“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

Shri Mallikarjun Urban Co Operative Credit Society Limited, Belagavi vs. ITO Ward 1 Belgaum, Belgaum

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

ITA 65/PAN/2026[2017-18]Status: DisposedITAT Panaji06 Mar 2026AY 2017-18

Bench: SHRI PAVAN KUMAR GADALE (Judicial Member)

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

adjudication of the issue before us. "80P(2) (d) (1). Where in the case of an assessee being a cooperative 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

Senthilkumar Thangaraj, Mumbai vs. ITO-Ward 42(3)(3), Mumbai

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

ITA 8221/MUM/2025[2016-17]Status: DisposedITAT Mumbai06 Mar 2026AY 2016-17

Bench: SHRI ANIKESH BANERJEE (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

For Appellant: Shri. Himanshu Gandhi

Section 139Section 147Section 148Section 149Section 250

Senthilkumar Thangaraj, Mumbai Rs.7,01,880/-. The assessee claimed deduction of Rs.1,55,330/- under Chapter VI-A of the Act against the gross total income of Rs.8,57,211/-. Subsequently, the Ld. AO initiated reassessment proceedings by issuing notice under section 148 of the Act on the ground that

Navakarnataka Pss Limited, Hospet vs. Income Tax Officer, Ward-1 & Tps, Hospet

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

ITA 2167/BANG/2025[2016-17]Status: DisposedITAT Bangalore05 Mar 2026AY 2016-17

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

For Appellant: Smt. Harsha, CAFor Respondent: Shri Subramanian .S, JCIT-DR

Section 142(1)Section 143(2)Section 194ASection 194A(3)(v)Section 2(19)Section 234ASection 250Section 40Section 40aSection 80P

details about the provision for NPA, the disallowance would have tax neutral effect as the same would be added back to gross total income and then deduction under Chapter VIA would be claimed on the entire income u/s. 80P of the Act and the net result would be Nil total

Grant Road (W) Omkar Co-Operative Housing Soc Limited, Mumbai vs. ITO 19(1)(1), Mumbai

ITA 260/MUM/2026[2021-22]Status: DisposedITAT Mumbai05 Mar 2026AY 2021-22

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhail

For Appellant: Shri Ashok MehtaFor Respondent: Shri Pravin Salunkhe, Sr.DR

Section 143(1)Section 80Section 80PSection 80P(1)Section 80P(2)(d)Section 80P(4)

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

Grant Road (W) Omkar Co-Operative Housing Soc Limited, Mumbai vs. ITO 19(1)(1), Mumbai

In the result, this appeal of the assessee is allowed

ITA 259/MUM/2026[2020-21]Status: DisposedITAT Mumbai05 Mar 2026AY 2020-21

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhail

For Appellant: Shri Ashok MehtaFor Respondent: Shri Pravin Salunkhe, Sr.DR

Section 143(1)Section 80Section 80PSection 80P(1)Section 80P(2)(d)Section 80P(4)

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

Income-Tax Officer, Tiruchirappalli vs. Palanikumar Velusamy Krishnakumar, Tiruchirappalli

In the result, appeal filed by the Revenue stands dismissed

ITA 2998/CHNY/2025[2017]Status: DisposedITAT Chennai04 Mar 2026

Bench: Shri Aby T. Varkey & Ms. Padmavathy. S

For Appellant: NoneFor Respondent: Ms.R. Anitha, Addl.CIT

Section 139(1)Section 142(1)Section 144Section 69A

return of income filed by him on 25.09.2019 for the assessment year 2017-18 vide acknowledgement no.175985381250919, declaring a gross total income of Rs.5,06,711/- and Rs.4,45,540/- respectively. In the written submission, the appellant has also stated the following: I am a dealer in batteries. During ... business of batteries. Pursuant to notice u/s 142(1), the assessee is noted to have filed ITR on 25-09-2019 declaring gross total income of Rs.5,06,711/- [vide acknowledgement number: 175985381250919]. The assessee is noted to have filed the financials, Tax Audit Report (TAR), and books of account

Oriental Hotels Ltd., Chennai vs. DCIT, Corporate Circle-5(1), Chennai

The appeal of the assessee is allowed for statistical purpose

ITA 2601/CHNY/2025[2018-19]Status: DisposedITAT Chennai04 Mar 2026AY 2018-19

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

For Appellant: Shri. Vikram VijayaraghavanFor Respondent: Shri. K. Ilaiyaraja, Addl. CIT

Section 143(1)Section 143(2)Section 143(3)Section 14ASection 154Section 35D(8)(C)

refund of Rs.2,90,58,959/-. The return of income was processed vide intimation u/s.143(1) of the Act dated 25.01.2021 wherein, the gross total income was determined at Rs.9,48,59,398/- as against Rs.8,86,48,670/- declared by the assessee. Subsequently, the case was taken ... instead of setting off correct carry forward business loss to the extent of profits determined at Rs.9,04,58,562/- and thereby the gross total income was wrongly determined at Rs.9,48,59,398/- as against Rs.8,86,48,670/-. The assessee was under the strong belief that the additions

