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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

Ascendas Panvel Ftwz Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, Ward 14(1)(1), Mumbai

In the result, the appeals filed by the assessee are allowed in the above terms

ITA 712/MUM/2025[2021-22]Status: DisposedITAT Mumbai10 Feb 2026AY 2021-22

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

Section 3(12)Section 80

this point for the sake of ready reference, the relevant provision of Section 80-IAB is reproduced hereunder:- “80-IAB(1) Where the gross total income of an assessee, being a Developer, includes any profits and gains derived by an undertaking or an enterprise from any business of developing

Ascendas Panvel Ftwz Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, Ward 14(1)(1), Mumbai

ITA 711/MUM/2025[2020-21]Status: DisposedITAT Mumbai10 Feb 2026AY 2020-21
Section 3(12)Section 80

this point for the sake of ready reference, the relevant provision of Section 80-IAB is reproduced hereunder:- “80-IAB(1) Where the gross total income of an assessee, being a Developer, includes any profits and gains derived by an undertaking or an enterprise from any business of developing

Ascendas Panvel Ftwz Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, Ward 14(1)(1), Mumbai

ITA 701/MUM/2025[2018-19]Status: DisposedITAT Mumbai10 Feb 2026AY 2018-19
Section 3(12)Section 80

this point for the sake of ready reference, the relevant provision of Section 80-IAB is reproduced hereunder:- “80-IAB(1) Where the gross total income of an assessee, being a Developer, includes any profits and gains derived by an undertaking or an enterprise from any business of developing

Income Tax Officer, Chennai vs. Railway Employees Cooperative Credit Society, Chennai

In the result, the both the appeals filed by the Revenue are dismissed

ITA 2096/CHNY/2025[2018]Status: DisposedITAT Chennai09 Feb 2026

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Ms. R. Anitha, Addl. CITFor Respondent: Shri. Vignesh Kumarasamy, Advocate
Section 143(3)Section 80P(2)Section 80P(2)(a)

Deduction in respect of income of co- operative societies:— (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 ... business of banking or providing credit facilities to its members by a co-operative society and is liable to be deducted from the gross total income under Section 80P of the Act. 11. In this context when we look at the judgment of the Apex Court in Totgars Co-operative

Income Tax Officer, Chennai vs. Railway Employees Cooperative Credit Society Limited, Chennai

In the result, the both the appeals filed by the Revenue are dismissed

ITA 2095/CHNY/2025[2017-18]Status: DisposedITAT Chennai09 Feb 2026AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Ms. R. Anitha, Addl. CITFor Respondent: Shri. Vignesh Kumarasamy, Advocate
Section 143(3)Section 80P(2)Section 80P(2)(a)

Deduction in respect of income of co- operative societies:— (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 ... business of banking or providing credit facilities to its members by a co-operative society and is liable to be deducted from the gross total income under Section 80P of the Act. 11. In this context when we look at the judgment of the Apex Court in Totgars Co-operative

Hiriadka Souharda Sahakari (Ni), Udupi vs. ITO-Ward 1&Tps, Aadi Udupi

In the result, Appeal filed by the Assessee is allowed

ITA 1966/BANG/2025[2017-18]Status: DisposedITAT Bangalore09 Feb 2026AY 2017-18

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year :2017-18 M/S. Hiriadka Souhadra Sahakari (Ni), Post Office Main Road, The Income Tax Officer, Hiriadka, Udupi, Ward-1& Tps, Vs. Karnataka – 576 113. Udupi. Pan: Aabah2220H Appellant Respondent

For Appellant: Shri Ravindra Poojary, Advocate
Section 143(2)Section 143(3)Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

operative society carrying on the banking facility to its members. It filed its return of income on 31.10.2017 wherein the gross total income of the Assessee is Rs. 13,69,573/- and the same was claimed as deduction u/s. 80P(2)(a)(i) resulting into the return of income

Primary Cooperative Agriculture Rural Development Bank Limited, Chikmagalur vs. Income Tax Officer, Ward-2, Chikmagalur

