“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

Assistant Commissioner of Income-Tax, Jaipur vs. Nash Fashion(India) Limited, Jaipur

In the result, the appeal of the assessee is allowed in ITA no

ITA 89/JPR/2024[2013-14]Status: DisposedITAT Jaipur28 Apr 2025AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Dheeraj Borad, C.AFor Respondent: Shri Anup Singh Addl. CIT a

Section 1Section 143(3)Section 40Section 80G

ACIT vs. Nash Fashion (India) Ltd. donation made to both the donee institutions are eligible for claim of 100% deduction out of Gross Total Income. Accordingly, the claim of deduction of Rs. 1,27,67,676/- u/s 80G was disallowed and added to the total income of the assessee. Assessment ... evidence to the effect that the donation made to both the donee institutions are eligible for claim of 100% deduction out of Gross Total Income.  The Assessing Officer has also noted that in this case the Gross Total Income of the assessee as per return of income

Nash Fashion (India) Limited, Jaipur vs. DCIT Circle 1, Jaipur

In the result, the appeal of the assessee is allowed in ITA no

ITA 160/JPR/2024[2013-14]Status: DisposedITAT Jaipur28 Apr 2025AY 2013-14

For Appellant: Shri Dheeraj Borad, C.AFor Respondent: Shri Anup Singh Addl. CIT

Section 143(3)Section 40Section 80G

evidence to the effect that the 4. donation made to both the donee institutions are eligible for claim of 100% deduction out of Gross Total Income. Accordingly, the claim of deduction of Rs.1,27,67,676/- u/s 80G was disallowed and added to the total income of the assessee. Assessment ... evidence to the effect that the donation made to both the donee institutions are eligible for claim of 100% deduction out of Gross Total Income. The Assessing Officer has also noted that in this case the Gross Total Income of the assessee as per return of income is Rs.2

Nash Fashion (India) Limited, Jaipur vs. DCIT Circle -2, Jaipur

In the result, the appeal of the assessee is allowed in ITA no

ITA 159/JPR/2024[2013-14]Status: DisposedITAT Jaipur28 Apr 2025AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Dheeraj Borad, C.AFor Respondent: Shri Anup Singh Addl. CIT a

Section 1Section 143(3)Section 40Section 80G

Sushiladevi Vijaykumar Yadav, Mumbai vs. ITO Ward 42 (1)(5), Mumbai

In the result appeal file by the assessee stands partly allowed

ITA 950/MUM/2025[2017-18]Status: DisposedITAT Mumbai28 Apr 2025AY 2017-18

Bench: Shri Narender Kumar Choudhryassessment Year: 2017-18

For Appellant: Shri Ajay R. Singh a/wFor Respondent: Shri Srinivas P., Ld. Sr. D.R

Section 142(1)Section 250

getting appropriate guidance from other Counsel, the Assessee immediately filed her return of income for the A.Y. under consideration on 25.11.2019 declaring gross total income of Rs.5,77,166/- {being Rs. 26,766 as commission income + 4 Mrs. Sushiladevi Vijaykumar Yadav 5,50,400/- being profit

Vimal Coal Pvt.Ltd., Ahmedabad vs. The Dy.CIT., Circle-4(1)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1446/AHD/2024[2020-21]Status: DisposedITAT Ahmedabad25 Apr 2025AY 2020-21

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं/Ita No.1446/Ahd/2024 निर्धारण वर्ष / Assessment Year : 2020-21 Vimal Coal Pvt.Ltd. The Dy.Cit 503, Addpr Aspire बनाम / Circle-4(1)(1) Near Jahanvee Restaurant V/S. Ahmedabad University Road To Panjrapole Road (अपीलार्थी/ Appellant) Ahmedabad - 380 009 (प्रत्यर्थी/ Respondent) स्थायी लेखा सं./Pan: Aabcv 4259 J Assessee By: Ms. Priyanka Sajnani, Ar On Behalf Of Shri Sunil Maloo, Ar Revenue By : Shri Atul Pandey, Sr.Dr सुनवाई की तारीख /Date Of Hearing 23/04/2025 घोषणा की तारीख / Date Of Pronouncement: 25/04/2025 आदेश/Order Per Makarand V. Mahadeokar, Am: This Appeal By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “Cit(A)"] Dated 10.06.2024 For The

