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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

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

In the result, Revenue’s Appeal is dismissed

ITA 2271/PUN/2025[2018-19]Status: DisposedITAT Pune21 Jan 2026AY 2018-19

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2270 & 2271/Pun/2025 निर्धारण वषा / Assessment Year: 2018-19 The Income Tax Officer, V Kanifnath Gramin Bigar Sheti Ward-2, Ahmednagar. S Sahakaripatsanstha Maryadit, At Post Malad, Taluka Sangamner, Ahmednagar – 422608. Pan: Aabak1395E Appellant/ Revenue Respondent /Assessee Assessee By Shri Pramod S Shingte – Ar Revenue By Smt Neha Thakkar (Virtual) Date Of Hearing 19/01/2026 Date Of Pronouncement 21/01/2026 आदेश/ Order Per Bench : These Two Appeals Filed By The Revenue Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac],Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2018- 19Dated 01.07.2025 Emanating From The Assessment Order Dated 30.03.2021 Under Section 143(3) R.W.S. 143(3A) & 143(3B) Of The Income Tax Act, 1961 & Order Under Section 250 Of The Income

Section 143(3)Section 250Section 270ASection 56Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

eligibility, it is unnecessary toprobe 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

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

In the result, Revenue’s Appeal is dismissed

ITA 2270/PUN/2025[2018-19]Status: DisposedITAT Pune21 Jan 2026AY 2018-19

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2270 & 2271/Pun/2025 निर्धारण वषा / Assessment Year: 2018-19 The Income Tax Officer, V Kanifnath Gramin Bigar Sheti Ward-2, Ahmednagar. S Sahakaripatsanstha Maryadit, At Post Malad, Taluka Sangamner, Ahmednagar – 422608. Pan: Aabak1395E Appellant/ Revenue Respondent /Assessee Assessee By Shri Pramod S Shingte – Ar Revenue By Smt Neha Thakkar (Virtual) Date Of Hearing 19/01/2026 Date Of Pronouncement 21/01/2026 आदेश/ Order Per Bench : These Two Appeals Filed By The Revenue Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac],Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2018- 19Dated 01.07.2025 Emanating From The Assessment Order Dated 30.03.2021 Under Section 143(3) R.W.S. 143(3A) & 143(3B) Of The Income Tax Act, 1961 & Order Under Section 250 Of The Income

Section 143(3)Section 250Section 270ASection 56Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

eligibility, it is unnecessary toprobe 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

Suvodeep Pyne, Garia vs. ITO, Ward 63(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2252/KOL/2025[2020-2021]Status: DisposedITAT Kolkata21 Jan 2026AY 2020-2021

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2251&2252/Kol/2025 Assessment Years: 2018-19 & 2020-21 Suvodeep Pyne…………………..…..……….………….……….……….……Appellant Castle Apt 3B, 129, Garia Main Road, Kamdahari, Garia S.O, W.B-700084.. [Pan: Bbypp8655C] Vs. Ito, Ward-63(1), Kolkata……………………………..…….....……...…..…..Respondent Appearances By: Shri Siddharth Pratim Dutta, Adv. & Sanjana Jha, Adv., Appeared On Behalf Of The Appellant. Shri S B Chakraborthy, Cit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 04, 2025 Date Of Pronouncing The Order : January 21, 2026 Order Per Pradip Kumar Choubey: Both The Captioned Appeals Have Been Preferred By The Assessee For The Assessment Years 2018-19 & 2020-21 Against Separate Orders Both Dated 09.08.2025 Of The Addl/Jcit(A) Kochi [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In Both The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. Ita No.2251/Kol/2025 Is Taken As Lead Case For Narration Of Facts. Ita No.2251/Kol/2025 – Brief Facts Of The Case Are That In This 2. Case, The Assessee Filed His Return Of Income For The Fy-2017-18, Relevant To The A.Y- 2018-19 On 29.08.2018 By Disclosing Gross Total Income Of Rs. 68,85,998/- & Claimed Deduction A Sum Of Ra.7,455/-. During The Year Under Consideration, The Assessee Disclosed Income From Salary Of

Section 111ASection 112Section 154Section 250Section 90

case, the assessee filed his return of income for the FY-2017-18, relevant to the A.Y- 2018-19 on 29.08.2018 by disclosing gross total income of Rs. 68,85,998/- and claimed deduction a sum of Ra.7,455/-. During the year under consideration, the assessee disclosed Income from salary

Suvodeep Pyne, Garia vs. ITO, Ward 63(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2251/KOL/2025[2018-2019]Status: DisposedITAT Kolkata21 Jan 2026AY 2018-2019

