“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

Assistant Commissioner of Income Tax -16(1), Mumbai vs. Eagle Fims, Mumbai

In the result, the grounds of

ITA 3204/MUM/2025[2017-18]Status: DisposedITAT Mumbai24 Sept 2025AY 2017-18

Bench: Shri Pawan Singh& Smt.Renu Jauhri(Physical Hearing)

Section 2(14)Section 254(1)Section 55(2)(a)

business and were profit earning apparatus. 4. The Ld.CIT(A) on considering the submission of assessee noted that Assessing Officer computed tax on gross total income and in the computation sheet income has assessed at Rs.16.33 crores. The Assessing Officer was directed to verify the correct figure both

DCIT Akola Circle, Akola vs. The Akola Janata Commercial Co-Operative Bank Ltd., Akola

In the result, Revenue’s appeal is dismissed

ITA 189/NAG/2025[2020-21]Status: DisposedITAT Nagpur22 Sept 2025AY 2020-21

Bench: Shri Narender Kumar Choudhry & Shri K.M. Roy, Accountant, Member

For Appellant: Shri S.G. GandhiFor Respondent: Shri Pankaj Kumar

Section 143(1)Section 143(3)Section 147Section 154

cooperative society by way of invest for dividend from its investments with other co-op society if such income is included in the gross total income of the such co-op society. In view of these facts and circumstances we are of the considered view that the assessee is entitled ... society by way of interest or dividend from its investments [Q\ "with other co-op society if such income is included in the gross total income of the such Co-op society. In view these facts and circumstances we are of the considered view that the assessee is entitled

Dadar Avanti Co-Operative Housing Society Limited, Dadar Mumbai vs. Income Tax ITO Ward 22(1)(6), Mumbai

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

ITA 3429/MUM/2025[2013-2014]Status: DisposedITAT Mumbai22 Sept 2025AY 2013-2014

Bench: Shri Sandeep Gosain

Section 250Section 80PSection 80P(2)(a)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

Township Real Estate Developers Private Limited, Mumbai vs. Principal Commissioner of Income Tax -6, Mumbai

In the result, grounds of appeal raised by the assessee are allowed

ITA 3303/MUM/2025[2020-21]Status: DisposedITAT Mumbai19 Sept 2025AY 2020-21

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankartownship Real Estate V/S. Principal Commissioner Of Developers Private Limited, बनाम Income Tax– 6, Room No. C-62, Vibgyor Tower, Bandra 501, 5Th Floor, Aaykar Kurla Complex, Bandra - East, Bhawan, Maharishi Karve Mumbai –400 051, Maharashtra Road, Mumbai–400020, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aabct7356E Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Nishith Khatri, ARFor Respondent: Shri Ritesh Misra, (CIT-DR)

Section 135Section 143(3)Section 144BSection 263Section 80G

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

M/S Enam Asset Management Company Private Limited, Mumbai vs. PCIT-3, Mumbai

In the result, grounds of

ITA 2756/MUM/2025[2020-21]Status: DisposedITAT Mumbai19 Sept 2025AY 2020-21

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Dharan Gandhi,ARFor Respondent: Shri Hemanshu Joshi, (Sr. DR)

Section 135Section 142(1)Section 143(3)Section 263Section 37Section 37(1)Section 80G

Email Pharmaceuical Industries Pvt Ltd, Mumbai vs. PCIT-4, Mumbai

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

ITA 2079/MUM/2025[2020-21]Status: DisposedITAT Mumbai19 Sept 2025AY 2020-21

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarm/S Emil Pharmaceutical V/S. Principal Commissioner Of Industries Pvt. Ltd. बनाम Income Tax-4 101, Mangalam, Kulupwadi Room No. 629, Aayakar Road, Borivali East, Mumbai Bhawan, Maharishi Karve –400101, Maharashtra Road, Mumbai–400020, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaace0922A Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Anil Thakrar, CA (Virtually appeared)For Respondent: Shri Hemanshu Joshi, (Sr. DR)

