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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

Overseas Infrastructure Alliance(India) Private Limited, Mumbai vs. Assistant Commissioner of Income Tax, Central Circle -6, Mumbai

In the result, appeal by the assessee is allowed

ITA 4045/MUM/2025[2020-21]Status: DisposedITAT Mumbai20 Feb 2026AY 2020-21

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR
Section 1

where it expressly provides for what is not allowable. Section 80G falls in chapter VI-A which comes in play only after the gross total income has been computed by applying computation provisions under various heads of income. By considering the detailed submissions made by the assessee and by following

Overseas Infrastructure Alliance (India) Private Limtied, Mumbai vs. Assistant Commissioner of Income Tax Central Circle 6(2), Mumbai

In the result, appeal by the assessee is allowed

ITA 4044/MUM/2025[2021-22]Status: DisposedITAT Mumbai20 Feb 2026AY 2021-22

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR
Section 1

where it expressly provides for what is not allowable. Section 80G falls in chapter VI-A which comes in play only after the gross total income has been computed by applying computation provisions under various heads of income. By considering the detailed submissions made by the assessee and by following

Overseas Infrastructure Alliance (India) Private Limtied, Mumbai vs. Assistant Commissioner of Income Tax Central Circle 6(2), Mumbai

In the result, appeal by the assessee is allowed

ITA 4043/MUM/2025[2019-20]Status: DisposedITAT Mumbai20 Feb 2026AY 2019-20

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR
Section 1

where it expressly provides for what is not allowable. Section 80G falls in chapter VI-A which comes in play only after the gross total income has been computed by applying computation provisions under various heads of income. By considering the detailed submissions made by the assessee and by following

ACIT CC 6(2), Mumbai vs. Overseas Infrastructure Alliance (India) Private Limited, Mumbai

In the result, appeal by the assessee is allowed

ITA 3998/MUM/2025[2017-18]Status: DisposedITAT Mumbai20 Feb 2026AY 2017-18

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR
Section 1

where it expressly provides for what is not allowable. Section 80G falls in chapter VI-A which comes in play only after the gross total income has been computed by applying computation provisions under various heads of income. By considering the detailed submissions made by the assessee and by following

ACIT, CC-6(2), Mumbai vs. Overseas Infrastructure Alliance (India) Private Limited, Mumbai

In the result, appeal by the assessee is allowed

ITA 3995/MUM/2025[2011-12]Status: DisposedITAT Mumbai20 Feb 2026AY 2011-12

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Harsh Kothari and Shri Ronak Vasavada, CAsFor Respondent: Shri R. A. Dhyani, CIT DR and Shri Virabhadra S. Mahajan, Sr. DR
Section 1

where it expressly provides for what is not allowable. Section 80G falls in chapter VI-A which comes in play only after the gross total income has been computed by applying computation provisions under various heads of income. By considering the detailed submissions made by the assessee and by following

