“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

Deputy Commissioner of Income Tax, Chennai vs. Ashok Leyland Limited, Chennai

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

ITA 1663/CHNY/2024[2019-20]Status: DisposedITAT Chennai07 Jul 2025AY 2019-20

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.R. VijayaraghavanFor Respondent: Ms.Ann Marry Baby, CIT

Section 14ASection 92C

manufacturing of article or thing and the profit therefrom is eligible for deduction u/s.80-IC if that profit is part and parcel of the gross total income. As noted hereinabove, profit is the difference between the purchase price and the cost of production along with the cost of bringing the product

Avinash S Sadamate, ACIT, Circle 3 3 1 Mumbai, Mumbai vs. Rashmi Infrastructure Developers Limited, Mumbai

In the result, both the Revenue's appeal and Cross

ITA 6605/MUM/2024[2013-14]Status: DisposedITAT Mumbai07 Jul 2025AY 2013-14

Bench: Shri Pawan Singh & Shri Prabhash Shankar

For Appellant: Shri Madhur Agrawal / Jay Bhansali, ARsFor Respondent: Shri Uma Shankar Prasad, (CIT DR)

Section 133ASection 139(1)Section 143(3)Section 801B(10)Section 801B(10)(c)

Less: Depreciation as per IT Act (5,32,258) Profits and Gains from Business or 4,52,41,876 Profession Gross Total Income 4,52,41,876 Less Deduction u/s 80-IB(10) of 8,40,77,301 the Act Restricted to (4,52,41,876) Total Income NIL Therefore

Barkatullah Vishwavidyalaya, Bhopal vs. ITO NFAC, Delhi

Appeal is allowed for statistical purpose

ITA 871/IND/2024[2019-2020]Status: DisposedITAT Indore04 Jul 2025AY 2019-2020

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

Section 12ASection 13(3)Section 143(3)

Bakeri Projects Private Limited, Ahmedabad vs. DCIT Circle 1(1)(1), Ahmedabad

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

ITA 954/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad04 Jul 2025AY 2020-21

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokarasstt.Year : 2020-21 Bakeri Projects Pvt. Lt. The Dcit, Cir.(1)(1) 1St Floor, Sanskrut Vs. Ahmedabad. Old High Court Road Off: Ashram Road Ahmedabad. Pan : Aagcb 1864 L (Applicant) (Responent)

For Appellant: Shri Deepak Shah, AR, and Shri Bharat Shah, ARFor Respondent: Shri R.P. Rastogi, CIT-DR

Section 142(1)Section 143(3)Section 263Section 80I

said return was revised on 30.03.2021 declaring a total income of ‘NIL’ after setting off unabsorbed depreciation loss under normal provisions against gross total income. The case was selected for scrutiny and assessment proceedings were conducted under section 143(3) r.w.s. 144B of the Act. During the course of assessment ... claim of unabsorbed depreciation pertaining to earlier years including A.Y. 2018–19 and 2019–20. The assessment was finally framed determining the gross total income under normal provisions at Rs.62,91,18,337 and net total income (after Chapter VI-A deductions under section 80IBA of Rs.35

Mehanati Kishan S K U S Ltd., Ghatal, Paschim Medinipore vs. I.T.O., Ward - 38(1), Midnapur

In the result, appeal of the assessee allowed

ITA 940/KOL/2025[2018-2019]Status: DisposedITAT Kolkata02 Jul 2025AY 2018-2019

Bench: Shri George Mathanआयकर अपील सं/Ita No.940/Kol/2025 (नििाारण वर्ा / Assessment Year :2018-2019) Mehanati Kishan Skus Limited, Vs Ito, Ward-38(1), Midnapur Chaksultan, Panchberia, Ghatal, Paschim Medinipore, West Bengal Pan No. :Aaaam 7196 E (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. : Shri S.M.Surana, Advocate नििााररती की ओर से /Assessee By राजस्व की ओर से /Revenue By : Shri S.B. Chakraborthy, Addl. Cit-Sr.Dr सुनवाई की तारीख / Date Of Hearing : 02/07/2025 घोषणा की तारीख/Date Of Pronouncement : 02/07/2025

