“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

Infosys Limited, Bangalore vs. Deputy Commissioner of Income-Tax, Circle-3(1)(1), Bangalore

ITA 881/BANG/2023[2019-20]Status: DisposedITAT Bangalore06 Aug 2025AY 2019-20

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

Section 1Section 10ASection 155Section 250

ITA No.881/Bang/2023 ITA No.245/Bang/2024 Infosys Limited IN THE INCOME TAX APPELLATE TRIBUNAL "A" BENCH: BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT

Ravi Dyeware Company Private Limited, Nariman Point, Mumbai, Maharashtra vs. DCIT- 3(3)(1), Mumbai, Aayakar Bhawan

In the result, appeal filed by the assessee is allowed

ITA 2900/MUM/2025[2020-21]Status: DisposedITAT Mumbai06 Aug 2025AY 2020-21

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Girish Agrawalravi Dyeware Co. Pvt Ltd., Vs. Dcit – 3(3)(1) 121 Atlanta, Vs Marg Aayakar Bhavan Nariman Point, Mumbai – Mumbai. 400021. Pan/Gir No. Aaacr4665F (Applicant) (Respondent)

Section 142(1)Section 263Section 37(1)Section 80G

claim for deduction u/s.SQG 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, Section

Jubilant Foodworks Limited, Noida vs. Assistant Commissioner of Income Tax, Noida

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

ITA 184/DEL/2025[2022-23]Status: DisposedITAT Delhi06 Aug 2025AY 2022-23

Bench: Sh. M. Balaganesh & Sh. Sudhir Kumarassessment Year: 2022-23 Jubilant Food Works Vs. Assistant Commissioner Of Limited Plot No. 1A Sector Income Tax, Circle – 5 (1) 16 A Gautam Buddha Nagar (1), Noida Uttar Pradesh 201301 Pan No. Aabcd 1821 C (Appellant) (Respondent) Appellant By Sh. K M Gupta, Advocate Ms. Shruti Khimata, Ca Respondent By Sh. Jitender Singh, Cit Dr

Section 139(1)Section 139(5)Section 143(1)Section 80Section 80ASection 80J

interpretation of word “shall” as under: “…. [80JJA. Deduction in respect of employment of new employees- (1) Where the gross total income of an assessee to whom section 44B applies, includes any profits and gains derived from business, there shall, subject to the conditions specified in sub-section (2), be allowed

Subramanian Ramasamy, Coimbatore vs. Income Tax Officer, Non Corp Ward 2(2), Coimbatore

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

ITA 75/CHNY/2025[2017-18]Status: DisposedITAT Chennai05 Aug 2025AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.:75/Chny/2025 धनिाारण वर्ा / Assessment Year: 2017-18 Subramanian Ramasamy, The Income-Tax Officer, 405, Sathy Road, Vs. Non-Corp Ward 2(2), Coimbatore. Ganapathy, Coimbatore – 641 006. [Pan:Aofps-0316-E] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Shri. Darshan Bothra, C.A. प्रत्यथी की ओर से/Respondent By : Ms. Anitha, Addl. Jcit. सुनवाई की तारीख/Date Of Hearing : 21.07.2025 घोर्णा की तारीख/Date Of Pronouncement : 05.08.2025 आदेश /O R D E R Per S. R. Raghunatha, Am :

For Appellant: Shri. Darshan Bothra, C.AFor Respondent: Ms. Anitha, Addl. JCIT

Section 143(3)

being the total of the sums received from UPL Limited and Syngenta India Private Limited minus Rs.9,50,305/- being the gross total income declared by the assessee in the return of income). 6. Aggrieved by the said addition, the assessee preferred an appeal before the learned Commissioner of Income ... addition, whereas, the AO had originally added the difference of the sums reported in Form 26AS i.e., Rs.43,20,000/- and the gross total income of Rs.9,50,305/- amounting to Rs.34,19,695/- as the total income of the assessee. Hence, a sum of Rs.6,55,870/- being

