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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

The Haryana State Co-Operative Agriculture and Rural Development, Panchkula vs. DCIT, Circle, Panchkula

Appeal is allowed

ITA 589/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh30 May 2025AY 2015-16

Bench: BEFORE: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

relevant extract of this provision is as under : “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

The Haryana State Co-Operative Agriculture and Rural Development, Panchkula vs. DCIT, Circle, Panchkula

Appeal is allowed

ITA 588/CHANDI/2024[2014-15]Status: DisposedITAT Chandigarh30 May 2025AY 2014-15

Bench: BEFORE: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

relevant extract of this provision is as under : “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

Bindumalyam Panduranga Allanharinarayan, Bangalore vs. Income Tax Officer, Ward-5(2)(1), Bengaluru

ITA 107/BANG/2025[2018-19]Status: DisposedITAT Bangalore30 May 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Sri Bharadwaj Sheshadri, A.RFor Respondent: Smt. Neha Sahay, D.R
Section 143(1)Section 143(2)Section 23Section 250Section 44A

Loss) (11,06,093) Long Term Capital Gain (Exempt Income) 9,88,565 Income from Other Sources(as per return) 9,74,634 Gross Total Income 3,05,05,085 Less Deduction U/C VI A 1,68,750 Assessed Income 3,03,36,335 4. Aggrieved by the assessment completed

ACIT-2(1)(1), Mumbai vs. Geecee Ventures Limited, Mumbai

The appeal is allowed for statistical purposes

ITA 4119/MUM/2024[2018-19]Status: DisposedITAT Mumbai30 May 2025AY 2018-19

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Rahul SardaFor Respondent: Shri Bhangepatil Pushkaraj Ramesh
Section 143Section 143(1)Section 143(3)Section 14ASection 250Section 80I

return at Rs.1,57,73,420/- adjusted and disallowed u/s.143(1) as the assessee had no business income included in the gross total income, specifically ignoring the fact that the net result of computation of the business income disclosed by assessee and included in the gross total income ... relevant previous year. After setting off the aforesaid loss with Net Capital Gains of INR.9,10,81,871/-, the Assessee had Gross Total Income of INR.8,47,55,788/-. The Assessee claimed deduction of INR.1,57,73,420/- under Section 80IA falling in Chapter VIA of the Act from

Geecee Ventures Limited, Mumbai vs. DCIT, Circle 2(1)(1), Mumbai

The appeal is allowed for statistical purposes

ITA 3975/MUM/2024[2018-19]Status: DisposedITAT Mumbai30 May 2025AY 2018-19

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Rahul SardaFor Respondent: Shri Bhangepatil Pushkaraj Ramesh
Section 143Section 143(1)Section 143(3)Section 14ASection 250Section 80I

return at Rs.1,57,73,420/- adjusted and disallowed u/s.143(1) as the assessee had no business income included in the gross total income, specifically ignoring the fact that the net result of computation of the business income disclosed by assessee and included in the gross total income ... relevant previous year. After setting off the aforesaid loss with Net Capital Gains of INR.9,10,81,871/-, the Assessee had Gross Total Income of INR.8,47,55,788/-. The Assessee claimed deduction of INR.1,57,73,420/- under Section 80IA falling in Chapter VIA of the Act from

DCIT Cir 6(1)(2), Mumbai vs. Biostach India Ltd, Mumbai

In the result, the appeal of the assessee is partly allowed and the revenue’s appeal is dismissed

ITA 3559/MUM/2016[2011-12]Status: DisposedITAT Mumbai30 May 2025AY 2011-12

Bench: Shri Sandeep Gosain & Smt. Renu Jauhriआयकर अपील सं./Ita No. 349/Mum/2016 (निर्धारण वर्ा / Assessment Year :2011-12) Biostadt India Limited V/S. Dcit 6(1), Mumbai Poonam Chambers, A बिधम Aayakar Bhavan, Mumbai- Wing, 6Th Floor, Dr. A. B. 400020 Road, Worli, Mumbai- 400018 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaccb1830G Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी

For Appellant: Shri Kirit KamdarFor Respondent: Shri Leyaqat Ali Aafaqui
Section 115Section 115JSection 14ASection 154Section 250Section 263Section 32Section 32(1)(iia)Section 80

issue are that the assessee has claimed deduction u/s 80-IB at Rs. 14,93,24,525/-, which was restricted to the gross total income of Rs. 7,35,12,861/-. The assessee submitted Form 10CCB in respect of Jammu and Silvassa units showing deduction claimed

Biostadt India Ltd, Mumbai vs. DCIT Cir 6(1), Mumbai

In the result, the appeal of the assessee is partly allowed and the revenue’s appeal is dismissed