Income Tax Officer, Dehradun vs. Rakesh Mohan Verma, Dehradun

In the result, appeal of the Revenue is dismissed

ITA 122/DDN/2024[2017-18]Status: DisposedITAT Dehradun18 Feb 2026AY 2017-18

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2017-18] Ito Vs Rakesh Mohan Verma Ward-1(1)(3) 144, Neshvilla Road, Aaykar Bhawan, Dehradun, Uttarakhand- 13 A, Subhhash Road, 248001 Uttarakhand Pan-Abbpvcv4728J Appellant Respondent Revenue By Shri A.S.Rana, Sr.Dr Assessee By Shri Amit Arora, Ca & Shri Vishal Mishra, Ca Date Of Hearing 09.12.2025 Date Of Pronouncement 18.02.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Revenue Against The Order Dated 15.05.2024 By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld. Cit(A)”] In Appeal No. Cit(A) Dehradun/10729/2019-20 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 27.12.2019 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2017-18. 2. Brief Facts Of The Case Are That Assessee Filed His Return Of Income, Declaring Total Income 10,94,900/-. The Case Of The Assessee Was Selected For Scrutiny Through Cass With The Issue “Large Cash Deposits Compared To Returned Income”. Notice U/S 143(2) Was Issued On 08.08.2018, Followed By Notices U/S 142(1) Issued From Time To Time. In Response, The Assessee Filed Replies & Produced All The Information & Supporting Documentary Evidences For Examination. The Ao Vide Order Dated 27.12.2019 Passed U/S 143(3) Of The Act Assessed The Income Of The Assessee At Inr 1,53,25,642/- Wherein Addition Of Inr 69,81,000/- Is Made As Unexplained Money U/S 69A Of The Act Towards The Bank Deposits & Further Inr 9,60,568/- Added As Unexplained Income Being Difference Between Deposits & Income Declared. Further An Addition Of Inr 62,89,172/- Is Made As One Fourth Payments Against Loan Repayment Of Rs.251,56,689/- Repaid From Undisclosed Sources U/S 69A Of The Act.

Section 142(1)Section 143Section 143(2)Section 143(3)Section 250Section 69A

before us, the Revenue’s only claim is that the reasons of limited scrutiny are “(i) cash deposit and (ii) Aggregate of following: Gross total income, exempt income /agriculture income”. However, as observed above, from the perusal of the assessment order, it is evident that AO has made the additions

Bardc Bank, Bhatkal vs. National E-Assessment Centre, Delhi

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

ITA 297/PAN/2024[2018-19]Status: DisposedITAT Panaji17 Feb 2026AY 2018-19

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos.296 & 297/Pan/2024 (A.Y. 2017-18 & 2018-19) Bardc Bank Bhatkal, Ito-Ward-1, Vs Pld Bank, Main Road, Santerikrupa, . Uttara Kannada, Kaigaroad, Bhatkal S.O. Habbuwada, Karnataka-581320. Karwar-581306, Karnataka. Pan .No. Aaaap1731G (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

Section 80P(2)(a)

adjudication of the issue before us. "80P(2) (d) (1). Where in the case of an assessee being a cooperative 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 ... officer to allow the claim of deduction u/sec 80P(2)(d) of the Act to the extent of interest income included in the gross total income and such 13 ITA. No. 296&297/PAN/2024 BARDC Bank. deduction under this chapter VIA should be restricted to the gross total income

Bardc Bank, Bhatkal vs. Income Tax Officer, Ward - 1, Karwar

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

ITA 296/PAN/2024[2017-18]Status: DisposedITAT Panaji17 Feb 2026AY 2017-18

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos.296 & 297/Pan/2024 (A.Y. 2017-18 & 2018-19) Bardc Bank Bhatkal, Ito-Ward-1, Vs Pld Bank, Main Road, Santerikrupa, . Uttara Kannada, Kaigaroad, Bhatkal S.O. Habbuwada, Karnataka-581320. Karwar-581306, Karnataka. Pan .No. Aaaap1731G (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

Section 80P(2)(a)

adjudication of the issue before us. "80P(2) (d) (1). Where in the case of an assessee being a cooperative 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 ... officer to allow the claim of deduction u/sec 80P(2)(d) of the Act to the extent of interest income included in the gross total income and such 13 ITA. No. 296&297/PAN/2024 BARDC Bank. deduction under this chapter VIA should be restricted to the gross total income

Shree Ganesh Nagari Sahakari Pat Sanstha Maryadit, Sangli vs. Income Tax Officer Ward 5, Sangli

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

ITA 2571/PUN/2025[2020-21]Status: DisposedITAT Pune17 Feb 2026AY 2020-21

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Sarang GudhateFor Respondent: Smt. Shilpa NC Addl.CIT
Section 142(1)Section 143(1)Section 143(2)Section 250Section 80PSection 80P(2)(a)