Section 115BSection 142(1)Section 143(3)Section 263Section 80G

Nahta Prakash Chand Through Legal Heir Vachan Kumar Nahata, Seoni vs. Assessing Officer, Seoni

In the result, the appeal of the assessee is allowed

ITA 158/JAB/2024[2017-18]Status: DisposedITAT Jabalpur18 Sept 2025AY 2017-18

Bench: Shri Kul Bharat

For Appellant: Shri PC Bardia, AdvocateFor Respondent: Shri Alok Bhura, Sr. DR

Section 44ASection 69A

lakh during demonetization period be deleted. 2) Under the facts and circumstances of the case when the ITR filed u/s 44AD, declaring (Gross Total income of Rs. 2565570/-) business taxable income of Rs.727308/- (14.89%) on total sales of Rs. 48,83,652/- the CIT(Appeals) erred in confirming NO DOUBLE

Tinich Sahkari Ganna Samiti Limited, Bastii vs. ITO, Basti

ITA 295/LKW/2023[2015-16]Status: DisposedITAT Lucknow18 Sept 2025AY 2015-16

Bench: Shri. Sudhanshu Srivastava

For Appellant: None (Written submission)For Respondent: Shri Sanjeev Krishna Sharma and Shri Amit Kumar, D.Rs

Section 143(3)Section 244ASection 271(1)(c)Section 28Section 80PSection 80P(2)(a)

appellant has, in the return filed for the year, claimed a deduction at Rs.3557576/- u/s 80P(2)(a)(iii), out of the gross total income of Rs.3557576/-, which is the total net profit from business. As explained in a written reply dt. 09.09.2016 submitted u/s 143(2) before

Tinich Sahkari Ganna Samiti Limited, Basti vs. ITO, Basti

ITA 294/LKW/2023[2014-15]Status: DisposedITAT Lucknow18 Sept 2025AY 2014-15

Bench: Shri. Sudhanshu Srivastava

For Appellant: None (Written submission)For Respondent: Shri Sanjeev Krishna Sharma and Shri Amit Kumar, D.Rs

Section 143(3)Section 244ASection 271(1)(c)Section 28Section 80PSection 80P(2)(a)

Agni Steels Pvt. Ltd., Erode vs. DCIT, Circle-1, Erode

In the result, appeal filed by the assessee is allowed

ITA 1285/CHNY/2025[2014-15]Status: DisposedITAT Chennai18 Sept 2025AY 2014-15

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

Section 801A

book profit of Rs.9,64,37,461/- after claiming various expenditure including director remuneration of Rs.5,40,00,000/-. The assessee had computed gross total income of Rs.10,13,16,048/- in the computation of total income and admitted Rs.97,10,962/- for taxation after claiming VIA deduction of Rs.42 ... extent of Rs.19,63,935/- and the balance amount has to brought to tax as stated below: M/s. Agni Steels Pvt. Ltd. :: 4 :: GROSS TOTAL INCOME 10,13,15,048 SALARY TO DIRECTOR 5,40,00,000 PERCENTAGE OF SALRY TO GTI 53.30% Hence Rs.22,41,493/- @ 53.30% on Rs.42

Thane Zilla Vidyasevak Sahakari Patpedhi Ltd, Mumbai vs. ITO, Ward 3(4), Mumbai

In the result, the appeal of the assessee is allowed

ITA 4900/MUM/2025[2018-19]Status: DisposedITAT Mumbai18 Sept 2025AY 2018-19

Bench: Ms. Kavitha Rajagopal & Smt. Renu Jauhrithane Zilla Vidyasevak Vs. Commissioner Of Income Sahakari Patpedhi Ltd. Tax (Appeals), National Through Mr. Sudhir Evram Faceless Appeal Centre/ Ghagas Chairman 1St Floor, Ward 3(4) Sundera Plaza, Near Sanai Ashar It Park, Neheru Mangal Hall, Kalyan (West), Nagar, Wagle Industrial Kalyan-421301. Estate, Thane West, Thane- 400604. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aadft4365L Appellant .. Respondent

For Appellant: Shri Shekhar Parwardhan, CAFor Respondent: Shri Hemanshu Joshi, Sr. DR