In the result, the Appeal of the Assessee is allowed

ITA 1843/BANG/2025[2017-18]Status: DisposedITAT Bangalore09 Feb 2026AY 2017-18

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2017-18 M/S. Primary Cooperative Agriculture Rural Development Bank Limited, The Income Tax Officer, D. No. 22, Sharadha Nagar, Ward-2, Vs. Sringeri, Chikmagalur District, Chikmagalur. Karnataka – 577 139. Pan: Aacap9326R Appellant Respondent

For Appellant: Shri Prasanna Shenoy, CA
Section 143(3)Section 4Section 5BSection 80PSection 80P(2)(a)Section 80P(2)(c)Section 80P(4)Section 80P(4)(b)

brief facts of the case shows that the Assessee filed its return of income on 28.10.2017 wherein the gross total income of Rs. 39,92,145/- and total income of Rs. Nil/- were shown claiming deduction of Rs. 39,92,145/- u/s. 80P of the Act. The return of income

Aditya Birla Sun Life Amc Limited, Maharashtra vs. The Deputy Commissioner of Income Tax- Circle 6(1)(1), Maharashtra

ITA 6703/MUM/2025[2023-24]Status: DisposedITAT Mumbai06 Feb 2026AY 2023-24

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar1. Ita No. 6663/Mum/2025 (Assessment Year: 2017-18) 2. Ita No. 6701/Mum/2025 (Assessment Year: 2018-19) 3. Ita No. 6702/Mum/2025 (Assessment Year: 2022-23) & 4. Ita No. 6703/Mum/2025 (Assessment Year: 2023-24) Aditya Birla Sun Life Dcitcircle-6(1)(1), Amc Limited, Room No. 502, 5Th 17Th Floor, One World Vs. Floor, Aayakar Centre Tower-1, Jupiter Bhavan, M. K. Mill Compount, 841, Road, Churchgate, Senapati Bapat Marg, Mumbai-400 020 Delisle Road, S.O. Mumbai-400 013 Pan/Gir No. Aaacb6134D (Applicant) (Respondent) Assessee By Shri Ronak Doshi, Shri Shrey Agrawal & Shri Aadish Jain, Ld. Ars Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 27.01.2026 Date Of Pronouncement 06.02.2026

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 144BSection 250Section 270ASection 36(1)(va)Section 40Section 43B

amounting to Rs. 9,076/- while computing the total income of the Appellant. GROUND NO. V: INCORRECT COMPUTATION OF GROSS TOTAL INCOME CHARGEABLE TO TAX 1. On the facts and circumstances of case and in law, the AO erred in computing incorrect amount of gross total income chargeable ... instead of Rs. 4,20,47,33,978/-. 2. The Appellant prays that the AO be directed to correctly compute the gross total income chargeable to tax at Rs. 4,20,47,33,978/-. GROUND NO. VI: SHORT GRANT OF TAX DEDUCTED AT SOURCE (“TDS”) CREDIT AMOUNTING

Aditya Birla Sun Life Amc Limited, Maharashtra vs. The Deputy Commissioner of Income Tax-Circle 6(1)(1), Maharashtra

ITA 6702/MUM/2025[2022-23]Status: DisposedITAT Mumbai06 Feb 2026AY 2022-23
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 144BSection 250Section 270ASection 36(1)(va)Section 40Section 43B

amounting to Rs. 9,076/- while computing the total income of the Appellant. GROUND NO. V: INCORRECT COMPUTATION OF GROSS TOTAL INCOME CHARGEABLE TO TAX 1. On the facts and circumstances of case and in law, the AO erred in computing incorrect amount of gross total income chargeable ... instead of Rs. 4,20,47,33,978/-. 2. The Appellant prays that the AO be directed to correctly compute the gross total income chargeable to tax at Rs. 4,20,47,33,978/-. GROUND NO. VI: SHORT GRANT OF TAX DEDUCTED AT SOURCE (“TDS”) CREDIT AMOUNTING