Assessing Officer noted that the assessee has shown net profit from its activities at Rs.3,75,41,602/- after claiming deductible expenses and gross total income at Rs.5,58,72,706/-. The assessee claimed deduction of Rs.5,58,72,706/- u/s 80P(2)(a)(i) of the Act. On being

Shree Ganesh Nagari Sahakari Pat Sanstha Maryadit, Sangli vs. Income Tax Officer Ward 5, Sangli

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

ITA 2570/PUN/2025[2022-23]Status: DisposedITAT Pune17 Feb 2026AY 2022-23

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Sarang GudhateFor Respondent: Smt. Shilpa NC Addl.CIT
Section 142(1)Section 143(1)Section 143(2)Section 250Section 80PSection 80P(2)(a)

Assessing Officer noted that the assessee has shown net profit from its activities at Rs.3,75,41,602/- after claiming deductible expenses and gross total income at Rs.5,58,72,706/-. The assessee claimed deduction of Rs.5,58,72,706/- u/s 80P(2)(a)(i) of the Act. On being

Shri Hanuman Credit Souharda Sahakari Sangh Ltd, Belagavi vs. Income Tax Officer, Ward - 1, Nippani

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

ITA 235/PAN/2025[2017-18]Status: DisposedITAT Panaji16 Feb 2026AY 2017-18

Bench: SHRI PAVAN KUMAR GADALE (Judicial Member)

Section 80P(2)(a)

adjudication of the issue before us. "80P(2) (d) (1). Where in the case of an assessee being a cooperative 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 ... officer to allow the claim of deduction u/sec 80P(2)(d) of the Act to the extent of interest income included in the gross total income and such deduction under this chapter VIA should be restricted to the gross total income. And we allow the grounds of appeal in favour

Shree Mahila Credit Souhard Sahakari Sangh Niyamit, Belagavi vs. ITO Ward 1 Belagavi, Belagavi

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

ITA 116/PAN/2024[2017-18]Status: DisposedITAT Panaji13 Feb 2026AY 2017-18

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. No.116/Pan/2024 (A.Y. 2017-18) Shree Mahila Credit Souhard Vs Ito-Ward-2, Sahakari Sangh Niyamit, Feroj Khimjibhai Cpx, . Shop.No.3, Maruti Complex, Civil Hospital Road 2 Nd Railway Gate, Tilakwadi, Belagavi-590001. Belgaum-500006, Karnataka. Karnataka. . Pan .No. Aabas9244A (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.Pramod Y Vaidya.Ar Revenue By Smt.Rijula Uniyal.Sr.Dr सुनवाई की तारीख/Date Of Hearing 09.02.2026 घोषणा की तारीख/Date Of Pronouncement 13.02.2026 Order Per Pavan Kumar Gadale, Jm: The Appeal Is Filed By The Assesse Against The Order Of The Nfac/Cit(A) Passed U/Sec 143(3) & U/Sec 250 Of The Act. The Assessee Has Raised The Grounds Of Appeal Challenging The Order Of The Cit(A) Partially Sustaining The Denial Of Claim Of Deduction U/Sec80P(2)(A)(I) Of The Act Made By The Assessing Officer & Without Prejudice Alternate Relief U/Sec80P(2)(D) Of The Act & Sustaining Denial Of Deduction Of Interest On Income Tax Refund Under Section 80P(2)(A)(I) Of The Act.

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

adjudication of the issue before us. "80P(2) (d) (1). Where in the case of an assessee being a cooperative 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 ... officer to allow the claim of deduction u/sec 80P(2)(d) of the Act to the extent of interest income included in the gross total income and such deduction under this chapter VIA should be restricted to the gross total income. And we allow the grounds of appeal in favour

Income Tax Officer Ward-2 Ahmednagar, Ahmednagar vs. Kanifnath Grmain Bigar Sheti Sahakari Patsanstha Maryadit, Maldad

