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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

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 3779/MUM/2025[2022-23]Status: DisposedITAT Mumbai31 Jul 2025AY 2022-23

Bench: Shri Amit Shukla & Smt. Renu Jauhri

For Respondent: Ms. Hetal Vora
Section 143(1)(a)Section 244ASection 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 ... 3780/Mum/2025 AY 2023-24 Page 3 9,88,95,628/- 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 Honours

Bajaj Holdings Amd Investment Limited, Pune vs. Principal Commissioner of Income-Tax, Mumbai - 3, Mumbai

In the result, appeal of the assessee is allowed

ITA 3678/MUM/2025[2020-21]Status: DisposedITAT Mumbai31 Jul 2025AY 2020-21

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2020-21

For Appellant: Ms. Vasantiben Patel, AdvocateFor Respondent: Shri Satyaprakash R.Singh, CIT DR
Section 115JSection 143Section 143(3)Section 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

Abm Knowledgeware Limited, Mumbai vs. Assessing Officer Circle 4(1)(1), Mumbai

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

ITA 3460/MUM/2025[2020-2021]Status: DisposedITAT Mumbai31 Jul 2025AY 2020-2021

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 135Section 142(1)Section 143(2)Section 143(3)Section 263Section 37Section 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

Shiv Sagar Business Premises Co Op Soc. Ltd, Mumbai vs. Income Tax Officer Ward 22(3)(1), Mumbai

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

ITA 3104/MUM/2025[2021-22]Status: DisposedITAT Mumbai31 Jul 2025AY 2021-22

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

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

benefit u/s 80 P(2)(d)? 5. Section 80P provides that in case of assessee being a cooperative society, the gross total income which includes any income referred to sub-section 2 shall be deducted in accordance with subject to provision of this section. Sub-section 2 of section

Pashupati Capital Services Private Limited, Mumbai vs. Principal Commissioner of Income Tax Officer, Mumbai - 4, Mumbai

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

ITA 2985/MUM/2025[2020-21]Status: DisposedITAT Mumbai31 Jul 2025AY 2020-21

Bench: Shri Om Prakash Kant & Shri Raj Kumar Chauhan

Section 135Section 142(1)Section 143(2)Section 143(3)Section 263Section 28Section 37Section 37(1)Section 80G

section 37(1) by virtue of Explanation 2 of Section 37 of the Act as the deduction u/s 80G is available from the gross total income of the assessee which is the aggregate of all heads of income in contrast to section 37 which is applicable for computing the income

Axis Trustee Services Limited, Mumbai vs. Principal Commissioner of Income Tax 3, Mumbai

In the result, appeal of the assessee is allowed

ITA 2130/MUM/2025[2020-21]Status: DisposedITAT Mumbai31 Jul 2025AY 2020-21

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2020-21

For Appellant: Shri. Ashwin Kashinath, ARFor Respondent: Shri. Rajesh Kumar Yadav, CIT DR
Section 143(3)Section 263Section 37(1)Section 80G

contribution of Rs.53,80,860/- to arrive at income under the head business income of Rs. 23,52,70,704/-. Thereafter from the gross total income, assessee made a claim u/s. 80G in respect of the donation made to Axis Bank Foundation which pertained to the amount of CSR expenditure ... 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

Firmenich Aromatics Production (India) Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle 1(3)(1), Mumbai

ITA 6100/MUM/2024[2021-22]Status: DisposedITAT Mumbai31 Jul 2025AY 2021-22

Bench: Smt. Beena Pillai & Shri Girish Agrawal

For Appellant: Shri Madhur Agrawal, AdvocateFor Respondent: Ms. Ramapriya Raghavan, CIT DR
Section 144C(5)

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

Firmenich Aromatics Production (India) Private Limited, Mumbai vs. Assessing Officer, New Delhi

ITA 3987/MUM/2024[2020-21]Status: DisposedITAT Mumbai31 Jul 2025AY 2020-21

Bench: Smt. Beena Pillai & Shri Girish Agrawal

Section 144C(5)

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

Genpact Services Llc, Gurgaon vs. Assistant Commissioner of Income Tax Circle - Int Tax 1(3)(1), Delhi

ITA 4477/DEL/2024[2020-21]Status: DisposedITAT Delhi31 Jul 2025AY 2020-21

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

Section 133ASection 143(3)Section 92C

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘H’: NEW DELHI BEFORE SHRI PRAKASH CHAND YADAV, JUDICIAL MEMBER AND SHRI

Digwijay Singh, Patna vs. ITO, Ward- 4 (2), Patna

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

ITA 407/PAT/2024[2017-18]Status: DisposedITAT Patna30 Jul 2025AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 407/Pat/2024 Assessment Year: 2017-2018 Digwijay Singh,………....………………..………Appellant Near Mission Hospital, Maharaj Nagar, Maner, Patna-801108, Bihar [Pan:Cjzps5599C] -Vs.- Income Tax Officer,……………………………..Respondent Ward-4(2), Patna, Lok Nayak Jay Prakash Bhawan, 4Th Floor, Dakbunglo Chowk, Patna-800001, Bihar Appearances By: N O N E, Appeared On Behalf Of The Assessee Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: June 24, 2025 Date Of Pronouncing The Order: July 30, 2025 O R D E R