Shri K.P. Magennavar Laxmi Credit Souharda Sahakari Sangh Ltd.Manjari., Chikodi vs. Income Tax Officer, Ward-1, Nippani

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

ITA 33/PAN/2026[2015-2016]Status: DisposedITAT Panaji27 Feb 2026AY 2015-2016

Bench: Shri Pavan Kumar Gadalei T A. No.33/Pan/2026 (A.Y. 2015-16 ) Shri K.P.Magennavar Laxmi Vs I.T.O-Ward-1, Credit Souharda Sahakari Nemchand Building, . Sangh Limited, 747,Ashoknagar, 521,Laxmibuilding,Mainroad, Nipani-591237, Manjari, Chikodi, Karnataka. Belagavi-591213, Karnataka. Pan .No. Aabas3175N (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.Jaykumar Patil.Ar Revenue By Smt.Thamba Mahendra.Sr.Dr सुनवाई की तारीख/Date Of Hearing 25.02.2026 घोषणा की तारीख/Date Of Pronouncement 27.02.2026 Order Per Pavan Kumar Gadale, Jm: The Assessee Has Filed The Appeal Against The Order Of Addl/Jcit(A)-7 Mumbai Passed U/Se 143(3) & U/Sec250 Of The Act. The Assessee Has Raised The Grounds Of Appeal Challenging The Order Of The Cit(A) Sustaining The Denial Of Claim Of Deduction U/Sec80P(2)(A)(I) Of The Ac & Without Prejudice Alternate Relief U/Sec80P(2)(D) Of The Act On Interest Income From Cooperative Banks & Scheduled Banks. 2. The Brief Facts Of The Case Are That, The Assessee Souhard Credit Cooperative Society Is Engaged In Providing

Section 80P(2)(a)Section 80P(2)(d)

Sewa Sahakari Samiti Sirri, Balod vs. Income Tax Officer, Ward-1(3), Bhilai

In the result, the appeal of the assessee is allowed

ITA 109/RPR/2026[2016-17]Status: DisposedITAT Raipur27 Feb 2026AY 2016-17

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.109/Rpr/2026 िनधा"रण वष" /Assessment Year: 2016-17 Sewa Sahkari Samiti Sirri, Village & Post:Sirri, Tehsil Gunderdehi, District Balod, Chhattsigarh, 491221 Pan: Aagas8961H .......अपीलाथ" / Appellant बनाम / V/S.

For Appellant: Mr. Vinit Kumar Jain, CAFor Respondent: None (Petition filed)

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

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. 9. In this context when we look at the judgment of the Apex Court in the case

Shri Dandi Sewa Ashram, Onkareshwar vs. Income Tax Officer Exemption, Bhopal

ITA 560/IND/2025[2017-18]Status: DisposedITAT Indore27 Feb 2026AY 2017-18

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

Section 10Section 10(24)Section 11Section 124Section 143(1)Section 154Section 246ASection 250Section 253

judgment of the Hon. Tribunal in the case of Indore Contract Bridge Association. The addition may please be deleted. 5. The taxing of gross total income may please be deleted. 6. The assessee craves to amend, alter or delete any of the ground of appeal. 3. Record of Hearing

Vrihtakar Seva Sahakari Samiti Maryadit Surgi, Rajnandgaon vs. Income Tax Officer-1, Rajnandgaon

In the result, appeal of the assessee is allowed

ITA 105/RPR/2026[2018-19]Status: DisposedITAT Raipur26 Feb 2026AY 2018-19

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.105/Rpr/2026 "नधा"रण वष" /Assessment Year : 2018-19

For Appellant: Shri Rakesh Dhody, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 80Section 80P(2)Section 80P(2)(a)Section 80P(2)(d)

Minakshi Das, Jalpaiguri vs. I.T.O., Ward - 1(3), Siliguri

In the result, the appeal of the assessee is allowed

ITA 1648/KOL/2025[2019-2020]Status: DisposedITAT Kolkata26 Feb 2026AY 2019-2020

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Shri Soumitra Choudhary, DRFor Respondent: Shri Mangtinlen Haokip, DR

Section 147Section 148Section 148ASection 69A

INCOME FROMINTEREST Interest from Saving Bank A/c S/B Int. 63565 Interest on F.d. with banks F.D Int 15885. INCOME FROMOTHERS LIC commission 85370 GROSS TOTAL INCOME Less:- Deduction under Chapter VI-A Deduction u/s 80TTA Interest from Saving Bank A/c 63,565 Allowable Deduction u/s 80-TTA 10000 Total deductions

Ravi Suryakantbhai Shah, Ahmedabad, Gujarat vs. Income Tax Officer, Ward 7(2)(1), Ahmedabad, Gujarat

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

ITA 2344/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad25 Feb 2026AY 2019-20

Bench: Ms. Suchitra Kambleassessment Year 2019-20

For Appellant: Shri Sarju Mehta, A.RFor Respondent: Shri Rameshwar P. Meena, Sr. D.R