For Respondent: Shri S.B. Chakraborthy, Addl. CIT-Sr.DR

Section 80P(2)(d)

perusal of Section 80P(1) 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

C P Metaliks Private Limited, G.T. Road Bhiringee vs. Income Tax Officer, Ward 1(2), Durgapur

In the result, the appeal is partly allowed

ITA 1482/KOL/2024[2009-10]Status: DisposedITAT Kolkata01 Jul 2025AY 2009-10

Bench: Shri George Mathan & Shri Rakesh Mishraassessment Year: 2009-10

For Appellant: NoneFor Respondent: Shri Kapil Mandal, DR

Section 250Section 68

concern. On perusal of the documents filed by the appellant it is seen that M/s.Wondermax Tracon Pvt. Ltd. has filed a return with gross total income of Rs.1,079/- for A.Y.2007-08 only. The company had a profit before tax of Rs.1079/- for A.Y.2017-18 and Rs.74964/- for A.Y.2008-09

Acg Pam Pharma Technologies Pvt. Ltd, Mumbai vs. Principal Commissioner of Income Tax-4, Mumbai

In the result, appeal filed by the assessee is allowed

ITA 2734/MUM/2025[2021-22]Status: DisposedITAT Mumbai01 Jul 2025AY 2021-22

Bench: Shri Sandeep Gosain(Jm) & Shri Prabhash Shankar(Am) Acg Pam Pharma Technologies Pcit-4 Private Limited Room No. 629 127, Kandivali Industrial Vs. Aayakar Bhavan Estate, Charkop, Kandivali W M.K. Road Mumbai-400 067. Mumbai-400 020. Pan : Aaacp4776H Appellant Respondent

For Appellant: Shri Aditya RaiFor Respondent: Shri K.K. Ved

Section 135Section 143(3)Section 263Section 30Section 36Section 37Section 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 tlwt 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

Jivrajbhai Mavjibhai Pa vs. Iya, Suratvs.Income Tax Officer Ward 3(3)(1) Surat, Ayakar Bhawan, Surat

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

ITA 1102/SRT/2024[2017-18]Status: DisposedITAT Surat30 Jun 2025AY 2017-18

Bench: Shri Tr Senthil Kumar & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1120/Srt/2024 Assessment Year: (2017-18) (Hybrid Hearing) Jivrajbhai Mavjibhai Pavsiya 204, Amizara Palace, B/H Vs. Gabani Kidney Hospital, Lal Darwaja, Surat-395006 Income Tax Officer Ward No.3(3)(2), Surat, Ayakar Bhawan, Majura Gate Nr. New Civil Hospital, Surat-395 001 स्थायीलेखासं. / जीआइआरसं./Pan/Gir No: Adwpp 2625 F (अपीलार्थी/Appellant) (प्रत्यर्थी / Respondent) निर्धारिती की ओर से /Appellant By Shri Kamlesh Pandya, Ca राजस्व की ओर से /Respondent By Ms. Neerja Sharma, Sr-Dr सुनवाई की तारीख/Date Of Hearing 08/05/2025 उ‌द्घोषणा की तारीख/Date Of Pronouncement 30/06/2025 आदेश / Order Per Bijayananda Pruseth, Am: This Appeal By The Assessee Emanates From The Order Passed Under Section 250 Of The Income-Tax Act, 1961 (In Short, 'The Act') Dated 30.08.2024 By The National Faceless Appeal Centre, Delhi /Commissioner Of Income-Tax (Appeals) [In Short, 'Cit(A)'] For The Assessment Year (Ay) 2017-18, Which In Turn Arises Out Of Assessment Order Passed By Assessing Officer (In Short, 'Ao') U/S 143(3) Of The Act Dated 27.12.2019. Grounds Of Appeal Raised By The Assessee Are As Under: "1. Learned Cit(A) Erred In Making Order By Upholding Addition Made By Ito Without Considering Facts, Circumstances Of Our Case & Submission Made By Us During Appeal Proceedings Even Though Source Of Cash Deposit Already Explained, Therefore Section 69A Not Applicable In Our Case.

