“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

Muniyappa Muniraju, Bengaluru vs. Pr. Commissioner of Income Tax, Bengaluru-2, Bengaluru

In the result, appeal filed by the assessee is allowed

ITA 1119/BANG/2025[2017-18]Status: DisposedITAT Bangalore11 Sept 2025AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan Kassessment Year : 2017-18 Shri. Muniyappa Muniraju, Vs. Pr. Cit, No.1/3, 1St Cross, Muni Narasimhaiah Bangalore - 2. Garden, Chocolate Factory Main Road, Btm I Stage, Bangalore – 560 029, Karnataka. Pan : Anjpm 0458 N Appellant Respondent Assessee By : Shri. Narendra Sharma, Advocate Revenue By : Shri. Muthu Shankar, Cit(Dr)(Itat), Bangalore. Date Of Hearing : 04.09.2025 Date Of Pronouncement : 11.09.2025

For Appellant: Shri. Narendra Sharma, AdvocateFor Respondent: Shri. Muthu Shankar, CIT(DR)(ITAT), Bangalore

Section 139(1)Section 142(1)Section 143(2)Section 147Section 148Section 194CSection 194HSection 263Section 44A

authorities below, we noted that assessee has filed return of income in pursuance to under section 148 of the Act dated 16.04.2021 declaring gross total income of Rs.5,48,500/- and claimed TDS of Rs.65,000/-. The AO issued notice under section 143(2) of the Act. On going through

ACIT 17(1), Mumbai vs. Nawazbhai Ratan Tata Trust, Mumbai

In the result, appeal of the revenue is dismissed

ITA 3581/MUM/2025[2016-17]Status: DisposedITAT Mumbai11 Sept 2025AY 2016-17

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

For Appellant: Shri Sukhsagar Syal, A/RFor Respondent: Shri Satyaprakash R. Singh, CIT D/R

Section 10(34)Section 11(7)Section 12ASection 80GSection 80G(4)

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 with law" आयकर अपीलीय अधिकरण INCOME TAX APPELLATE TRIBUNAL I.T.A. No. 3581/Mum/2025 2 4. Whether ... 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

Manisha Kamal Khetan, Mumbai vs. Deputy Commissioner of Income Tax, Central Circle 3(4), Mumbai

In the result, the captioned appeal filed by the assessee is allowed, in terms of our

ITA 2698/MUM/2025[2013-14]Status: DisposedITAT Mumbai11 Sept 2025AY 2013-14

Bench: Smt. Beena Pillai, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Rakesh JoshiFor Respondent: Shri Annavaran Kasuri, SR AR

Section 10(38)Section 131Section 143(2)Section 147Section 250Section 68Section 69C

Senior DR that as per ld. AO's observation at page 18 of the assessment order, M/s. ACI Infocom Limited's gross total income in F.Y. 2011-12, 2012-13, 2013-14 and 2014-15 was zero as stated by Mr. Omprakash Mohanlal Bohra, director of M/s. ACI Infocom Limited

West Central Railway Employees Cooperative Credit Society Ltd., Kota vs. ITO, Ward-2(1), Kota

In the results, the appeal of the assessee in ITA no

ITA 1009/JPR/2025[2022-23]Status: DisposedITAT Jaipur10 Sept 2025AY 2022-23

For Appellant: Sh. P. C. Parwal, CAFor Respondent: Sh. Gautam Singh Choudhary, JCIT

Section 143(3)Section 270ASection 80P

said section deals with deduction in respect of income of co-operative societies. Section 80P(1), inter alia, states that where the gross total income of a co-op society includes any income from one or more specified activities, then such income shall be deducted from the gross total income ... Railway Employees Cooperative Credit Society Ltd. vs. ITO 80P. (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

West Central Railway Employees Cooperative Credit Society Ltd., Kota vs. ITO, Ward-2(1), Kota

In the results, the appeal of the assessee in ITA no

ITA 1008/JPR/2025[2020-21]Status: DisposedITAT Jaipur10 Sept 2025AY 2020-21

Section 143(3)Section 270ASection 80P

West Central Railway Employees Cooperative Credit Society Ltd., Kota vs. ITO, Ward-2(1), Kota

In the results, the appeal of the assessee in ITA no

ITA 1007/JPR/2025[2017-18]Status: DisposedITAT Jaipur10 Sept 2025AY 2017-18

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Sh. P. C. Parwal, CAFor Respondent: Sh. Gautam Singh Choudhary, JCIT