Prakash Narayanan, Bengaluru vs. DCIT Circle 3(3)(1), Bengaluru

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

ITA 969/BANG/2025[2018-19]Status: DisposedITAT Bangalore05 Aug 2025AY 2018-19

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2018-19

For Appellant: Shri Anoop Agarwal, CAFor Respondent: Shri Murali Mohan, CIT-DR

Section 142(1)Section 143(2)Section 90

brief facts of the case are that the assessee is an individual and filed his revised return of income on 28/03/2019 declaring a gross total income of Rs. 1,62,94,120/-. 3. The assessee had included his income from salary and income from other sources. The return filed

Gallagher Insurance Brokers Private Limited, Mumbai vs. The Principal Commissioner of Income Tax-3, Mumbai

In the result, we set-aside the said findings of the ld PCIT as well

ITA 3778/MUM/2025[2020-21]Status: DisposedITAT Mumbai05 Aug 2025AY 2020-21

Bench: Shri Vikram Singh Yadav & Shri Sandeep Gosainassessment Year : 2020-21 Gallagher Insurance Brokers The Principal Commissioner Of Private Limited, Income Tax-3, Unit No. 34, Tower-3, Vs. Room No. 612, 6Th Floor, 4Th Floor, Wing-B, Aayakar Bhavan, Kohinoor City Mall, Maharshi Karve Road, Kohinoor City, Mumbai-400020. Kirol Road, Kurla West, Mumbai-400070. Pan : Aaaci7196J (Appellant) (Respondent) Assessee By : Shri Mahadev P. Lohia Revenue By : Shri Swapnil Choudhary Date Of Hearing : 31-07-2025 Date Of Pronouncement : 05-08-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Principal Commissioner Of Income Tax-Mumbai-3 [„Ld.Pcit‟], Dated 28-03-2025 Passed U/S. 263 Of The Income Tax Act, 1961 („The Act‟), Pertaining To Assessment Year (Ay) 2020-21. 2. During The Course Of Hearing, The Ld.Ar Taken Us Through The Findings Of The Ld.Pcit, Which Are Contained At Paragraph No. 7.2 & 7.3 Of The Impugned Order & The Contents Thereof Read As Under:

For Appellant: Shri Mahadev P. LohiaFor Respondent: Shri Swapnil Choudhary

Section 263Section 40aSection 80G

that the contribution should be voluntary and that the CSR spend is an application of income which is eligible for deduction from the gross total income of the assessee as per the provisions of section 80G. 6. The word "donation" has not been defined under the Act. However ... under the provision of Section 28-44DB whereas the deduction under section 80G is claimed under Chapter VIA ie. after computing the Gross Total Income. The provisions of section 80G does not impose any condition that the contribution should be voluntary and therefore when the CSR spend is evaluated

Coral India Finance & Housing Limited, Mumbai vs. The Principal Commissioner of Income Tax - 3, Mumbai

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

ITA 2496/MUM/2025[2020-21]Status: DisposedITAT Mumbai05 Aug 2025AY 2020-21

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri V K Ginde, ARFor Respondent: Shri R A Dhyani, (CIT-DR)

Section 135Section 142(1)Section 143Section 143(3)Section 263Section 37Section 37(1)Section 80GSection 80G(2)(a)

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

Dy..C.I.T., Bangalore vs. M/S State Bank of Mysore, Bangalore

In the result, the appeal of the Revenue Ground-3 is dismissed

ITA 683/BANG/2015[2010-11]Status: DisposedITAT Mumbai05 Aug 2025AY 2010-11

Bench: Shri Narendra Kumar Billaiya, Account Member & Shri Anikesh Banerjee

For Appellant: Shri Ketan Ved & Ninad PatadeFor Respondent: Shri P.C. Chhotaray, Spl. Counsel

Section 143(3)Section 250Section 36(1)(vii)Section 36(1)(viia)Section 41(1)Section 41(4)

profession [before allowing deduction under section 36(1)(viii)] as apportioned based on the ratio of interest income from eligible business to the gross total income. It is submitted that there is no requirement of maintaining a separate set of books of accounts for the purpose of claiming a deduction ... assessee has consistently followed the method of apportionment of profits based on the ratio of interest income from eligible business to the gross total income and has accordingly transferred Rs. 60,42,30,000/- to the Special Reserve. The Ld. AO disallowed the deduction primarily on two grounds: (i) absence

