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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

Shree Siddheshwar Co-Op Credit Society Limited, Belagavi vs. Assessing Officer, National E-Assessment Centre, Delhi

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

ITA 302/PAN/2024[2017-18]Status: DisposedITAT Panaji07 Mar 2025AY 2017-18

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos. 302/Pan/2024 (A.Y. 2017-18 ) Shree Siddheshwar Co-Op Vs Ito-Ward-6, Civil Hospital Road, Credit Society Limited, . Belagavi-590001. P B Road, Kakati, Karnataka. Belgaum-591113, Karnataka. . Pan .No. Aaifs6553Q (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee By Shri.Santosh Kumar Dlatthe.Ar Revenue By Shri.Manikandan.S.Sr.Dr सुनवाई क" तार"ख/Date Of Hearing 06.03.2025 घोषणा क" तार"ख/Date Of Pronouncement 07.03.2025 Order Per Pavan Kumar Gadale, Jm: The Appeal Is Filed By The Assesse Against The Order Of Nfac/Cit(A) Passed U/Sec 143(3) & U/Sec 250 Of The Act. 2. At The Time Of Hearing, The Ld.Ar Of The Assessee Submitted That There Is A Delay In Filing The Appeal Before The Hon’Ble Tribunal & The Assesse Has Filed The Affidavit For Condonation Of Delay. Whereas, The Facts Mentioned In The Affidavit Are Reasonable & The Ld. Dr Has No Specific Objections. Accordingly, We Condone The Delay & 2 Ita. No..302/Pan/2024 Shri Siddeswar Co-Op Society Limited.. Admit The Appeal. The Assessee Has Raised The Grounds Of Appeal Challenging The Order Of The Cit(A) Sustaining The Denial Of Claim Of Deduction Under Section 80P(2)(D) Of The Act.

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

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 ... 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

The New India Multi Purpose Co-Op Society Limited, Mapusa vs. Income Tax Officer, Ward - 1(4), Panaji

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

ITA 244/PAN/2024[2017-18]Status: DisposedITAT Panaji04 Mar 2025AY 2017-18

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos. 244/Pan/2024 (A.Y. 2016-17 ) The New India Multi Vs Ito-Ward-1(4), Aayakar Bhavan, Purpose Co-Op Society Ltd, . Plot.No 5, Edc C/2,Ug Floor, Saidanha Complex,Patto Plaza, Business Towers,Near Panaji.-403001, Court Circle, Bardez Goa. Mapusa-403607 . Goa. Pan .No. Aadat8151H (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee By Shri. Amogh Arlekar.Ar Revenue By Shri.Manikandan.S.Sr.Dr सुनवाई क" तार"ख/Date Of Hearing 03.03.2025 घोषणा क" तार"ख/Date Of Pronouncement 04.03.2025 Order Per Pavan Kumar Gadale, Jm: The Appeal Is Filed By The Assesse Against The Order Of Addl/ Jcit(A) Kolkata 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) Sustaining The Denial Of Claim Of Deduction Under Section 80P(2)(D) Of The Act. 2. The Brief Facts Of The Case Are That, The Assessee Is A Cooperative Society Registered Under The Maharashtra Co-

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

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 ... 244/PAN/2024 The New India Multi Purpose Co-Op Society Limited.. 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

Nashik District Primary Teachers Co-Op Credit Society Ltd, Nashik vs. ITO Ward 1(1), Nashik

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

ITA 2071/PUN/2024[2021-22]Status: DisposedITAT Pune28 Feb 2025AY 2021-22

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.2070 & 2071/Pun/2024 निर्धारण वर्ष / Assessment Years : 2018-19 & 2021-22 Nashik District Primary Teachers Co-Op Credit Society Ltd., Saraswati Complex, Malviya Chowk, Panchavatikaranja, Nashik-422002 Vs. Ito, Ward – 1(1), Nashik Pan: Aaaan2859D अपीलार्थी /Appellant प्रत्यर्थी / Respondent Assessee By : Shrisanket Joshi Department By : Shriramnath P. Murkunde Date Of Hearing : 31-12-2024 Date Of Pronouncement : 28-02-2025 आदेश / Order Per Astha Chandra, Jm : These Two Appeals Filed By The Assessee Is Directed Against The Two Separate Orders Both Dated 22.08.2024 Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi [“Cit(A)”] Pertaining To Assessment Year (“Ays”) 2018- 19 & 2021-22. Since The Issues Involved Are Identical The Same Were Heard Together & Are Disposed Of By This Common Order.

For Appellant: ShriSanket JoshiFor Respondent: ShriRamnath P. Murkunde
Section 143(1)Section 144Section 80PSection 80P(2)(a)

Where in the case of an assessee being a co-operative 10 ITA Nos.2070 & 2071/PUN/2024, AYS 2018-19 & 2021-221 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