Section 143(3)Section 270ASection 80P

Mahatma Gandhi Nagri Sahakari Pat Sanstha Mydt Udgir, Latur vs. Income Tax Officer- Ward 1 -Latur, Latur

In the result, the appeal of the assessee is allowed

ITA 671/PUN/2025[2020-21]Status: DisposedITAT Pune09 Sept 2025AY 2020-21

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.670 & 671/Pun/2025 निर्धारण वर्ष / Assessment Years : 2018-19 & 2020-21 Mahatma Gandhi Nagri Sahakari Pat Sanstha Mydt Udgir, Bidar Road, Near Mahatma Gandhi Udyan, Udgir, Latur-413517 Pan: Aabam7649H अपीलार्थी / Appellant Assessee By : Department By : Date Of Hearing : Date Of Pronouncement : Ito, Ward-1, Latur Vs. प्रत्यर्थी / Respondent Miss Sailee Gujarathi (Virtual) Shri Ramnath P. Murkunde 02-07-2025 09-09-2025 आदेश / Order Per Astha Chandra, Jm : The Above Two Appeals Filed By The Assessee Are Directed Against The Two Separate Orders Both Dated 10.01.2025 Of The Ld. Commissioner Of Income Tax (Appeals), Nfac, Delhi [“Cit(A)/Nfac"] Pertaining To

For Appellant: Department byFor Respondent: Date of hearing

Section 142(1)Section 143(3)Section 80P(2)(a)Section 80P(2)(d)

respect of income of co-operative societies 80P.(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 ... assessee was taxable under the head 'Income from Other Sources' under Section 56 of the Act and was not 100% deductible from the Gross Total Income under Section 80P of the Act, is not applicable to the present Assessment Years 2007-2008 to 2011-2012 involved in the present appeals

Mahatma Gandhi Nagri Sahakari Pat Sanstha Mydt Udgir, Latur vs. Income Tax Officer- Ward 1 -Latur, Latur

ITA 670/PUN/2025[2018-19]Status: DisposedITAT Pune09 Sept 2025AY 2018-19

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Miss Sailee Gujarathi (Virtual)For Respondent: Shri Ramnath P. Murkunde

Section 142(1)Section 143(3)Section 80P(2)(a)Section 80P(2)(d)

Gemological Research (Thailand) Co. Ltd., Thailand vs. The Assistant Commissioner of Income-Tax (International Taxation) - Circle 2(3)(2), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 1291/MUM/2025[2019-20]Status: DisposedITAT Mumbai09 Sept 2025AY 2019-20

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Anikesh Banerjee, Hon’Ble

For Appellant: Shri Satya Pal Kumar, CIT D/R a/w Shri Krishna Kumar, Sr. D/R

Section 147Section 148

Dubai Branch of GIA India Lab (Note 3) 25,94,47,404 Less: Not taxable - - 25,94,47,404 Gross Total Income - - 4. In its notes appended to the return, the assessee claimed that it provides gem grading services from Thailand to unrelated parties in India which are not taxable

ITO, Pune vs. Thegovernmentserventsmaharastraco-Op Credit Society Limited Pune, Pune

In the result, both the appeals filed by the Revenue are

ITA 714/PUN/2024[2018-19]Status: DisposedITAT Pune08 Sept 2025AY 2018-19

Bench: Dr. Manish Borad & Ms. Astha Chandra

For Respondent: Shri Ramnath P. Murkunde, DR

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

respect of income of co-operative societies. 80P. (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

ITO, Pune vs. The Government Servents Maharashtra Co-Op Credit Society Limited Pune, Pune

In the result, both the appeals filed by the Revenue are

ITA 713/PUN/2024[2017-18]Status: DisposedITAT Pune08 Sept 2025AY 2017-18

Bench: Dr. Manish Borad & Ms. Astha Chandra

For Respondent: Shri Ramnath P. Murkunde, DR

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

Prudent Insurance Brokers Private Limited, Mumbai vs. PCIT-8, Mumbai

In the result, the appeal of the assessee stands allowed

ITA 3186/MUM/2025[2020-21]Status: DisposedITAT Mumbai04 Sept 2025AY 2020-21

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

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

claim for deduction u/s.80G on a donation should be voluntary. It is independent of computation of business income as it is allowed from Gross Total Income. The assessee had disallowed the CSR expenses while computing business income. Further, there is no dispute that the assessee has filed complete details ... Section, such sum paid by the assessee in the previous year as a donation. Deduction under Chapter VIA provides deduction from the gross total income which is computed after making necessary allowances / disallowances in accordance with Section 28-44BB of the Act including Explanation to Section 37(1). Thus

