIT(It)-4(3)(2), Mumbai vs. Wells Fargo Bank National Association, Mumbai

ITA 3795/MUM/2024[2013-14]Status: DisposedITAT Mumbai26 Sept 2025AY 2013-14

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawal

For Appellant: Shri Niraj Sheth, AdvocateFor Respondent: Shri Krishna Kumar, Sr. DR

Section 139(1)Section 143(3)Section 147

reassessment proceedings resulting into total income reassessed at Rs.36,59,84,420/-. The details are tabulated below: Particulars Amount (Rs.) Gross Total Income as per assessment order under section 143(3) r.w.s.144C(3), dated 08.02.2018 33,51,10,090 Add: Income attributable to the LO as disclosed in ROI filed

ACIT(It)-4(3)(2), Mumbai vs. Wells Fargo Bank National Association, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 3794/MUM/2024[2014-15]Status: DisposedITAT Mumbai26 Sept 2025AY 2014-15

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawal

For Appellant: Shri Niraj Sheth, AdvocateFor Respondent: Shri Krishna Kumar, Sr. DR

Section 139(1)Section 143(3)Section 147

reassessment proceedings resulting into total income reassessed at Rs.36,59,84,420/-. The details are tabulated below: Particulars Amount (Rs.) Gross Total Income as per assessment order under section 33,51,10,090 143(3) r.w.s. 144C(3), dated 08.02.2018 Add: Income attributable to the LO as disclosed

Mohan Roshan, Bengaluru vs. Income Tax Officer, Ward-7(2)(5), Bangalore

In the result, appeal filed by theassessee is dismissed

ITA 1390/BANG/2025[2018-19]Status: DisposedITAT Bangalore25 Sept 2025AY 2018-19

Bench: Shri Laxmi Prasad Sahuassessment Year : 2018-19 Shri. Roshan Mohan, Vs. Ito, M-30C, Forest Quarters, 18Th Main, Ward – 7(2)(5), Malleshwaram, Bangalore. Bangalore – 560 055. Pan : Ajqpr 4955 Q Appellant Respondent Assessee By : Shri. Deepak Chopra, Ca Revenue By : Shri. Ganesh R. Ghale, Advocate, Standing Counsel For Revenue. Date Of Hearing : 10.09.2025 Date Of Pronouncement : 25.09.2025

For Appellant: Shri. Deepak Chopra, CAFor Respondent: Shri. Ganesh R. Ghale, Advocate, Standing Counsel for Revenue

Section 194JSection 44A

44ADA of the Act, presumptive profits of Rs.16,44,968/-. Later on 28.03.20-18, assessee has revised his return of income and computed gross total income from business / profession of Rs.3,07,001/- and the entire receipts were computed as income under section 44AD of the Act. The revised return

Income Tax Officer, Mumbai vs. K K Ventura, Mumbai

In the result, the appeal of the Revenue stands

ITA 5331/MUM/2024[2018-19]Status: DisposedITAT Mumbai25 Sept 2025AY 2018-19

Section 133(6)Section 143(3)Section 144BSection 260Section 68

section 133(6) was examined. The examination of ITR shows that ITR has been filed at total income of Rs.5,76,270/-and gross total income of Rs.7,41,268/ which includes interest of Rs.6,04,810/- received from the assessee firm on loan under consideration. This show that lender

Manpowergroup Services India Private Limited, Delhi vs. Assistant Commissioner of Income Tax, Central Circle 2, Delhi, Jhandewalan Extension, New Delhi

In the result, the appeal of the assessee in ITA No

ITA 3585/DEL/2024[2020-2021]Status: DisposedITAT Delhi25 Sept 2025AY 2020-2021

Bench: Shri Mahavir Singh & Shri Naveen Chandra

For Appellant: Shri S.K. Agarwal, ARFor Respondent: Shri Dharm Veer Singh, CIT-DR

Section 143(3)Section 80JSection 92CSection 92D

above, the Assessee prays for consequential relief of deduction u/s 80JJAA of the Act to the extent of assessed Gross Total income. 5 . That on the facts and in the circumstances of the case and in law, the AO, Transfer Pricing Officer ('TPO') and DRP erred in enhancing the income ... 80JJAA of the Act is concerned, the same is reproduced below: [Deduction in respect of employment of new employees. 80JJAA. (1) Where the gross total income of an assessee to whom section 44AB applies, includes any profits and gains derived from business, there shall, subject to the conditions specified

Pankaj Kumar Mittal, Dholpur vs. Income Tax Officer Ward 4 Bharatpur, Bharatpur

In the result, stands allowed

ITA 393/JPR/2025[2018-2019]Status: DisposedITAT Jaipur24 Sept 2025AY 2018-2019

For Appellant: Shri Rahul Pandya, AdvFor Respondent: Shri Gautam Singh Choudhary, JCIT

Section 144Section 144ASection 148Section 271ASection 44A

NEAR AVM SCHOOL MAIN MARKET Town/City/District DHOLPUR Rajasthan State Designation of AO(Ward/Circle) ITO WD 4, BHARATPUR E-filing Acknowledgement Number 601911330290422 1 Gross total income 2 Deductions under Chapter-VI-A 3 Total Income 3a Current Year loss, if any PAN APXPM0304B Area/Locality Flat/Door/Block No MANIYA Pin/Zip Code