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2251&2252/Kol/2025 Assessment Years: 2018-19 & 2020-21 Suvodeep Pyne…………………..…..……….………….……….……….……Appellant Castle Apt 3B, 129, Garia Main Road, Kamdahari, Garia S.O, W.B-700084.. [Pan: Bbypp8655C] Vs. Ito, Ward-63(1), Kolkata……………………………..…….....……...…..…..Respondent Appearances By: Shri Siddharth Pratim Dutta, Adv. & Sanjana Jha, Adv., Appeared On Behalf Of The Appellant. Shri S B Chakraborthy, Cit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 04, 2025 Date Of Pronouncing The Order : January 21, 2026 Order Per Pradip Kumar Choubey: Both The Captioned Appeals Have Been Preferred By The Assessee For The Assessment Years 2018-19 & 2020-21 Against Separate Orders Both Dated 09.08.2025 Of The Addl/Jcit(A) Kochi [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In Both The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. Ita No.2251/Kol/2025 Is Taken As Lead Case For Narration Of Facts. Ita No.2251/Kol/2025 – Brief Facts Of The Case Are That In This 2. Case, The Assessee Filed His Return Of Income For The Fy-2017-18, Relevant To The A.Y- 2018-19 On 29.08.2018 By Disclosing Gross Total Income Of Rs. 68,85,998/- & Claimed Deduction A Sum Of Ra.7,455/-. During The Year Under Consideration, The Assessee Disclosed Income From Salary Of

Section 111ASection 112Section 154Section 250Section 90

case, the assessee filed his return of income for the FY-2017-18, relevant to the A.Y- 2018-19 on 29.08.2018 by disclosing gross total income of Rs. 68,85,998/- and claimed deduction a sum of Ra.7,455/-. During the year under consideration, the assessee disclosed Income from salary

Iris Realty LLP, Chennai vs. DCIT, Ncc-3(1), Chennai

In the result, the appeal filed by the assessee is partly-allowed for statistical purposes and the stay application filed by the assessee is dismissed

ITA 4129/CHNY/2025[2018-19]Status: DisposedITAT Chennai09 Jan 2026AY 2018-19

Bench: Shri George George Kand Ms Padmavathy Sआयकर अपील सं./Ita No.: 4129/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 & S.A. No. 142/Chny/2025 [In Ita No. 4129/Chny/2025] M/S. Iris Realty Llp, The Deputy Commissioner (Successor To Iris Realty Vs. Of Income Tax, Pvt.Ltd.,) Non-Corporate Circle 3(1), 11, Kakani Towers, Chennai. 15, Khader Nawaz Khan Road, Nungambakkam, Chennai – 600 034. Pan: Aagfi 9722F (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Vikram Vijaraghavan, Advocate ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 08.01.2026 घोषणा क" तारीख/Date Of Pronouncement : 09.01.2026

For Appellant: Shri Vikram Vijaraghavan, AdvocateFor Respondent: Ms. Gouthami Manivasagam
Section 143(3)Section 234ASection 250Section 68

income of ₹1,87,40,396/- for AY 2018-19 iii. Acknowledgement of Income Tax Return (ITR-V) for AY 2018-19 showing Gross Total Income of ₹2,73,68,243/-. B) Mr. K. Sarath Reddy (shareholder/director) i. Bank statement (April 2017-March 2018) evidencing investment ... Form 16 evidencing salary income of ₹1,68,66,531/- for AY 2018-19. iii. ITR-V for AY 2018-19 showing Gross Total Income of ₹2,51,49,642/- for AY 2018-19". 9. The Ld.AR submitted that the above documents clearly evidences that the Directors namely Shri Ajit

Pune Zilla Sahakari Dudh Utpadak Sangh Maryadit, Pune vs. DCIT, Circle-5, Pune

In the result, appeal of the Assessee for A

ITA 2195/PUN/2025[2018-19]Status: DisposedITAT Pune08 Jan 2026AY 2018-19

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita Nos.2194 & 2195/Pun/2025 निर्धारण वषा / Assessment Years: 2017-18 & 2018-19 Pune Zilla Sahakari Dudh V Dcit, Utpadak Sangh Maryadit, S. Circle-5, Pune. Katraj Dairy, Pune Satara Road, Katraj, Pune – 411037. Pan: Aaaap0836A Appellant/ Assessee Respondent / Revenue Assessee By Shri M.R.Bhagwat Revenue By Smt. Saumya Pandey Jain – Addl.Cit Date Of Hearing 20/11/2025 Date Of Pronouncement 08/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 Both Dated 30.07.2025 Emanating From The Separate Assessment Orders Under Section 143(3) Of The Act, 1961 Dated 19.12.2019 & 19.01.2021 For The A.Y.2017-18 & 2018-19 Respectively. For The Sake Of Convenience, Both The Appeals Were Heard Together & Decided In A

Section 143(3)Section 250Section 80Section 80P(2)(d)

reproduced here 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 sums specified