Section 143(3)Section 250Section 80P(2)(a)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

Surender Singh, Mohna Ballabgarh vs. ITO, Faridabad

In the result, impugned order is set aside and appeal of the assessee is allowed

ITA 2827/DEL/2025[2012-13]Status: DisposedITAT Delhi18 Sept 2025AY 2012-13

Bench: SHRI VIKAS AWASTHY (Judicial Member)

For Appellant: Shri Arvind Soni, Chartered AccountantFor Respondent: Shri Manoj Kumar, SR.DR

Section 44A

placed on record bank statement. The total turnover of the assessee is Rs.21,42,500/-, the assessee in return of income has declared gross total income of Rs.2,54,938/- including business profit on presumptive basis Rs.2,51,120/-. The AO has accepted the profit declared by the assessee

Vaks Multiple Service Private Limited, Faridabad vs. ACIT, Faridabad

In the result, Miscellaneous Application of the Revenue is dismissed

ITA 3255/DEL/2025[2019-20]Status: DisposedITAT Delhi17 Sept 2025AY 2019-20

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.Vaks Multiple Service Vs Acit Plot No. 58-59, D L F Main Cgo Complex, Nh 4, Market, Sector-11, Faridabad, Nit, Faridabad, Haryana Haryana Pan: Aaecv4819M Appellant Respondent Assessee By Sh. Ankit Gupta, Ca Revenue By Sh. Dheeraj Kumar Jain, Sr. Dr Date Of Hearing 03/09/2025 Date Of Pronouncement 17/09/2025 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals/ National Faceless Appeal Centre (‘Ld. Cit(A)/Nfac’ For Short), New Delhi Dated 17/03/2025 For The Assessment Year 2019-20. 2. Brief Facts Of The Case Are That, The Assessee Filed Its Return Of Income For The A.Y.2019-20 Having Gross Total Income Of Rs. 79,44,337/-. During The Processing Of Itr U/S. 143(1)(A), The Cpc Had Disallowed Rs. 33,02,357/- On Account Of Delay In Payment Of Employees Share Of Esi & Pf. Being Aggrieved With The Aforesaid Disallowance Of Rs. 33,02,357/-, The Assessee Filed An Appeal Before National Faceless Appeal Centre (Nfac). The Cit (Nfac) Vide Order Vaks Multiple Service Pvt. Ltd. Vs. Acit

Section 143(1)(a)Section 250Section 36Section 36(1)(va)

Assessment Year 2019-20. 2. Brief facts of the case are that, the assessee filed its return of income for the A.Y.2019-20 having gross total income of Rs. 79,44,337/-. During the processing of ITR u/s. 143(1)(a), the CPC had disallowed Rs. 33,02,357/- on account

Agilent Technologies (International) Private Limited, Manesar, Gurgaon vs. The Deputy Commissioner of Income Tax Circle 1(1), Gurgaon

In the result, the appeal of the assessee is allowed

ITA 3684/DEL/2024[2020-21]Status: DisposedITAT Delhi17 Sept 2025AY 2020-21

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2020-21 Agilent Technologies Vs. Dcit, (International) Private Limited, Circle 1(1), Plot No.Cp-11, Sector 8, Imt, Gurgaon Manesar, (Haryana) Gurgaon - 122051 Aadca4115C (Appellant) (Respondent)

For Appellant: S/Shri Mayank Khannam, Akhil GoelFor Respondent: Shri Dharm Veer Singh, CIT (DR)

Section 142(1)Section 143(2)Section 143(3)Section 144C(13)Section 19Section 21Section 92C

which deduction shall be allowed to the assessee. 9 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 37(1) of the Act. Thus

M/S Ram Sukh Chunni Lal, Jaipur vs. ITO, Ward-1(3), Jaipur

In the result, the appeal of the assessee is allowed with above directions

ITA 782/JPR/2025[2018-19]Status: DisposedITAT Jaipur15 Sept 2025AY 2018-19

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyalram Sukh Chunni Lal, A-5, New Grain Mandi, Outside Chandpole, Jaipur 302 001 Pan No. Aabfr 5271M ...... Appellant Vs.