For Appellant: Ms. Priyanka Sajnani, ARFor Respondent: Shri Atul Pandey, Sr.DR

Section 135Section 37(1)Section 80GSection 80G(2)(iiihk)Section 80G(5)

under section 80G is made post disallowance of CSR expense under section 37(1), Section 80G of the Act is a deduction from gross total income and not a business deduction, the donees are not covered by exclusionary clauses 80G(2)(iiihk) or (iiihl) and there is no express ... head “profits and gains of business or profession”. However, there is no corresponding bar introduced in Chapter VI-A, which governs deductions from gross total income, including under section 80G. The Explanatory Memorandum to the Finance Bill, 2014, clarifies that the objective was to prevent companies from reducing taxable business

Sree Seetharama Mandiram, Bengaluru vs. Income Tax Officer, Ward-5(2)(1), Bangalore

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

ITA 318/BANG/2025[2020-21]Status: DisposedITAT Bangalore25 Apr 2025AY 2020-21

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyassessment Year :2020-21

For Appellant: Shri. Zain Khan, CAFor Respondent: Shri. Subramanian S,JCIT(DR)(ITAT), Bangalore

Section 154Section 5Section 56Section 57Section 80PSection 80P(2)(a)

grounds were not pressed. 4. Briefly stated, the facts of the case are that the assessee filed return of income on 22.12.2020 declaring gross total income of Rs.1,01,46,503/- and claimed deduction under Chapter VI A of Rs.97,90,443/- under section

Yudhishtir Cooperative Housing Society Ltd, Mumbai vs. ITO Ward 42(1)(4), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 1784/MUM/2025[2017-18]Status: DisposedITAT Mumbai25 Apr 2025AY 2017-18

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjeeyudhishtir Co-Operative Vs Jao, Ward Mum-W-42(1)(4), Housing Society Ltd, Kautilya Bhavan, Bandra East, Anand Nagar, N.L. Complex, Mumbai-400 051 Dahisar (East), Mumbai-400 068 Pan: Aaaay4170G Appellant Respondent

For Appellant: ShriVidyadhar KhandekarFor Respondent: Shri Asif Kamali (SR. DR.)

Section 139(1)Section 143Section 143(3)Section 250Section 80PSection 80P(2)(d)Section 80P(4)

brief facts of the case is that the assessee is a co-operative housing society and filed the return by declaring gross total income NIL after claiming deduction amount to Rs.15,22,825/- under Chapter VIA related to section 80P(2)(d) of the Act. The details of interest earned

Mrs. Hodike Hosahalli Venkate Gowda Sowmya, Maddur vs. Income Tax Officer, Ward-1 & Tps, Mandya

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

ITA 2584/BANG/2024[2012-13]Status: DisposedITAT Bangalore24 Apr 2025AY 2012-13

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2012-13

For Appellant: Ms. Sunaiana Bhatia, A.RFor Respondent: Sri Ganesh R Ghale, Standing counsel for revenue

Section 144Section 147Section 148Section 250

within the time limit as allowed under the Act. However she had filed her return of income belatedly on 26/03/2015 declaring Gross Total Income of Rs.3,42,620/- and claimed deduction under chapter VIA amounting to Rs. 7,258/- & thus declared Net Taxable Income of Rs.3

Deputy Commissioner of Income Tax-4(3)(1), Mumbai vs. Kismet Exports and Investments Pvt Ltd., Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 5520/MUM/2024[2012-13]Status: DisposedITAT Mumbai24 Apr 2025AY 2012-13

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2012-13 Deputy Commissioner Of Income Kismet Exports & Tax-4(3)(1) Investments Pvt Ltd. 649 Aayakar Bhavan M K Road Vs. C-1/5, Sarathi Chs, Khira Mumbai-400020 Nagar, S.V.Road, Santacruz (West), Mumbai-400054 Pan No. Aacck 2895 C Appellant Respondent

For Appellant: Mr. Bupendra ShahFor Respondent: Mr. Hemanshu Joshi, Sr. DR

Section 115JSection 154Section 234B

order of ITAT, the AO has merely adopted the income as appearing in the assessment order passed on 19.03.2015 wherein the gross total income and total book profit were shown at Rs. 9,16,97,564/- and Rs. 8,24,66,366/-, however the AO did not consider the issues