ITA 349/MUM/2016[2011-12]Status: DisposedITAT Mumbai30 May 2025AY 2011-12

Bench: Shri Sandeep Gosain & Smt. Renu Jauhriआयकर अपील सं./Ita No. 349/Mum/2016 (निर्धारण वर्ा / Assessment Year :2011-12) Biostadt India Limited V/S. Dcit 6(1), Mumbai Poonam Chambers, A बिधम Aayakar Bhavan, Mumbai- Wing, 6Th Floor, Dr. A. B. 400020 Road, Worli, Mumbai- 400018 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaccb1830G Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी

For Appellant: Shri Kirit KamdarFor Respondent: Shri Leyaqat Ali Aafaqui
Section 115Section 115JSection 14ASection 154Section 250Section 263Section 32Section 32(1)(iia)Section 80

issue are that the assessee has claimed deduction u/s 80-IB at Rs. 14,93,24,525/-, which was restricted to the gross total income of Rs. 7,35,12,861/-. The assessee submitted Form 10CCB in respect of Jammu and Silvassa units showing deduction claimed

Mohd. Ayaz, Lucknow vs. DCIT, Range-4, Lucknow

In the result, the appeal of the assessee is allowed

ITA 213/LKW/2025[2017-18]Status: DisposedITAT Lucknow29 May 2025AY 2017-18

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

For Appellant: Sh. Rakesh Garg, AdvocateFor Respondent: Sh. Vachaspati, CIT DR
Section 143(3)Section 250Section 263Section 282Section 40A(3)Section 69A

income from supply of Buffaloes and has shown sale of goods at Rs. 67,63,71,053/-. After deducting purchases and expenditures, the gross total income had been shown at Rs. 34,81,704/- and after deduction under Chapter VI-A, the net income from business had been shown

Vardayini Co-Operative Housing Society Limited, Pune vs. Income Tax Officer, Ward-2(2), Pune

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

ITA 1991/PUN/2024[2020-21]Status: DisposedITAT Pune29 May 2025AY 2020-21

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1991/Pun/2024 िनधा"रण वष" / Assessment Year : 2020-21 Vardayini Co-Operative Vs. Ito, Ward-2(2), Pune. Housing Society Limited, Plot No.96, Vardayini Sangruh Marva, Pashan Sus Road, Pune- 411021. Pan : Aabav3603Q Appellant Respondent Assessee By : Shri Pramod S. Shingte Revenue By : Shri Arvind Desai Date Of Hearing : 05.03.2025 Date Of Pronouncement : 29.05.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 25.07.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2020-21. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. On The Facts & In The Circumstances Of The Case & In Law, Lower Authorities Have Erred In Considering The Gross Total Income Of Rs. 6,32,09,055/- As Assessed Income Of The Appellant, Without Appreciating The Fact That Out Of This Rs. 5,35,00,000/- Is Already Offered For Taxation & Taxes Due Thereon Are Fully Paid

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Arvind Desai
Section 139(4)Section 143(2)Section 144Section 80ASection 80PSection 80P(2)(d)

appeal :- “1. On the facts and in the circumstances of the case and in law, lower authorities have erred in considering the gross total income of Rs. 6,32,09,055/- as assessed income of the appellant, without appreciating the fact that out of this

Sri Ananthapadmanabha Credit Co-Operative Society Ltd, Udupi vs. ITO, Ward 1 & Tps, Udupi

ITA 2195/BANG/2024[2018-19]Status: DisposedITAT Bangalore29 May 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Sanket S Nayak, CAFor Respondent: Shri Subramanian S, JCIT (DR)
Section 18Section 80PSection 80P(2)(a)Section 80P(2)(d)

account Right to participate in Yes No No administration Deposit and loan Yes = Yes 4. The assessee for the year under consideration declared gross total income of Rs. 69,77,720/- and the same was claimed as deduction under section

Sri Ananthapadmanabha Credit Co-Operative Society Ltd, Udupi vs. ITO, Ward 1 & Tps, Udupi

ITA 2193/BANG/2024[2016-17]Status: DisposedITAT Bangalore29 May 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Sanket S Nayak, CAFor Respondent: Shri Subramanian S, JCIT (DR)
Section 18Section 80PSection 80P(2)(a)Section 80P(2)(d)

account Right to participate in Yes No No administration Deposit and loan Yes = Yes 4. The assessee for the year under consideration declared gross total income of Rs. 69,77,720/- and the same was claimed as deduction under section

ITO, Ward-6(3)(1), Bangalore vs. Sahakara Nagar Credit Co-Operative Society Limited, Bangalore

ITA 1733/BANG/2024[2017-18]Status: DisposedITAT Bangalore29 May 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Year: 2017-18