Aditya Birla Sun Life Amc Limited, Maharashtra vs. The Deputy Commissioner of Income Tax- Circle 6 (1)(1), Maharashtra

Accordingly, this ground is allowed

ITA 6701/MUM/2025[2018-19]Status: DisposedITAT Mumbai06 Feb 2026AY 2018-19
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 144BSection 250Section 270ASection 36(1)(va)Section 40Section 43B

amounting to Rs. 9,076/- while computing the total income of the Appellant. GROUND NO. V: INCORRECT COMPUTATION OF GROSS TOTAL INCOME CHARGEABLE ΤΟ ТАХ 1. On the facts and circumstances of case and in law, the AO erred in computing incorrect amount of gross total income chargeable ... instead of Rs. 4,20,47,33,978/-. 2. The Appellant prays that the AO be directed to correctly compute the gross total income chargeable to tax at Rs. 4,20,47,33,978/-. GROUND NO. VI: SHORT GRANT OF TAX DEDUCTED AT SOURCE (“TDS”) CREDIT AMOUNTING

Aditya Birla Sun Life Amc Limited, Maharashtra vs. The Deputy Commissioner of Income Tax Circle 6(1)(1), Maharashtra

Accordingly, this ground is allowed

ITA 6663/MUM/2025[2017-18]Status: DisposedITAT Mumbai06 Feb 2026AY 2017-18
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 144BSection 250Section 270ASection 36(1)(va)Section 40Section 43B

amounting to Rs. 9,076/- while computing the total income of the Appellant. GROUND NO. V: INCORRECT COMPUTATION OF GROSS TOTAL INCOME CHARGEABLE TO TAX 1. On the facts and circumstances of case and in law, the AO erred in computing incorrect amount of gross total income chargeable ... instead of Rs. 4,20,47,33,978/-. 2. The Appellant prays that the AO be directed to correctly compute the gross total income chargeable to tax at Rs. 4,20,47,33,978/-. GROUND NO. VI: SHORT GRANT OF TAX DEDUCTED AT SOURCE (“TDS”) CREDIT AMOUNTING

Meghna Banga, Delhi vs. DCIT Central Circle-7, Delhi

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

ITA 3936/DEL/2025[2017-2018]Status: DisposedITAT Delhi06 Feb 2026AY 2017-2018

Bench: Shri Mahavir Singh & Shri Krinwant Sahay[Assessment Year: 2017-18]

Section 132Section 142Section 153Section 153CSection 153DSection 250Section 292CSection 65Section 69A

Banga's ITRs and copies of their joint Bank accounts for the relevant period, i.e. AY-2011-12 to AY-2017-18. AY Gross Total Income

Sewa Sahakari Samiti Latabod, Latabod vs. Income Tax Officer, Risali

In the result, appeal of the assessee is allowed

ITA 5/RPR/2026[2016-17]Status: DisposedITAT Raipur05 Feb 2026AY 2016-17

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.5/Rpr/2026 "नधा"रण वष" /Assessment Year : 2016-17 Sewa Sahakari Samiti Latabod K-6, Anupam Nagar, Raipur (C.G.) Pan: Aahas1552M

For Appellant: Shri Vinit Kumar Jain, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 80Section 80PSection 80P(2)(a)

business of banking or providing credit facilities to its members by a co-operative society and is liable to be deducted from the gross total income under Section 80P of the Act. 9. In this context when we look at the judgment of the Apex Court in the case

Honnali Urban Credit Co-Operative Society Limited, Honnali vs. Principal Commissioner of Income Tax-1, Bangalore

In the result appeal filed by the assessee is allowed

ITA 819/BANG/2025[2020-21]Status: DisposedITAT Bangalore03 Feb 2026AY 2020-21

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2020-21

For Appellant: Shri Siddesh N. Gaddi, CAFor Respondent: Shri Shivanand Kalkeri, CIT(DR)(ITAT), Bengaluru
Section 142Section 143(3)Section 263Section 56Section 80Section 80PSection 80P(2)(a)Section 80P(2)(d)

respect of income of co-operative societies: 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 Page 9 of 16 subject to the provisions ... business of banking or providing credit facilities to its members by a co-operative society and is liable to be deducted from the gross total income under Section 80P of the Act. 9. In this context when we look at the judgment of the Apex Court in the case