Roto World Fze, Ahmedabad vs. The DCIT, CPC, Banglore

The appeal of the assessee is allowed for statistical purposes

ITA 491/AHD/2020[2018-19]Status: DisposedITAT Ahmedabad23 Apr 2025AY 2018-19

Bench: DR. BRR KUMAR (Vice President), SHRI T.R SENTHIL KUMAR (Judicial Member)

Section 115BSection 143(1)Section 154

Establishment (PE) in India. The return of income was processed u/s.143(1) and intimation dated 10.06.2019 has issued by the DCIT, CPC wherein gross total income was considered at Rs.32,57,500/- instead of Rs. 16,28,750/- and tax thereon raised a demand of Rs.8,30,712/. An online

Mr.Jayaram Subramanaiam, Chennai vs. DCIT, Central Circle-2(1), Chennai

In the result, the appeal of the assessee is dismissed

ITA 26/CHNY/2025[2018-19]Status: DisposedITAT Chennai23 Apr 2025AY 2018-19

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.26/Chny/2025 Assessment Years: 2018-19 Mr.Jayaram Subramaniam, The Deputy Commissioner Of No.9A Nn Laxmi Street, Income Tax, Valasaravakkam, Central Circle-2(1), Aswathy, Chennai Chennai- 600 087. [Pan: Afaps5678H] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Ms.Lavanya, Ca प्रत्यर्थी की ओर से /Revenue By : Smt.Samantha Mullamudi, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 24.03.2025 घोषणा की तारीख /Date Of Pronouncement : 23.04.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Ms.Lavanya, CAFor Respondent: Smt.Samantha Mullamudi, Addl.CIT

Section 143(1)Section 143(3)

that an order u/s 143(1) dated 25.10.2019 was passed determining tax liability at Rs.4,61,990/-. This had arisen on account of gross total income determined at Rs.1,57,89,054/- u/s 143(1) as against income returned of Rs.1,47,53,002/-. Subsequently, the case of the assessee

Aman Rajendrakumar Jain, Mumbai vs. Income Tax Officer, Mumbai

In the result, the ground of appeal raised by the assessee is partly allowed

ITA 1326/MUM/2025[2017-18]Status: DisposedITAT Mumbai23 Apr 2025AY 2017-18

Bench: SHRI PAWAN SINGH (Judicial Member)

Section 254(1)Section 69A

overlooking the fact that the initial cash withdrawal was appropriately reported in the income tax return of respective AYs. • The appellant disclosed a gross total income of Rs. 6.08,105/- and claimed a deduction of Rs. 1.72.135/-under Chapter VI-A, resulting in a Net taxable income

Shree Yadvesh Transport Co . Pvt Ltd, Mumbai vs. ITO, Ward 13(2)(1), Mumbai

In the result the appeal filed by the assessee stands allowed

ITA 6877/MUM/2024[2016-17]Status: DisposedITAT Mumbai22 Apr 2025AY 2016-17

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

Section 115JSection 142(1)Section 143(2)Section 271(1)(c)Section 32

proceedings u/s 271(1)(c) are initiated separately for furnishing inaccurate particulars of income.” 2.2 The assessment order was completed by determining the gross total income of Rs.8,02,195/- in the hands of the assessee. Against the assessment order the assessee did not file any appeal before

Anugraha Education Trust, Sullia vs. Commissioner of Income Tax(Exemptions), Bangalore

ITA 23/BANG/2025[2024-25]Status: DisposedITAT Bangalore21 Apr 2025AY 2024-25

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Ms. Sunaiana Bhatia, A.RFor Respondent: Smt. Srinandini Das, D.R

Section 12ASection 80GSection 80G(2)

Exemptions) has decided the issue from the perspective of the donor who claims the deduction u/s 80G of the Act (Chapter VIA) from Gross Total Income after paying donation and not from the perspective of the institution/Trust being the donee who is seeking approval U/s 80G of the Act. Further

Beejady Fishermen Co-Op. Society Limited, Udupi vs. Income Tax Officer, Ward-1., Udupi