Section 115BSection 143(2)Section 143(3)Section 250Section 44ASection 69A

Rs.7,71,930/-. Thus, agricultural income of Rs.10,38,320/- has been accepted by the AO. In AY 2014-15, assessee had declared gross total income of Rs.3,72,237/- and agricultural income of Rs.3,28,560/- (page-101 of PB). In AY 2015-16, assessee has shown gross total ... income of Rs.4,90,135/- and agricultural income of Rs.4,90,290/- (page 109 of PB). The assessee has declared gross total income of Rs.6,24,269/- and Rs.7,68,531/- in AYs 2016-17 and 2017-18 respectively (pages 136 and 143 of PB). Considering the above

Invesco(India) Private Limited, Hyderabad vs. DCIT, Circle -2 (1), Hyderabad

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

ITA 111/HYD/2022[2017-18]Status: DisposedITAT Hyderabad30 Jun 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA, Sriram SeshadriFor Respondent: Shri B Bala Krishna, CIT-DR

Section 143(3)Section 144C(5)

section 80G of the Act in respect of eligible donations/ payments made by Appellant for the year under consideration based on the assessed Gross Total Income. 6.1. Without prejudice to Grounds 4 & 5 above, that on the facts and in the circumstances of the case

K.K.Chinnaputhur Paccs, Tiruppur vs. ITO, Ward-2(4), Tiruppur

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 829/CHNY/2025[2016-17]Status: DisposedITAT Chennai30 Jun 2025AY 2016-17

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. Nos.828 & 829/Chny/2025 िनधा"रण वष"/Assessment Years: 2015-16 & 2016-17 K.K. Chinnaputhur Primary Agricultural Vs. The Income Tax Officer, Co-Operative Credit Society, 52/37A, Ward 2(4), Reddipalayam, Chinnapudhur Post, Tiruppur. Dharapuram, Tiruppur 638 656. [Pan:Aabak3665K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sridhar, Advocate (Erode) ""थ" की ओर से/Respondent By : Ms. R. Anita, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 04.06.2025 घोषणा की तारीख /Date Of Pronouncement : 30.06.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Appeals Filed By The Assessee Are Directed Against Separate Orders Dated 29.08.2024 & 18.02.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Years 20015-16 & 2016-17 Respectively.

For Appellant: Shri S. Sridhar, Advocate (Erode)For Respondent: Ms. R. Anita, Addl. CIT

Section 142(1)Section 143(2)Section 147Section 148Section 3Section 69ASection 80PSection 80P(2)

income from undisclosed sources under section 69A r.w.s. 115BBE of the Act. 7. The Assessing Officer further noted that the assessee has shown gross total income at ₹.7,56,308/- and claimed entire income as 4 I.T.A. Nos.828 & 829/Chny/25 deduction under section 80P of the Act on the ground that

K.K. Chinnaputhur Paccs, Tiruppur vs. ITO, Ward-2(4), Tiruppur

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 828/CHNY/2025[2015-16]Status: DisposedITAT Chennai30 Jun 2025AY 2015-16

For Appellant: Shri S. Sridhar, Advocate (Erode)For Respondent: Ms. R. Anita, Addl. CIT

Section 142(1)Section 143(2)Section 147Section 148Section 3Section 69ASection 80PSection 80P(2)

Income-Tax Officer, Ward-7(2)(1), Bengaluru vs. M/S. Bangalore Credit Co-Operative Society Limited, Bengaluru

ITA 2347/BANG/2024[2018-19]Status: DisposedITAT Bangalore30 Jun 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Respondent: Sri Sandeep Chalapathy, A.R

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

ITA Nos.2347 & 2348/Bang/2024 & CO Nos.4 & 5/Bang/2025 M/s. Bangalore Credit Co-operative Society Ltd., Bangalore “A”BENCH: BANGALORE BEFORE SHRI WASEEM

