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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

Shri Sainath Sevabhavi Sanstha, Latur vs. ITO, Exemption Ward, Nanded

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

ITA 1319/PUN/2025[2013-14]Status: DisposedITAT Pune22 Aug 2025AY 2013-14

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1319/Pun/2025 िनधा"रण वष" / Assessment Year : 2013-14 Shri Sainath Sevabhavi Vs. Ito, Exemption Ward, Sanstha, Nanded. Akharwai, Harangul Bk, Latur, Harangai Bk, B.O., Latur- 413531. Pan : Aakts9324H Appellant Respondent Assessee By : Shri Sarang Gudhate Revenue By : Shri Akhilesh Srivastva Date Of Hearing : 30.07.2025 Date Of Pronouncement : 22.08.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 30.04.2025 Passed By Ld. Addl./Jcit(A)-7, Delhi [‘Ld. Cit(A)’] For The Assessment Year 2013-14. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “(Without Prejudice To Each Other) 1. Under The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A)/Nfac Has Erred In Not Condoning The Delay In Filing Of Appeal. 2. Under The Facts & Circumstances Of The Case & In Law, Ld Cit(A)/Nfac Has Erred In Denying The Expenditure Incurred & Treating The Gross Receipts As Income In Intimation U/S 143(1).

For Appellant: Shri Sarang GudhateFor Respondent: Shri Akhilesh Srivastva
Section 119(2)(b)Section 143(1)Section 154

expenses of Rs.73,17,696/- were shown resulting in net surplus of Rs.1,91,045/-. CPC processed the return on 14.03.2015 determining gross total income of Rs.75,08,740/- treating gross receipt as income and rejecting the claim of expenses of Rs.73,17,696/-. Against the above intimation, the assessee

Jila Sahakari Kendiya Bank Maryadit, Balaghat vs. Income Tax Officer, Circle Chhindwara, Chhindwara

In the result, appeals of the assessee are allowed for statistical purposes

ITA 137/JAB/2023[2017-18]Status: DisposedITAT Jabalpur21 Aug 2025AY 2017-18

Bench: Shri Kul Bharat & Shri, Nikhil Choudharyassessment Year: 2016-17 Jila Sahakari Kendriya Bank V. Income Tax Officer Maryadit Chhindwara-480001. Near Kali Putli Chowk, Madhya Pradesh-481001. Tan/Pan:Aaaaj0474A (Appellant) (Respondent) Assessment Year: 2017-18 Jila Sahakari Kendriya Bank V. Assessing Officer, Nfac, Maryadit Delhi Near Kali Putli Chowk, Madhya Income Tax Officer, Pradesh-481001. Circle Chhindwara-480001. Tan/Pan:Aaaaj0474A (Appellant) (Respondent) Appellant By: Shri Pankaj Shah, Ca Respondent By: Shri Alok Bhura, Sr. Cit(Dr) Date Of Hearing: 19 08 2025 Date Of Pronouncement: 21 08 2025 O R D E R

For Appellant: Shri Pankaj Shah, CAFor Respondent: Shri Alok Bhura, Sr. CIT(DR)

confirming the addition of Rs. 97,39,910/- made by the AO on the ground of difference in the computation of income and gross total income in ITR without properly appreciating the factual matrix of the case. The Appellant prays that the said addition be directed to be deleted ... erred in confirming the addition of Rs.18910474 made by the AO on the ground of difference in the computation of income and gross total income in ITR without properly appreciating the factual matrix of the case. The Appellant prays that the said addition be directed to be deleted

The Pursottam Farmers Co.Op. Cotton Ginning & Pressing Society Ltd., Surat vs. The Assistant Commissioner of Income Tax, Ciracle-2(2), Surat

In the result, the appeal of the assessee is allowed, whereas the appeal of the revenue is dismissed

ITA 523/SRT/2024[2017-18]Status: DisposedITAT Surat19 Aug 2025AY 2017-18

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.499/Srt/2024 Assessment Year: (2017-18) (Hybrid Hearing) Dcit, Vs. The Pursottam Farmers Co-Op. Circle – 2(1)(1), Cotton Grnning & Pressing Soc. Surat Ltd., Jahangirpura Gin., Jahangirpura, Rander – 395009, "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaat3000A (Appellant) (Respondent) आयकर अपील सं./Ita Nos.523/Srt/2024 Assessment Year: (2017-18) The Pursottam Farmers Co-Op. Vs. Dcit, Cotton Grnning & Pressing Soc. Ltd., Circle – 2(1)(1), Jahangirpura Gin., Jahangirpura, Surat Rander – 395009, "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaat3000A (Appellant) (Respondent) Appellant By Shri Ajay Uke, Sr. Dr Respondent By Shri Akshay M. Modi, Ca Date Of Hearing 23/07/2025 Date Of Pronouncement 19/08/2025

Section 143(3)Section 194A(3)(v)Section 250Section 80PSection 80P(1)Section 80P(2)(d)Section 80P(4)

deductions claimed under Chapter VIA of the Act for the aggregate amount of Rs. 2,65,23,665/- (subject to the availability of Gross Total Income), purely on misinterpretation and misconstruction of the provisions of law, misleading, mis-conceptual, arbitrary and perverse observations and hence, is liable to be quashed ... interest from investments with other co-operative societies for the aggregate amount of Rs.2,32,57,862/- (restricted to the availability of Gross Total Income) and therefore, the CIT (Appeals)'s action confirming the AO's order u/s 143(3) of the Act denying the deduction claimed under Chapter

Dy. Commissoner of Income-Tax, Circle-2(1)(1), Surat vs. The Pursottam Farmers Co Op Cotton Grnning and Pressing Society Ltd, Surat

In the result, the appeal of the assessee is allowed, whereas the appeal of the revenue is dismissed

ITA 499/SRT/2024[2017-18]Status: DisposedITAT Surat19 Aug 2025AY 2017-18

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.499/Srt/2024 Assessment Year: (2017-18) (Hybrid Hearing) Dcit, Vs. The Pursottam Farmers Co-Op. Circle – 2(1)(1), Cotton Grnning & Pressing Soc. Surat Ltd., Jahangirpura Gin., Jahangirpura, Rander – 395009, "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaat3000A (Appellant) (Respondent) आयकर अपील सं./Ita Nos.523/Srt/2024 Assessment Year: (2017-18) The Pursottam Farmers Co-Op. Vs. Dcit, Cotton Grnning & Pressing Soc. Ltd., Circle – 2(1)(1), Jahangirpura Gin., Jahangirpura, Surat Rander – 395009, "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaat3000A (Appellant) (Respondent) Appellant By Shri Ajay Uke, Sr. Dr Respondent By Shri Akshay M. Modi, Ca Date Of Hearing 23/07/2025 Date Of Pronouncement 19/08/2025

Section 143(3)Section 194A(3)(v)Section 250Section 80PSection 80P(1)Section 80P(2)(d)Section 80P(4)

deductions claimed under Chapter VIA of the Act for the aggregate amount of Rs. 2,65,23,665/- (subject to the availability of Gross Total Income), purely on misinterpretation and misconstruction of the provisions of law, misleading, mis-conceptual, arbitrary and perverse observations and hence, is liable to be quashed ... interest from investments with other co-operative societies for the aggregate amount of Rs.2,32,57,862/- (restricted to the availability of Gross Total Income) and therefore, the CIT (Appeals)'s action confirming the AO's order u/s 143(3) of the Act denying the deduction claimed under Chapter