For Appellant: Shri Aprameya K, AdvocateFor Respondent: Shri Subramanian S, JCIT (DR)
Section 22Section 40Section 80PSection 80P(2)(a)Section 80P(2)(c)Section 80P(2)(d)

Dividend Right Yes Yes No Right to participate in Yes Yes Yes activity 4. The assessee for the year under consideration declared gross total income of Rs. 1,76,24,174/- which consist of business income of Rs. 1,75,65,121/- and income from house property ... only. The entire gross total income of Rs. 1,76,24,174/- claimed as deduction under section 80P(2)(a)(i) of the Act. 5. In the assessment proceeding, the AO found that the assessee is catering to the different classes of members having different rights with regard to participate

Primary Agriculture Cooperative Credit Society Limited, Adarakatti, Lakshmeshwar Taluk Gadag District vs. Income Tax Officer Ward 1, Gadag

In the result, the appeal of the assessee is dismissed

ITA 279/BANG/2025[2017-18]Status: DisposedITAT Bangalore28 May 2025AY 2017-18

Bench: Shri Waseem Ahmed

For Appellant: Shri Mahesh Hindi, CAFor Respondent: Shri Ganesh R Gale, Standing Counsel for Dept
Section 10ASection 10BSection 139(1)Section 142(1)Section 144Section 80A(5)Section 80PSection 80P(2)(a)

made in computing total income. 80A. (1) In computing the total income of an assessee, there shall be allowed from his gross total income, in accordance with and subject to the provisions of this Chapter, the deductions specified in sections 80C to 83 [80U] ... (5) Where the assessee fails

Kalimuddin Mohamad Rafique, Mumbai vs. DCIT, Cir-4(3)(2), Mumbai

ITA 594/MUM/2024[2011-12]Status: DisposedITAT Mumbai28 May 2025AY 2011-12

Bench: Shri Pawan Singh & Shri Giriish Agrawal

For Appellant: Ms. Priyanshi Desai, AdvocateFor Respondent: Shri. Rajesh Meshram, Sr. DR
Section 143(2)Section 144Section 68

showing loss from house property of Rs. 1,50,000/- and income from business/profession at Rs.2,71,135/-. Thus, the assessee reported gross total income at Rs.2,71,485/- against which claimed a deduction u/ch XIA at Rs.63,147/-. According to the Ld.AO, AIR (ITS) data showed that there

Anil Kumar, Panipat vs. ITO, Ward- 1, Panipat

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

ITA 5566/DEL/2024[2017-18]Status: DisposedITAT Delhi28 May 2025AY 2017-18

Bench: SHRIS.RIFAUR RAHMAN (Accountant Member)

For Appellant: Shri Amit Kaushik, AdvocateFor Respondent: Shri Sanjay Kumar, Sr. DR
Section 142(1)Section 143(2)Section 44ASection 69A

business for which income was already declared u/s 44AD of the Act. The cash deposits can be traced back to the gross total income of the assessee u/s 44AD of the Act. The grounds taken by the assessee are allowed. 10. In the result, the appeal filed by the assessee

L T Foods Ltd., New Delhi vs. Addl.CIT, Special Range-5, New Delhi

In the result, the appeal of the assessee is allowed

ITA 1444/DEL/2019[1999-2000]Status: DisposedITAT Delhi28 May 2025AY 1999-2000

Bench: Shri Ramit Kochar & Shri Sudhir Kumar

For Appellant: Sh. Rohit Jain, AdvocateFor Respondent: Sh. Abhishek Deval, Sr. DR
Section 271(1)Section 271(1)(c)Section 80Section 80GSection 80HSection 80I

deduction u/s 80HHC computed then also the assessee restricted its claim of deduction in under chapter VA to the gross total income of Rs. 1,99,54,739.30 leaving long term capital gain income of Rs. 6,20,054/-to tax. Thus, claiming total deduction under chapter ... included of claim of deduction u/s 80HHC, 80G and 80IA of 13 the Act. It is also not the case of revenue that gross total income as declared by the assessee has been enhanced by the AO and so far as claim of deduction u/s 80IA is concerned is same

Rupesh Laldas Dhakate, Nagpur vs. ITO Ward -1, Bhandara

In the result, appeal of the assessee is allowed

ITA 185/NAG/2025[2017-18]Status: DisposedITAT Nagpur27 May 2025AY 2017-18

Bench: Shri V. Durga Rao

For Appellant: Shri Chandraprakash BhutadaFor Respondent: Shri Surjit Kumar Saha
Section 147Section 156Section 48Section 50CSection 69

assessment year under consideration. However, the assessee has filed an invalid return of income for the A.Y. 2017-18 on 29/07/2021 declaring gross total income from salary of Rs.3,15,890/-, claiming Chapter-VIA deductions of Rs.66,785/- and showing total income at Rs.2,49,110/- As per the information