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

ITA 2197/BANG/2024[2020-21]Status: DisposedITAT Bangalore21 Apr 2025AY 2020-21

Bench: Shri Waseem Ahmed

For Appellant: Shri Mahesh R Uppin, AdvocateFor Respondent: Shri Ganesh R Gale, Standing Counsel for Dept

Section 143(2)Section 57Section 80PSection 80P(2)(a)Section 80P(2)(c)Section 80P(2)(d)

Bank Rs. 11,672/- Total Rs. 47,870/- 11.2 The provision of section 80P(2)(a)(i) of the Act provides that the gross total income of a cooperative society includes any income referred under subsection (2) of section 80P of the Act, such sum shall be allowed as deduction

Beejady Fishermen Co-Operative Society Limited, Kundapura vs. Income Tax Officer, Ward-1 & Tps, Udupi

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

ITA 2196/BANG/2024[2018-19]Status: DisposedITAT Bangalore21 Apr 2025AY 2018-19

Bench: Shri Waseem Ahmed

For Appellant: Shri Mahesh R Uppin, AdvocateFor Respondent: Shri Ganesh R Gale, Standing Counsel for Dept

Section 143(2)Section 57Section 80PSection 80P(2)(a)Section 80P(2)(c)Section 80P(2)(d)

S D M College Co-Operative Stores Limited, Mangalore vs. Income Tax Officer, Ward-1, Puttur

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

ITA 1438/BANG/2024[2020-21]Status: DisposedITAT Bangalore21 Apr 2025AY 2020-21

Bench: Shri Waseem Ahmedassessment Year: 2020-21

For Appellant: Shri Mahesh R Uppin, AdvocateFor Respondent: Shri Ganesh R Gale, Standing Counsel for Dept

Section 143(1)Section 154Section 57Section 80PSection 80P(2)(a)Section 80P(2)(c)Section 80P(2)(d)Section 80P(2)(i)

members of the assessee society in accordance with its bye-laws. The assessee for the year under consideration declared gross total income of Rs. 7,50,150/- out which an amount of Rs. 3,49,500/- was claimed as deduction under section 80P(2)(d) of the Act and further

M/S Godfrey Phillips India Ltd, Mumbai vs. The Assessing Officer, National Faceless Assessment Centre, Delhi/ Circle1(3)(1), Mumbai

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

ITA 1218/MUM/2024[2015-16]Status: DisposedITAT Mumbai15 Apr 2025AY 2015-16

Bench: Ms. Padmavathy S. & Shri. Raj Kumar Chauhan

Section 135Section 143(1)Section 143(2)Section 143(3)Section 147(1)Section 148Section 151Section 250Section 80G

sums 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

Deepali Manish Shrivastava, Pune vs. Income Tax Officer Ward 6(1) Pune, Pune

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

ITA 2547/PUN/2024[2018-19]Status: DisposedITAT Pune09 Apr 2025AY 2018-19

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Umesh Kumar M. MaliFor Respondent: Ms. Shilpa N. C

Section 133(6)Section 142(1)Section 143(2)Section 144Section 68

that it is the proprietorship concern of Shri Manish Nandlal Shrivastava. However, perusal of the ITR filed by Shri Manish reveals that his Gross Total Income is Rs 9,13,742/- and that he is an Employee of M/s Tirumala Facility earning salary income of Rs 3,30,500/- apart

Shree Parshwanath Nagari Sahakari Pat Sanstha Ltd, Vita vs. Income Tax Officer Ward 2, Sangli

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

ITA 1574/PUN/2024[2020-21]Status: DisposedITAT Pune08 Apr 2025AY 2020-21

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Amit Shintre (Virtual)

Section 143(2)Section 143(3)Section 57Section 80Section 80PSection 80P(2)(a)Section 80P(2)(c)Section 80P(2)(d)

income from Co-Operative Banks was 2 Rs.1,74,31,818, but the claim under section 80P(2)(d) was restricted to the gross total income of Rs. 1,19,74,102 while filing the return of income. 2) Without prejudice to Ground No. 1, on facts and circumstances ... income received from cooperative banks was in-fact Rs.1,74,31,118/- but the claim u/s 80P(2)(d) was restricted to the gross total income of Rs.1,19,74,102/-. Apart from above without prejudice to the ground no.1, it was also submitted before the Bench that the assessee