Section 139Section 250Section 80G

declaring total income of Rs. 35,82,200/- claiming deduction under Chapter VI-A of Rs. 12,35,000/- from gross total income of Rs. 48,47,200/-. The assessee did not respond the notices and therefore the assessee made addition of Rs. 10 lacs thereby disallowing the deduction claimed

Horizon Co Operative Housing Society Limited, Mumbai vs. ITO Ward 21(2)(4), Mumbai

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

ITA 8469/MUM/2025[2018-19]Status: DisposedITAT Mumbai25 Feb 2026AY 2018-19

Bench: Shri Amit Shukla () & Shri Girish Agrawal ()

Section 143(3)Section 2(19)Section 80PSection 80P(1)Section 80P(2)(d)Section 80P(4)

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

Horizon Co-Operative Housing Society Limted, Mumbai vs. ITO Ward 21(1)(4), Mumbai

ITA 8468/MUM/2025[2013-14]Status: DisposedITAT Mumbai25 Feb 2026AY 2013-14

Bench: Shri Amit Shukla () & Shri Girish Agrawal () Ι.Τ.Α. Νο. 8468 & 8469/Mum/2025

Section 143(3)Section 2(19)Section 80PSection 80P(1)Section 80P(2)(d)Section 80P(4)

Income Tax Officer, Kolkata vs. Milestone Finstock Pvt. Ltd., Kolkata

In the result, the appeal filed by the revenue is dismissed

ITA 1180/KOL/2023[2012-13]Status: DisposedITAT Kolkata24 Feb 2026AY 2012-13

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2012-13 Ito, Ward-12(1), Kolkata…..…………..………….……….……….……Appellant Vs. Milestone Finstock Pvt. Ltd..……...…………………….....……...…..…..Respondent 62A, Hazra Road, Kol-700019. [Pan: Aaccm0280B] Appearances By: Shri Mohit Mrinal, Cit-Dr, Appeared On Behalf Of The Appellant. Shri N S Saini, Ar & Priyanka Salarpuria, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 07, 2026 Date Of Pronouncing The Order : February 24, 2026 Order Per Pradip Kumar Choubey: This Appeal Filed By The Revenue Is Directed Against The Order Dated 24.09.2020 Of The Cit(Appeals)-4, Kolkata (Hereinafter Referred To As The “Cit(A)”) Passed U/S 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2012–13. 2. The Appeal Has Been Filed By The Revenue With A Delay Of 1075 Days & The Revenue Has Filed An Affidavit For Condonation Of The Delay. The Contents Of The Said Affidavit Are As Under: Milestone Finstock Pvt. Ltd

Section 143(2)Section 143(3)Section 250Section 73

mention the Explanation to Section 73 reads as follows: “Where any part of the business of a company [other than a company whose gross total income consists mainly of income which is chargeable under the heads “Interest on securities”, “Income from house property”, “Capital gains” and “Income from other sources

Divya Dinesh, Bengaluru vs. DCIT, Circle-7(1)(1), Bangalore

ITA 2195/BANG/2025[2021-22]Status: DisposedITAT Bangalore24 Feb 2026AY 2021-22

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

Section 115BSection 143(1)Section 154Section 250Section 80G

Divya Dinesh, Bengaluru vs. DCIT, Circle-7(1)(1), Bangalore

In the result appeal of the assessee is allowed

ITA 2194/BANG/2025[2019-2020]Status: DisposedITAT Bangalore24 Feb 2026AY 2019-2020

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Sudheendra B.R, AdvocateFor Respondent: Shri Balusamy N, JCIT

Section 115BSection 143(1)Section 154Section 250Section 80G

noted that due to the disallowance of set off of short-term capital loss, the gross total income increased. As per section 80G(4) of the Act, the donation in excess of 10% of the gross total income has to be ignored while computing the deduction. Since the gross total ... loss of Rs. 16,28,978/- against long-term capital gains in accordance with section 70 of the Act. Consequently, the computation of gross total income as returned by the assessee was in accordance with law. Once the gross total income is restored to the figure declared in the return

Sarvanand Sadhuram Sonwani, Rajkot vs. DCIT, CC-1, Rajkot

ITA 819/RJT/2024[2022-23]Status: DisposedITAT Rajkot23 Feb 2026AY 2022-23

Bench: Dr. Arjun Lal Saini

For Respondent: Shri Mehul Ranapura, Ld. AR

Section 143(3)Section 147Section 148Section 2

total income of Rs. 15,20,590/- after claiming deductions under chapter VI-A of the Act of Rs. 1,20,173/-. The gross total income consists of Salary of Rs. 10,50,000/-, Capital Gains of Rs.5,82,794/-, and other incomes of Rs. 7,968/-. A Search, Seizure

Sarvanand Sadhuram Sonwani, Rajkot vs. DCIT, CC-1, Rajkot

ITA 818/RJT/2024[2021-22]Status: DisposedITAT Rajkot23 Feb 2026AY 2021-22

Bench: Dr. Arjun Lal Saini

For Respondent: Shri Mehul Ranapura, Ld. AR

Section 143(3)Section 147Section 148Section 2