In the result, the appeal of the Revenue is dismissed

ITA 2247/PUN/2025[2022-23]Status: DisposedITAT Pune13 Feb 2026AY 2022-23

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Madhan Thirmanpalli
Section 143(2)Section 143(3)Section 80PSection 80P(2)Section 80P(2)(a)

providing credit facilities to its members. For the Assessment Year 2022-23, it has filed the return of income on 26.10.2022 offering a gross total income of Rs.48,74,240/- and total income of Rs.Nil after claiming deduction of Rs.48,74,240/- under section 80P of the Income

Kishore Sewani, Mumbai vs. ITO Ward 23(2)(6), Mumbai

In the result, the appeal by the assessee is dismissed

ITA 3006/MUM/2025[2017-18]Status: DisposedITAT Mumbai13 Feb 2026AY 2017-18

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailkishore Sewani 1St Floor 19, Krishna Niwas, 2Nd Fanas Wadi Dadi Seth Aigari Lane, Mumbai - 400002. ............... Appellant Pan: Abbps4546F V/S Income Tax Officer, Ward – 23(2)(6), ……………… Respondent Mumbai

For Appellant: NoneFor Respondent: Shri Pravin Salunkhe, Sr. DR
Section 133(6)Section 142(1)Section 143(2)Section 144Section 250Section 69A

current year to the tune of Rs.2,05,053 against the other income of Rs.14,19,813, and thereby arrived at his gross total income of Rs.12,14,760. Since the assessee did not furnish any details to justify this claim of loss of Rs.2,05,053, the same

Shree Keshav Co Op Credit Society Ltd, Junagadh vs. The DCIT/ACIT, Cir 1(1), Rajkot

In the result, both appeals filed by the assessee, are allowed

ITA 794/RJT/2025[2020-21]Status: DisposedITAT Rajkot12 Feb 2026AY 2020-21

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri D. M. Rindani, ARFor Respondent: Shri Dheeraj Kumar Gupta, Sr. DR
Section 143(3)Section 80P(2)Section 80P(2)(a)Section 80P(2)(d)

from Total Income under Chapter VI-A The assessee society has filed Return of Income for AY.2018-19 on 13.08.2018, vide acknowledgment no.108456181130818, reflecting Gross Total Income Rs.43,36,723/- and after claiming deduction u/s 80P(2) of the I.T. Act, 1961 Returned income is declared NIL. The same is processed

Shree Keshav Co Op Credit Society Ltd, Junagadh vs. The DCIT/ACIT, Cir - 1(1), Rajkot

In the result, both appeals filed by the assessee, are allowed

ITA 793/RJT/2025[2018-19]Status: DisposedITAT Rajkot12 Feb 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri D. M. Rindani, ARFor Respondent: Shri Dheeraj Kumar Gupta, Sr. DR
Section 143(3)Section 80P(2)Section 80P(2)(a)Section 80P(2)(d)

from Total Income under Chapter VI-A The assessee society has filed Return of Income for AY.2018-19 on 13.08.2018, vide acknowledgment no.108456181130818, reflecting Gross Total Income Rs.43,36,723/- and after claiming deduction u/s 80P(2) of the I.T. Act, 1961 Returned income is declared NIL. The same is processed

Everest Grande Commercial Premises Co-Op. Society Ltd, Mumbai vs. ITO, 24 (1)(1), Mumbai

In the result, the appeal by the assessee is allowed

ITA 8609/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Feb 2026AY 2022-23

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhaileverest Grande Commercial Premises Co- Op. Society Ltd Cts 46/34, Plot 3A Everest Grande Society, Mahakali Caves Road, Andheri Kurla Road, ............... Appellant Andheri (East), Mumbai- 400093 Pan: Aaaae5455A

For Appellant: Shri N. R AgrawalFor Respondent: Shri Pravin Salunkhe, Sr. DR
Section 142(1)Section 143(2)Section 143(3)Section 144BSection 250Section 3Section 80PSection 80P(2)(d)Section 80P(4)

Society. Thus, if any income as referred to in sub-section 6 (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