Savitrivasudeva Govinda Rao, Bangalore vs. Income Tax Office, Ward-3(3)(4), Bengaluru

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

ITA 2072/BANG/2024[2017-18]Status: DisposedITAT Bangalore30 Jun 2025AY 2017-18

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri Annamalai, Advocate

Section 115BSection 250Section 69A

other income, mainly used the interest income for his livelihood. During the A.Y., the assessee filed his revised return of income declaring a gross total income of Rs. 3,30,860/-. Thereafter the case was selected for limited scrutiny to examine the issue of cash deposits made during the demonetisation

Jai Jalaram Co-Operative Credit Society Limited, Mumbai vs. The Income Tax Officer, Ward 29(1)(5), Mumbai

In the result appeal of the assessee is allowed partly for esult appeal of the assessee is allowed partly for esult appeal of the assessee is allowed partly for statistical purpose

ITA 2887/MUM/2025[2015-16]Status: DisposedITAT Mumbai30 Jun 2025AY 2015-16

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2015-16 Jai Jalaram Co-Operative Credit The Ito Ward 29(1)(5), Society Ltd., Kautilya Bhavan, Bandra Kurla Vs. Shop No. -2 Ground Floor, Shop Complex, No. -2 Ground Floor, Mulund Mumbai-400051. Siddhivinayak C.H.S. Near Punjab National Bank Zaver Road, Mulund West, Mumbai-400080. Pan No. Aaaaj 2603 B Appellant Respondent

For Appellant: Mr. Pravin Chavan, Sr. DRFor Respondent: None

Section 143(3)Section 56Section 80P(2)(a)Section 80P(2)(d)Section 80P(4)

Secondly, for purposes of eligibility for deduction, the assessee uction, the assessee must be a "co- -operative society" ill) Thirdly, the gross total income must include income that is ill) Thirdly, the gross total income must include income that is ill) Thirdly, the gross total income must include income that

Rahul Ramesh Ektare, Thane vs. Circle 5(3)(1), Mumbai

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

ITA 2886/MUM/2025[2018-19]Status: DisposedITAT Mumbai30 Jun 2025AY 2018-19

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2018-19 Rahul Ramesh Ektare Circle 5(3)(1) 1101, Dahila, Runwal Garden City, Aayakar Bhavan, Maharshi Balkum, Balukum S.O., Thane, Vs. Karve Rd, New Marine Lines, Mumbai-400608 Churchgate, Mumbai- 400020 Pan No. Aafpe 5470 R Appellant Respondent

For Appellant: Mr. Devendra JainFor Respondent: Mr. Pravin M Chavan, CIT-DR

Section 143(1)Section 249(3)

from which a loss of ₹1,75,182/- was claimed under the head “Income from House Property”, resulting in a gross total income of ₹18,88,007/-. After claiming a deduction of ₹1,50,000/- under Chapter VI-A of the Income-tax Act, 1961 (hereinafter referred

Priya Kapil Todarwal, Mumbai vs. Income Tax Officer Ward, 30(1)(1), Mumbai

In the result the appeal filed by the assessee stands allowed

ITA 1838/MUM/2025[2019-20]Status: DisposedITAT Mumbai30 Jun 2025AY 2019-20

Bench: Smt. Beena Pillai () & Smt. Renu Jauhri ()

Section 143(1)Section 143(1)(a)Section 154Section 71(2)Section 80A(1)Section 80CSection 80DSection 80GSection 80T

intimation the assessee preferred appeal before the Ld.CIT(A). 3. Before the Ld. CIT(A) the assessee submitted that, the gross total income of Rs.1,00,29,935/- included income from other sources of Rs. 9,38,459/- the assessee claimed deduction of Rs.1,93,000/- under Chapter ... submitted that, as per Section 80A(1) In computing the total Income of an assessee, there shall be allowed from gross total income, in accordance with and subject to the provisions of this Chapter, the deductions specified in sections 80C to 80U. 4 ITA 1838/Mum/2025; A.Y. 2019-20 Priya Kapil