Lions Nab Community Eyecare Centre, Miraj, Sangli vs. Deputy Commissioner of Income-Tax, CPC, Bangalore

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

ITA 257/PUN/2022[2011-12]Status: DisposedITAT Pune27 May 2025AY 2011-12

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.257/Pun/2022 िनधा"रण वष" / Assessment Year : 2011-12 Lions Nab Community Vs. Dcit, Cpc, Bangalore. Eyecare Centre, Plot No.P-39, Midc, Miraj, Sangli- 416410. Pan : Aabfl4373L Appellant Respondent Assessee By : Shri Pramod S. Shingte Revenue By : Shri Arvind Desai Date Of Hearing : 05.03.2025 Date Of Pronouncement : 27.05.2025 आदेश / Order Per Vinay Bhamore, Jm: This Is Recalled Matter. Vide Order Dated In M.A. No.151/Pun/2023 For The Assessment Year 2011-12 Filed Against The Order Of The Tribunal In Ita No.257/Pun/2022 Dated 06.01.2023 (Appeal Filed By The Assessee) Was Recalled To Adjudicate The Issue De Novo. 2. There Is Delay In Filing Of The Present Appeal. We Are Satisfied With The Reasons Mentioned In The Condonation Application Duly

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Arvind Desai
Section 11Section 11(1)Section 11(1)(i)Section 11(1)(ii)Section 11(2)Section 143(1)

INCOME FROM BUSINESS OR PROFESSION 54,93,373 54,93,373 LOSS OF PREVIOUS YEARS ADJUSTED 2,57,057 2,57,057 GROSS TOTAL INCOME 52,36,316 52,36,316 TOTAL INCOME AFTER DEDUCTIONS 52,36,316 52,36,320 AGGREGATE INCOME

Parsi Salsette Bldg No. 1 Chs Limited, Mumbai vs. Income Tax Officer 24(3)(1), Mumbai

Accordingly, Ground No. II raised by the Assessee is allowed and as a result, Ground No

ITA 1734/MUM/2025[2021-22]Status: DisposedITAT Mumbai27 May 2025AY 2021-22

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Haridas BhatFor Respondent: Shri Akhtar Hussain Ansari
Section 143(1)Section 143(3)Section 80Section 80PSection 80P(2)(d)Section 80P(4)

said section deals with deductions in respect of income of co-operative Societies. Section 80P(1), inter alia, states that where the gross total income of a co-operative Society includes any income from one or more specified activities, then such income shall be deducted from the gross total income ... adjudication of the issue before us. “80P(2)(d) (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

Vineet Prakash Pol, Nashik vs. ACIT Circle-1, Nashik

In the result, appeal of the assessee is partly allowed

ITA 302/PUN/2025[2015-16]Status: DisposedITAT Pune26 May 2025AY 2015-16

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.302/Pun/2025 िनधा"रण वष" / Assessment Year: 2015-16 Vineet Prakash Pol, V The Acit, F-16, Midc, Ambad, S. Circle-1, Nashik. Nashik – 422010. Maharashtra. Pan: Abkpp4357J Appellant/ Assessee Respondent / Revenue Assessee By Shri Sanket Joshi – Ar Revenue By Shri Vinod Pawar – Addl.Cit(Dr) Date Of Hearing 08/05/2025 Date Of Pronouncement 26/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commssioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Act, Dated31.01.2024For The A.Y.2015-16. The Assessee Has Raised The Following Grounds Of Appeal : “1. The Learned Cit(A) Erred In Confirming The Disallowance Of Rs.13,81,195 Out Of The Total Disallowance Of Rs.30,74,834 Made By The A.O In Respect Of Interest Paid To Partnership Firms On Loans Obtained From Them Without Appreciating That The Said Disallowance Was Not Justified On Facts & In Law. 2. The Learned Cit(A) Ought To Have Appreciated That While

Section 250

Income from Other Sources 0 0 0 -After allowing Deduction of Interest paid to Partnership Firms as per decision of CIT(A) Gross Total Income 21,58,259 21,31,500 26,759 6 Deduction under Chapter VI-A (1,65,000) (165,000) 0 7 Total Income ... Gain Rs.26,759/- Income from Other Sources Rs.16,93,639/- Total Rs.40,51,898/- Particulars Amount set-off of loss Rs.19,20,398/- Gross Total Income Rs.21,31,500/-, Chapter VIA deduction Rs.1,65,000/-, Total Rs.19,66,500/-. Losses of Current Year to be 0 carried forward 4.1 Accordingly