For Appellant: Mr. P. C. Parwal, CA, Ld. ARFor Respondent: Mrs. Alka Gautam, CIT, Ld. DR

Section 250Section 43BSection 68

income was below the maximum amount chargeable to tax. However for A.Y. 2018-19 she filed the return on 25.03.2019 declaring gross total income of Rs. 5, 01,407/- (PB 26-29). As on 31.03.2006 she had deposit of Rs. 8, 93,222/- with the assessee firm which ... filed as its income was below the maximum amount chargeable to tax. For A.Y. 2018-19 returns was filed on 11.07.2018 declaring gross total income of Rs. 4, 81,708/- (PB 80-83). As on 31.03.2015 it had deposit of Rs. 4,36,800/- with the assessee firm which

Chandan Steel Limited, Mumbai vs. Principal Commissioner of Income Tax Officer, Mumbai 4, Mumbai

ITA 3444/MUM/2025[2020-21]Status: DisposedITAT Mumbai15 Sept 2025AY 2020-21

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudhary

For Appellant: Shri Rakesh JoshiFor Respondent: Shri R.A. Dhyani, CIT-DR

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

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “C” BENCH : MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER AND SHRI RAHUL

Ambience Developers and Infrastructure Private Limited, Delhi vs. PCIT (Central) Delhi-2, Jhandewalan New Delhi, Delhi

ITA 1869/DEL/2025[2020-21]Status: DisposedITAT Delhi12 Sept 2025AY 2020-21

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Sh. Mahesh Kumar CA &For Respondent: Sh. Mahesh Kumar, CIT, DR

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 263

Page 1 ITA Nos.1868 & 1869/Del/2025 Ambience Developers and Infrastructure Pvt. Ltd. (AY: 2018-19 & 2020-21) THE INCOME TAX APPELLATE

Ambience Developers and Infrastructure Private Limited, Delhi vs. PCIT (Central), Delhi-2 Jhandewalan, New Delhi, Delhi

ITA 1868/DEL/2025[2018-19]Status: DisposedITAT Delhi12 Sept 2025AY 2018-19

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Sh. Mahesh Kumar CA &For Respondent: Sh. Mahesh Kumar, CIT, DR

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 263

been explained during the course of hearing as can be verified from records. That after setting off losses via inter-head adjustment, the Gross Total Income declared is Rs.217.09 Crores, against which income tax of Page 12 ITA Nos.1868 & 1869/Del/2025 Ambience Developers and Infrastructure ... Less: Deduction u/s 24(a) Interest on Borrowed fund House Property 0 1953084909 25951120 1927133789 578140137 524306921 0 1953084909 25951120 1927133789 1102447058 824686731 Gross Total Income Gross Total Income as -Ve figure is not allowed in return form. Total Income Round Off u/s 288A Calculation of MAT Profit

Sh. Vinod Kumar Jain, Kota vs. ACIT, Central Circle, Kota

In the result both these appeals of the assessee are allowed

ITA 647/JPR/2025[2019-20]Status: DisposedITAT Jaipur11 Sept 2025AY 2019-20

Bench: Dr. Mitha Lal Meena, Hon’Ble & Dr. S. Seethalakshmi, Hon’Ble

Section 115BSection 132(4)Section 68Section 69B

noted that the same was separately disclosed in computing the income from business and thereafter return was filed declaring gross total income of Rs.27,25,629/- which has been accepted by the AO at Pg 9 of the assessment order. In our view, when AO itself has accepted the excess

Sh. Vinod Kumar Jain, Kota vs. ACIT, Central Circle, Kota

In the result both these appeals of the assessee are allowed

ITA 646/JPR/2025[2018-19]Status: DisposedITAT Jaipur11 Sept 2025AY 2018-19

Bench: Dr. Mitha Lal Meena, Hon’Ble & Dr. S. Seethalakshmi, Hon’Ble

Section 115BSection 132(4)Section 68Section 69B