Vardhaman Vasundhara Family Trust, Pune vs. ITO, Ward 7(1), Pune

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

ITA 741/PUN/2025[2022-23]Status: DisposedITAT Pune27 Jun 2025AY 2022-23

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.741/Pun/2025 धििाारण वर्ा / Assessment Year : 2022-23 Vardhaman Vasundhara Family Trust, Income Tax Officer, S. No. 1A, F-1, Irani Market Compound, Ward – 7(1), Pune Yerwada, Pune-411006 Vs. Pan : Aactv6457E अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri C.H. Naniwadekar Department By : Shri Akhilesh Srivastva Date Of Hearing : 25-06-2025 Date Of 27-06-2025 Pronouncement :

For Appellant: Shri C.H. NaniwadekarFor Respondent: Shri Akhilesh Srivastva

Section 143Section 143(1)Section 143(1)(a)

Amount as provided by the tax payer" and "Amount as computed u/s 143[1]", the same remained to be adjusted in computation of gross total income in the intimation u/s 143(1). 4. In not appreciating that the response was submitted in respect of the prior intimation

Bright Paints Pvt Ltd, Mumbai vs. Dy Commissioner of Income Tax - 12(1)(2), Mumbai

In the result, the ground no

ITA 6817/MUM/2024[2014-15]Status: DisposedITAT Mumbai27 Jun 2025AY 2014-15

Bench: MS. KAVITHA RAJAGOPAL (Judicial Member), SHRI OMKARESHWAR CHIDARA (Accountant Member)

For Appellant: Shri. Nitesh JoshiFor Respondent: Shri. Leyaqat Ali, SR. DR

Section 143(1)Section 143(2)Section 143(3)(ii)Section 14ASection 250Section 73

That the NFAC ought to have held that the Appellant's case falls within the exception to the said Explanation as its gross total income consisted mainly of income from house property and income by way of capital gains. In any event of the matter, if derivatives ... speculative transaction. On the contrary, the Explanation to Section 73 states in case of loss in speculation business other than the company whose gross total income consists mainly of income which is chargeable under the head interest on 5 Bright Paints Pvt. Ltd. securities, income from house property, capital gain

United Phosphorus Ltd, Mumbai vs. DCIT Cen Cir 38, Mumbai

ITA 6950/MUM/2013[2004-05]Status: DisposedITAT Mumbai27 Jun 2025AY 2004-05

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Ms. Vasanti Patel, Advocate and Ms. Saisudha Multani, CAFor Respondent: Shri Abhishek Tharwal, Sr. DR

Section 2(24)(x)Section 36(1)Section 36(1)(va)Section 80

deduction u/s.80HHC as against claim of assessee of Rs.3,87,70,453/-. According to him, deduction u/s.80HHc is not allowable as the gross total income is negative and thus, the same is also not allowable while computing book profit u/s.115JB. 8. 2. Revenue has come up in appeal vide ground

Iifl Samasta Finance Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-(1)(1), Bangalore

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

ITA 18/BANG/2025[2023-24]Status: DisposedITAT Bangalore26 Jun 2025AY 2023-24

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year : 2023-24 Iifl Samasta Finance Limited 110/3, Lalbagh Main Road Krishnappa Layout Dcit Vs. Bangalore 560 027 Circle 3(1)(1) Bangalore Pan No :Aaacc4577H Appellant Respondent

For Appellant: Sri Gowthama H.V., A.RFor Respondent: Smt. Srinandini Das, D.R

Section 139Section 139(1)Section 143(1)Section 143(1)(a)Section 250Section 44ASection 80J

return of income was processed and accordingly an intimation under section 143(1) of the act was passed on 29/05/2024 by accepting the gross total income as declared by the assessee company, however the deduction under section 80JJAA of the act amounting to Rs. 35,71,25,441/- as claimed ... relevant provisions of the Act for ease of reference & record: - Deduction in respect of employment of new employees. 80JJAA (1) Where the gross total income of an assessee to whom section 44AB applies, includes any profits and gains derived from business, there shall, subject to the conditions specified