Primary Agricultural Credit Co-Operative Society, Kodagu vs. Pr. Commissioner of Income Tax, Bengaluru -3, Bengaluru

In the result appeal filed by the assessee is allowed

ITA 1073/BANG/2025[2020-21]Status: DisposedITAT Bangalore03 Feb 2026AY 2020-21

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2020-21

For Appellant: Shri Narendra Sharma, AdvocateFor Respondent: Shri Muthu Shankar, CIT(DR)(ITAT), Bengaluru
Section 142Section 143Section 263Section 80Section 80PSection 80P(2)(a)

respect of income of co-operative societies: 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 ... business of banking or providing credit facilities to its members by a co-operative society and is liable to be deducted from the gross total income under Section 80P of the Act. 9. In this context when we look at the judgment of the Apex Court in the case

Palapetty Velappan Shakthidaran, Bangalore vs. Commissioner of Income Tax (Appeal), Nashik

ITA 1939/BANG/2025[2017-18]Status: DisposedITAT Bangalore02 Feb 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Vignaraj Bhat N, CAFor Respondent: Shri Ganesh R Ghale, Advocate – Standing
Section 250Section 44ASection 56

44ADA of the Act to the tune of Rs. 3,71,500 (being 50% of gross receipts of Rs. 7,43,000/-). The gross total income of the assessee worked out to Rs. 5,14,347/- and assessee claimed deduction u/c VI-A to the tune

Mandyam Krishnakumar Sathyanarayana, Bengaluru vs. Income Tax Officer, Ward 3(3)(5), Bengaluru

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

ITA 1233/BANG/2025[2017-18]Status: DisposedITAT Bangalore02 Feb 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Shri GS Prashanth, CAFor Respondent: Shri Ganesh R Ghale, Advocate – Standing
Section 250Section 44ASection 56Section 57

44ADA of the Act to the tune of Rs. 3,71,500 (being 50% of gross receipts of Rs. 7,43,000/-). The gross total income of the assessee worked out to Rs. 5,14,347/- and assessee claimed deduction u/c VI-A to the tune

Hira Manek Co Operative Housing Society Limited, Mumbai vs. ITO Ward 34(2)(1), Mumbai

In the result, the appeal by the assessee for the assessment year 2020-

ITA 8500/MUM/2025[2020-21]Status: DisposedITAT Mumbai02 Feb 2026AY 2020-21

Bench: Shri Sandeep Singh Karhailshri Bijayananda Pruseth

For Appellant: Shri Rajesh Kumar GandhiFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 143(1)Section 250Section 80P

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

Hira Manek Co Operative Housing Society Limited, Mumbai vs. ITO Ward 34(2)(1), Mumbai

In the result, the appeal by the assessee for the assessment year 2020-

ITA 8499/MUM/2025[2021-22]Status: DisposedITAT Mumbai02 Feb 2026AY 2021-22

Bench: Shri Sandeep Singh Karhailshri Bijayananda Pruseth

For Appellant: Shri Rajesh Kumar GandhiFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 143(1)Section 250Section 80P

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

Bashir Jafar Bhaldar, Sonai Services 1 Sonai Services, Baramati Road Ind vs. Assessing Officer Ward 14(5) Pune, Aayakar Sadan Bodhi Tower Salasbury Park Gultekdi

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

ITA 2919/PUN/2025[2023-24]Status: DisposedITAT Pune30 Jan 2026AY 2023-24

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.2919/Pun/2025 Assessment Year : 2023-24

For Appellant: Shri Rajkumar DoshiFor Respondent: Date of hearing
Section 143(3)Section 250Section 288Section 33BSection 44ASection 80J

which reads as under : 3 Bashir Jafar Bhaldar “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 in sub-section