Unmesh Ravindranath Fadnis, Thane vs. ITO Ward 3(4), Thane

In the result, grounds raised by the assessee are allowed for statistical purpose

ITA 6589/MUM/2025[2017-18]Status: DisposedITAT Mumbai11 Feb 2026AY 2017-18

Bench: SHRI ANIKESH BANERJEE (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

For Appellant: Shri Sanjeev Bhramhe, CAFor Respondent: Shri Sushil Bhagat, Sr. DR
Section 142(1)Section 144Section 147Section 148Section 148ASection 194ASection 69

also erred in conforming the demand of Rs. 3,11,33,037/-. The CIT (A) has erred in confirming the gross total income as mentioned in the computation sheet attached with the Assessment order as against the actual income of Rs 72,67,952/- as per the Assessment order. 10.The

Aurangabad Division Life Insurance Employees Co-Op Credit Society Ltd, Auranbad vs. ITO, Ward-1(1), Aurangabad

In the result, appeal of the assessee is allowed

ITA 3175/PUN/2025[2020-21]Status: DisposedITAT Pune10 Feb 2026AY 2020-21

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.3175/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Aurangabad Divison Life V The Income Tax Officer, Insurance Employees Co-Op S Ward-1(1), Aurangabad. Credit Society Ltd., 11, Jeevan Prakash, Lic Office Building Adalat Road, Kranti Chowk, Aurangabad -431005 Pan: Aaaaa2245A Appellant/ Assessee Respondent /Revenue Assessee By Ca Payal Rathi (Virtual) Revenue By Shri Sadananda – Jcit Date Of Hearing 09/02/2026 Date Of Pronouncement 10/02/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2020-21 Dated 24.09.2025 Emanating From The Assessment Order Passed Under Section 143(3) Read With Section 144B Of The Income Tax Act, 1961

Section 143(3)Section 144BSection 250Section 56Section 66Section 80PSection 80P(2)(a)

unnecessary to probe any further as to whether the co-operative society is classified as X or Y. 29. Thirdly, the gross total income must include income that is referred to in sub-section (2). 30. Fourthly, sub-clause (2)(a)(i) with which we are directly concerned, then speaks

Uday Uttamrao Nevase, Pune vs. The Assessing Officer / Assessment Unit, Pune

In the result, appeal of the assessee in ITA No

ITA 2606/PUN/2025[2022-23]Status: DisposedITAT Pune10 Feb 2026AY 2022-23

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2606/Pun/2025 निर्धारण वषा / Assessment Year: 2022-23 Uday Uttamrao Nevase, V The Assessing Officer / Saugandh Niwas, Hind Colony S Assessment Unit, Pune. Lane No.1 A, Bhekrai Nagar, Phursungi, Pune – 412308. Pan: Akqpn1150Q Appellant/ Assessee Respondent /Revenue Assessee By Ca Rohan Gupta Revenue By Shri Harshit Bari – Addl.Cit(Virtual) Date Of Hearing 16/12/2025 Date Of Pronouncement 10/02/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2022-23 Dated 04.09.2025 Emanating From The Penalty Order Passed Under Section 270A, Dated 17.09.2024. The Assessee Has Raised The Following Grounds Of Appeal : “Ground 1 Section 270Aa Immunity Cit A Erred In Law By Confirming The Penalty Of Rs 629382 Under Section 270A Without Considering And

Section 143(3)Section 250Section 270A

reproduced here as under: “FACTS OF THE CASE (As already placed on record) 1. The Assessee is a salaried individual with disclosed Gross Total income (GTI) of 18,96,108 for AY 2022-2023 2. During filing of the original return, the tax practitioner of assessee inadvertently claimed certain deductions ... processed u/sec. 143(1) of the Act and refund was issued to the assessee. Later, it was revealed that assessee has suppressed the gross total income itself to the extent of Rs.3,20,000/-. This was in spite of Form 16 issued by the employer showing higher and correct salary