Section 115BSection 142Section 69A

procuring milk from own dairy and supply to Anuj Dairy, Hazipur and some individual customers. During the assessment year, the assessee declared gross total income of Rs.5,25,002/- and after deduction under chapter VIA, total income comes to Rs.4,79,890/- and deposited tax under self-assessment amounting

Dadasaheb Tirodkar Shaikshanik Academy, Sindhudurg vs. Itod Exemption Ward, Kolhapur

In the result, appeal of the assessee is partly allowed

ITA 1016/PUN/2025[2017-18]Status: DisposedITAT Pune30 Jul 2025AY 2017-18

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1016/Pun/2025 निर्धारण वर्ष / Assessment Year: 2017-18 | Dadasaheb Tirodkar V | The Income Tax Officer, Shaikshanik Academy, S Exemption Ward, Pandurtitha Pandur, Kudal, Kolhapur. Maharashtra. Sindhudurg - 416520. Pan: Aactd5657Q Appellant/ Assessee Respondent / Revenue Assessee By Revenue By Date Of Hearing Date Of Pronouncement Shri Nikhil Pathak & Shri Mayuresh Doshi – Ar'S Shri Eknath Abhang –Addl.Cit(Dr) 23/07/2025 30/07/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By Assessee Against The Order Of Ld.Addl./Joint Commissioner Of Income Tax(Appeal), Udaipur Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2017-18 Dated 27.02.2025, Emanating From Order U/S.154 R.W.S 143(1) Of The Income Tax Act, 1961, Dated 09.07.2024. The Assessee Has Raised Following Grounds Of Appeal :

Section 10Section 10(21)Section 10(228)Section 10(24)Section 10(46)Section 10(47)Section 11Section 11(3)Section 13ASection 13B

Losses of current year to be set off against 13v (total of 2ix, 3lx and 4ix of Schedule CYLA) 15 0 16 Gross Total Income (14-15) 16 0 Page 6 2.3 However, the ADIT(CPS) processed the Return of Income and disallowed the assessee's claim. Assessee filed

B.S.N.L Employees Junior Co Operative Credit Society Limited, Mumbai vs. ITO Ward 17(1)(2), Mumbai

In the result, the Assessee’s appeal is allowed

ITA 3263/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Jul 2025AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri Omkareshwar Chidaraassessment Year: 2017-18

For Appellant: Shri Shekhar Patwardhan, Ld. ARFor Respondent: Shri Letaqat Ali Aafaqui, Ld. Sr. AR
Section 143(3)Section 144BSection 250Section 263Section 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

Madhu Khatri, Singapore vs. DCIT Circle 3(3)(1), Bangalore

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

ITA 1032/BANG/2025[2017-18]Status: DisposedITAT Bangalore29 Jul 2025AY 2017-18

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan Kassessment Year :2017-18

For Appellant: Shri. Naman Maloo, CAFor Respondent: Shri. Pradeep S, Addl. CIT(DR)(ITAT), Bangalore
Section 10Section 10(14)Section 143(1)Section 90

capital gains of Rs.5,98,727/- and income from other sources of Rs.23,55,452/-. The return was processed on 30.03.2019 assessing the gross total income at Rs.6,17,80,857/- in which the salary income was assessed at Rs.5,83,14,734/-. Resultantly, there is variation of Rs.7

Mahesh Khandelwal, Indore vs. Addl JCIT (A) -1 Jaipur, Jaipur

Appeal is allowed

ITA 330/JPR/2024[2010-11]Status: DisposedITAT Indore28 Jul 2025AY 2010-11

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

Section 139(1)Section 139(7)Section 143(1)

FROM CAPITAL GAINS 4 otra gift [') oO INCOME FROM OTHER SOURCES 5 ora yal 8 SI 3,766 INTRA HEAD ADJUSTMENTS 0 7 GROSS TOTAL INCOME(AFTER | vy INTRA HEAD ADJUSTMENTS) f $ rf 7,98,449| ri 8 LOSS OF CURRENT YEAR ADJUSTED fi) oO 9 LOSS OF PREVIOUS YEARS ... ADJUSTED 0) 0 INCO! 10 | DETAILS | Gross TOTAL INCOME 5,28,449 7,98,449| " DEDUCTIONS UNDER CHAPTER VIA 54,413] 54,413 12 TOTAL INCOME AFTER DEDUCTIONS. 4,74,040 7,44,040 “NOTE: Always quote Document identification Number, Date of Order and PAN. Page 10f5 Page