State Bank of Mysore, Bangalore vs. JCIT, Bangalore

In the result, the appeal of the Revenue Ground-3 is dismissed

ITA 660/BANG/2015[2010-11]Status: DisposedITAT Mumbai05 Aug 2025AY 2010-11

Bench: Shri Narendra Kumar Billaiya, Account Member & Shri Anikesh Banerjeestate Bank Of India Vs Joint Commissioner Of Income-Tax, (Erstwhile State Bank Of Large Tax Payers Unit, Bangalore Mysore Prior To Merger) Local Head Office Compliance Department, 4Th Floor, 65, St. Marks Road, Bangalore-560 001 Pan: Aaccs0155P Appellant Respondent Deputy Commissioner Of Vs State Bank Of Mysore Income-Tax, Ltu, Circle-1, Head Office, Finance & Accounts Bangalore Department, Kg Road, Bangalore- 560 009 Pan: Aaccs0155P Appellant Respondent

For Appellant: Shri Ketan Ved & Ninad PatadeFor Respondent: Shri P.C. Chhotaray, Spl. Counsel

Section 143(3)Section 250Section 36(1)(vii)Section 36(1)(viia)Section 41(1)Section 41(4)

Bibhisanpur Samabay Krishi Unnayan Samity Ltd., Kolkata vs. I.T.O., Ward - 27(4), Haldia/ Wbg-W-176(3), Haldia

ITA 1021/KOL/2024[2020-2021]Status: DisposedITAT Kolkata04 Aug 2025AY 2020-2021

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 250Section 56Section 80PSection 80P(2)(a)

contention of the learned counsel for the assessee misses two essential points required for claiming the exemption or 100% deduction from gross total income for a co- operative society: (i) that the character or nature of income, namely interest on investments or deposits, does not change irrespective of the fact

Prathamik Krushi Pattin Sahakar Sangh Niyamit Chimmad, Jamkhandi vs. Income Tax Officer, Ward-1, Bagalkot

ITA 286/BANG/2025[2018-19]Status: DisposedITAT Bangalore04 Aug 2025AY 2018-19

Bench: Shri Prashant Maharishi

For Appellant: Shri Ashok Mudnur, CAFor Respondent: Shri Ganesh R. Ghale, Standing Counsel for the Revenue

Section 143Section 80Section 80P

IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH : BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE PRESIDENT ITA No.286/Bang/2025 Assessment year : 2018

Assistant Commissioner of Income Tax, Circle- 1(1)(1), Dehradun vs. Thdc India Limited, Tehri

In the result, the appeal of the Revenue is dismissed as above

ITA 120/DDN/2024[2020-21]Status: DisposedITAT Dehradun31 Jul 2025AY 2020-21

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

Section 115JSection 7Section 80I

this juncture, it is relevant to set out sub-section (1) of section 80IA which provides that : `Where the gross total income of an assessee includes any profits and gains derived by an undertaking or an enterprise from any business referred to in sub-section (4) (such business being hereinafter

Mrs. Nidhi Yadav, Dehradun vs. ITO, Rudrapur

In the result, the assessee’s appeal is allowed for statistical purposes

ITA 117/DDN/2024[2015-16]Status: DisposedITAT Dehradun31 Jul 2025AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraita No.115/Ddn/2024, A.Y. 2013-14 Ita No.117/Ddn/2024, A.Y. 2015-16 Nidhi Yadav, Vs. Income Tax Officer, B-801, Forest Residency, Ward 2(1)(4), Dehradun, Uttarakhand Income Tax Office, Pin Code: 248014 Rudrapur, Uttarakhand Pan: Acapy5157E (Respondent) Appellant By Sh. Mohit Dev, Ca Respondent By Sh. Amarpal Singh, Sr. Dr Date Of Hearing 06/05/2025 Date Of Pronouncement 31/07/2025 Order Per Avdhesh Kumar Mishra, Am Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

Section 143(1)Section 148Section 271(1)(c)Section 69A

that the total credits in these two bank accounts are at Rs. 12,55,235/-. Whereas, the assessee has declared gross total income in the ROI for the year under consideration at Rs.6,92,034/-. There is extra credit of Rs.5,63,200/- found in the bank accounts