Abhishek Builders and Developers, Pune vs. ACIT Circle Panvel, Navi Mumbai

In the result, the appeal is dismissed

ITA 2726/PUN/2024[2010-11]Status: DisposedITAT Pune03 Sept 2025AY 2010-11

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: NoneFor Respondent: Shri Amol khairnar

Section 142(1)Section 143(2)Section 143(3)Section 250Section 80I

claim of the assessee is rejected and the income of the assessee is computed as under : Income from Business of Profession : 66513648 Gross Total income : 66513648 Total income : 66513648 11. Further, we note that ld.CIT(A) has confirmed the action of the Assessing Officer observing as follows

Naba Utkal Trust, Bhubaneswar vs. ITO, Exemption Ward, Bhubaneswar

Appeal of the assessee is allowed

ITA 268/CTK/2025[2021-22]Status: DisposedITAT Cuttack02 Sept 2025AY 2021-22

Bench: Shri Sonjoy Sarma, Jm & Shri Sanjay Awasthi, Am आयकर अपील सं/Ita No.268/Ctk/2025 (नििाारण वर्ा / Assessment Year : 2021-2022) Naba Utkal Trust, Vs Ito, Exemption, Bhubaneswar Plot No.841, Keshab Complex, Cuttack Road, Rasulgarh, Bhubaneswar-751010 Pan No. : Aabtn 0126 D (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. नििााररती की ओर से /Assessee By : Shri Ambika Prasad Mohanty, Ca राजस्व की ओर से /Revenue By : Shri Vijay Singh, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 28/08/2025 घोषणा की तारीख/Date Of Pronouncement : 02/09/2025 आदेश / O R D E R Per Sonjoy Sarma, Jm: This Is An Appeal Filed By The Assessee Against The Order, Dated 28.12.2024 Passed By The Ld. Addl./Jcit(A), Panaji, For The Assessment Year 2021-2022. 2. The Appeal Of The Assessee Is Barred By 60 Days. In This Regard, The Assessee Has Filed An Application For Condonation Of Delay Supported With An Affidavit Stating Therein That The Delay Of 60 Days In Filing The Present Appeal Is Due To Lack Of Knowledge About The Order Passed By The Ld.Pcit. Accordingly, The Assessee Prayed That The Delay Of 60 Days May Kindly Be Condoned & Appeal Of The Assessee May Kindly Be Admitted For Hearing. Ld. Sr. Dr Did Not Raise Any Objection To This Contention Of The Assessee For Condonation Of Delay. Accordingly, We Are Of The View That The Assessee

For Appellant: Shri Ambika Prasad Mohanty, CAFor Respondent: Shri Vijay Singh, Sr. DR

Section 11(2)Section 119(2)Section 12ASection 143(1)

which was 15.03.2021 and the return of income under the provisions was also filed and uploaded on 16.03.2021. During the year the gross total income of the assessee was declared at Rs.39,18,463/- The amount applied for charitable purpose was Rs.35,04,508/- and accumulation u/s.11

Sri Kalabhairaweshwara Multi-Purpose Co-Op.Society Limited, Chikkamagaluru vs. Income Tax Officer, Ward-1, Chikkamagaluru

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

ITA 1792/BANG/2025[2019-20]Status: DisposedITAT Bangalore01 Sept 2025AY 2019-20

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Mahesh R Uppin, AdvocateFor Respondent: Shri Ganesh R Ghale, Standing Counsel for Department

Section 139Section 139(1)Section 148Section 80ASection 80PSection 80P(2)(a)

materials available on record. On perusal of the statement of income placed at page 32 of the appeal set, we note that the gross total income of the assessee stands at ₹17,20,751 only, whereas the assessee has claimed the deduction of ₹38,58,079 under section

Brahtakar Krishi Sakh Sahakari Samiti Maryadit, Sahajpur vs. Income Tax Officer Ward 1(2), Jabalpur

In the result, all the three appeals in ITA Nos

ITA 151/JAB/2025[2015-16]Status: DisposedITAT Jabalpur28 Aug 2025AY 2015-16

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Sapan Usrethe, Advocate & ShFor Respondent: Sh. Alok Bhura, Sr. DR

Section 143(2)Section 147Section 148Section 250Section 80P

assessee made due compliance to the notices under section 148. It filed a return for the A.Y. 2013-14 on 21.05.2021 declaring gross total income of Rs.29,10,623/-, a total loss of Rs.27,448/- in respect of the A.Y. 2014-15 and gross total income of Rs.6