Bastuhara Sahayata Samiti, Kolkata vs. ITO, Ward 1(2)(Exemption), Kolkata

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

ITA 444/KOL/2025[2016-17]Status: DisposedITAT Kolkata28 Jul 2025AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 444/Kol/2025 Assessment Year: 2016-2017 Bastuhara Sahayata Samiti,……………….…Appellant 27/1B, Bidhan Sarani, Srimini Market, Kolkata-700006, West Bengal [Pan:Aaatb7422R] -Vs.- Income Tax Officer,……………………………..Respondent Ward-1(2), (Exemption), Kolkata, Office Of The Income Tax Officer, 10B, Middleton Row, Kolkata-700071 Appearances By: Shri S.K. Tulsian, Advocate & Ms. Puja Somani, C.A., Appeared On Behalf Of The Assessee Shri Somnath Das Biswas, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: May 20, 2025 Date Of Pronouncing The Order: July 28, 2025 O R D E R

Section 119(2)(b)Section 12ASection 142(1)Section 143(2)Section 143(3)

brief are that the assessee filed its return of income for the assessment year 2016-17 on 22.09.2016 through CPC declaring NIL gross total income vide e-filing. The case was selected for Complete Scrutiny through CASS. Notice under section 143(2) of the Income Tax Act dated

Pratim Chakraborty, Kolkata vs. ITO, Ward 43(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 437/KOL/2025[2019-20]Status: DisposedITAT Kolkata28 Jul 2025AY 2019-20

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz)

Section 139(1)Section 143(1)Section 143(1)(a)Section 90

Appeal. 2. The facts in brief are that during the year under consideration the assessee filed his original return on 27.08.2019 declaring gross total income of Rs.20,76,800/- . Subsequently, such return of income was revised on 3 Pratim Chakraborty 31.07.2020 declaring revised gross total income of Rs.33

Bishnupur Rowtara Primary Agriculture Co-Operative Credit Society Limited., Kotwali vs. ITO, Ward- 41(1), Nadia

In the result, appeal of the Revenue is dismissed

ITA 626/KOL/2024[2016-17]Status: DisposedITAT Kolkata28 Jul 2025AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 626/Kol/2024 Assessment Year: 2016-2017 Bishnupur Rowtara Primary Agriculture Cooperative Credit Society Limited,….………Appellant Bishnupur, Kotwali, Nadia-741103, West Bengal [Pan:Aacab3042Q] -Vs.- Income Tax Officer,……………………………..Respondent Ward-41(1), Nadia, Krishnanagar, Nadia-741101, West Bengal Appearances By: Shri P.K. Ray, Shri Ripan Chand Halder & Shri Trideep Nayak, A.Rs., Appeared On Behalf Of The Assessee Shri Somnath Das Biswas, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: May 20, 2025 Date Of Pronouncing The Order: July 28, 2025 O R D E R

Section 80PSection 80P(2)(a)

applied. Section 80P(l) of the Act entitles the Cooperative Societies to deduct the sums specified in sub- section (2) from its gross total income while computing the total income. Sub-section (2) of section 80P, in the sub-clause (a) allows deduction to cooperative society which is engaged

Equipment Fabricators, Bengaluru vs. ACIT, Circle-4(2)(1), Bengaluru

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

ITA 881/BANG/2025[2016-17]Status: DisposedITAT Bangalore28 Jul 2025AY 2016-17

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyassessment Year : 2016-17

For Appellant: Shri. B. S. Balachandran, AdvocateFor Respondent: Shri. Balusamy N, JCIT(DR)(ITAT), Bangalore
Section 143Section 143(1)Section 154Section 250

/APL/S/250/2024-25/1073779488(1) dated 27.02.2025. 2. Briefly stated the facts of the case are that the assessee filed its return of income on 16.10.2016 declaring gross total income of Rs.47,81,638/-. The return was processed under section 143(1) of the Act and case was selected for scrutiny under limited scrutiny

Interactive Brokers (India) Private Limited, Mumbai vs. The Principal Commissioner of Income-Tax, Mumbai-4, Mumbai

In the result, appeal of the assessee is allowed

ITA 3783/MUM/2025[2018-19]Status: DisposedITAT Mumbai28 Jul 2025AY 2018-19

Bench: SHRI AMIT SHUKLA, JUDICIAL MEMBER\n&\nSMT RENU JAUHRI (Accountant Member)

Section 135Section 143(3)Section 203Section 263Section 800Section 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

The Byculla Market Co Operative Society Ltd, Mumbai vs. ITO, Ward 20(3)(1), Mumbai

In the result, the orders of the lower authorities are reversed and the learned AO is directed to grant deduction to the assessee on interest income earned from cooperative banks u/s 80 P (2) (d) o...

ITA 237/MUM/2025[2017-18]Status: DisposedITAT Mumbai28 Jul 2025AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri Omkareshwar Chidaraassessment Year: 2017-18

For Appellant: Shri Kumar Kale, Ld. AdvFor Respondent: Shri Leyaqat Ali Aafaqui, Ld. Sr. A.R
Section 143(3)Section 2Section 250Section 80Section 80(2)(d)Section 80P(2)(d)

assessee. 10. According to the provisions of section 80 P in case of a cooperative society the gross total income if it includes the income referred to in is subsection (2) then same shall be granted as a deduction subject to the conditions and to the extent of amount specified