Smt. Nidhi Yadav, Dehradun vs. ITO- W-2(1)(4), Rudrapur

In the result, the assessee’s appeal is allowed for statistical purposes

ITA 115/DDN/2024[2013-14]Status: DisposedITAT Dehradun31 Jul 2025AY 2013-14

Section 143(1)Section 148Section 271(1)(c)Section 69A

Devendra Pratap Singh, Kumarganj Faizabad vs. ITO-1, Faizabad-New, Faizabad

In the result, the appeal of the assessee is partly allowed

ITA 176/LKW/2025[2017-2018]Status: DisposedITAT Lucknow31 Jul 2025AY 2017-2018

Bench: SH. SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Purnodaya Kumar Singh, AdvFor Respondent: Sh. Amit Kumar, DR

Section 142(1)Section 147Section 148Section 250Section 69A

went through the return of the assessee filed for the assessment year 2017-18 and recorded the fact that the assessee had shown gross total income of Rs. 10,42,396/- and total taxable income of Rs. 8,92,400/-. It 8 A/w S.A. No.1/LKW/2025 Devendra Pratap Singh

Capri Global Advisory Services Pvt. Ltd. (Now Amalgamated With Capri Global Holdings Pvt. Ltd.), Mumbai vs. Deputy Commissioner of Income Tax, Circle - 1(1)(1), Mumbai

In the result all the appeals of the assessee are allowed

ITA 4140/MUM/2025[2020-21]Status: DisposedITAT Mumbai31 Jul 2025AY 2020-21

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

Section 143(3)Section 14ASection 80G

claimed deduction for the said amount Capri Global Advisory Services Pvt. Ltd., under section 80G, treating such contributions as eligible donations from the gross total income. 15. The Assessing Officer, however, disallowed the claim, taking the view that since the donations were made in fulfilment of a statutory CSR obligation ... 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

Capri Global Advisory Services Pvt. Ltd. (Now Amalgamated With Capri Global Holdings Pvt. Ltd.), Mumbai vs. Deputy Commissioner of Income Tax, Circle - 1(1)(1), Mumbai

In the result all the appeals of the assessee are allowed

ITA 4139/MUM/2025[2018-19]Status: DisposedITAT Mumbai31 Jul 2025AY 2018-19

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

Section 143(3)Section 14ASection 80G

Capri Global Advisory Services Pvt. Ltd. (Now Amalgamated With Capri Global Holdings Pvt. Ltd.), Mumbai vs. Deputy Commissioner of Income Tax, Circle - 1(1)(1), Mumbai

In the result all the appeals of the assessee are allowed

ITA 4138/MUM/2025[2017-18]Status: DisposedITAT Mumbai31 Jul 2025AY 2017-18

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

Section 143(3)Section 14ASection 80G

Innoven Capital India Private Limited, Mumbai vs. Principal Commissioner of Income Tax, Mumbai - 3, Mumbai

In the result, appeal of the assessee is allowed

ITA 3784/MUM/2025[2020 - 2021]Status: DisposedITAT Mumbai31 Jul 2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

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

Il&Fs Investment Managers Limited, Mumbai vs. Deputy Commissioner of Income Tax - 14(1)(1), Mumbai

In the result the appeal filed by the assessee stands allowed

ITA 3780/MUM/2025[2023-24]Status: DisposedITAT Mumbai31 Jul 2025AY 2023-24

Bench: Shri Amit Shukla & Smt. Renu Jauhri

For Respondent: Ms. Hetal Vora

Section 143(1)(a)Section 250Section 80M

restricting the deduction u/s 80M to Rs. 21,72,32,748/- without appreciating the fact that deduction u/s 80M is allowed from the Gross total income and so long as Appellant has Gross total income, the eligible amount of deduction u/s 80M should be available. The appellant prays before Your ... restricting the deduction u/s 80M to Rs. 21,72,32,748/- without appreciating the fact that deduction u/s 80M is allowed from the Gross total income and so long as Appellant has Gross total income, the eligible amount of deduction u/s 80M should be available. The appellant prays before Your