Brahtakar Krishi Sakh Sahakari Samiti Maryadit, Sahajpur vs. Income Tax Officer Ward 1(2), Jabalpur

In the result, all the three appeals in ITA Nos

ITA 149/JAB/2025[2013-14]Status: DisposedITAT Jabalpur28 Aug 2025AY 2013-14

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Sapan Usrethe, Advocate & ShFor Respondent: Sh. Alok Bhura, Sr. DR

Section 143(2)Section 147Section 148Section 250Section 80P

JCIT(OSD), Cir011(1), Kolkata vs. M/S. Philips Carbon Black Ltd., Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 234/KOL/2023[2014-15]Status: DisposedITAT Kolkata28 Aug 2025AY 2014-15

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumari.T.A. No.234/Kol/2023 Assessment Year: 2014-15 Jcit(Osd), Circle-11(1), Kolkata........................…...........................……….……Appellant Vs. M/S Philips Carbon Black Ltd.............…..….…..….........……........……...…..…..Respondent Duncan House, 31 Netaji Subhas Road, Kol-1. [Pan: Aabcp5762E] Appearances By: Shri Praveen Kishore, Cit-Dr, Appeared On Behalf Of The Appellant. Shri Akkal Dudhewala, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : June 30, 2025 Date Of Pronouncing The Order : August 29Th, 2025 Order Per Rajesh Kumar:

Section 144CSection 250Section 32(1)Section 32(1)(ii)Section 32(1)(iia)Section 80Section 80I

figure and therefore there was no occasion for him to quantify and allow any deduction u/s 80-IA of the Act, as the gross total income continued to remain NIL. Considering factual matrix , there is merit in the plea raised by the Ld. AR that the impugned transfer pricing adjustment ... case of Pr.CIT Vs Kesoram Industries Ltd in GA No. 2/2022 dated 20th December 2022 in which it was held that, where the gross total income was NIL due to losses and no deduction was claimed u/s 80-IA of the Act, then the question of any TP adjustment

Mr. Firoz Ahammad Mujawar, Bangalore vs. Income Tax Officer, Ward- 3(3)(4), Bangalore

In the result, appeal filed by the assessee is allowed

ITA 98/BANG/2025[2017-18]Status: DisposedITAT Bangalore28 Aug 2025AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan Kassessment Year : 2017-18 Shri. Firoz Ahammad, Vs. Ito, Acharya Iti No 15, 1St Cross 1St Stage Peenya Ward – 3(3)(4), Industrial Estate, Bangalore. Bangalore – 560 058, Karnataka. Pan : Agqpm 8839 D Appellant Respondent Assessee By : Shri. Mahesh G, Ca Revenue By : Shri.Ganesh R. Ghale, Advocate, Standing Counsel For Revenue. Date Of Hearing : 15.07.2025 Date Of Pronouncement : 28.08.2025

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

Section 115BSection 143(2)Section 69A

deposits in bank account. 2. Briefly stated, the facts of the case are that assessee filed his return of income on 18.07.2017 declaring gross total income of Rs.6,85,225/- and total income of Rs.5,29,730/- after claiming deduction of Rs.1,55,500/- under Chapter

Krishnamurthy L/R by Smt. Nagarathnamma, Bangalore vs. DCIT, Circle-2(1), Bangalore

In the result, appeal filed by the assessee is allowed

ITA 570/BANG/2025[2012-13]Status: DisposedITAT Bangalore28 Aug 2025AY 2012-13

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan Kassessment Year : 2012-13 Shri. Krishnamurthy, Vs. Dcit, Represented By His Lr Smt. Nagarathnamma, Circle –2(1), No.152, 2Nd Floor, Hanuman Chambers, Bangalore. 7Th Cross, 2Nd Main, Chamarajpet, Bangalore – 560 018. Pan : Admpk 2463 J Appellant Respondent Assessee By : Shri. Ravishankar S. V, Advocate Revenue By : Shri. Balusamy N, Jcit(Dr)(Itat), Bangalore. Date Of Hearing : 22.07.2025 Date Of Pronouncement : 28.08.2025

For Appellant: Shri. Ravishankar S. V, AdvocateFor Respondent: Shri. Balusamy N, JCIT(DR)(ITAT), Bangalore

Section 139(1)Section 139(9)Section 140ASection 143(1)Section 143(2)Section 148Section 292B

assessee fled return on 10.03.2014 as scanned supra, where the assessee has shown tax payable of Rs.8,57,000/- and gross total income shown by the assessee is Rs.1,08,25,483/-. On going by the provision of section 139(9) of the Act, the return is defective return. However