“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

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

In the result, appeal of the Assessee for A

ITA 2194/PUN/2025[2017-18]Status: DisposedITAT Pune08 Jan 2026AY 2017-18

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

Shri Jinnappanna Chougule Lalbahadur Credit Souhard Sahakari Sangh Niyamit, Belgaum vs. Income Tax Officer, Belgaum

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

ITA 276/PAN/2025[2018-19]Status: DisposedITAT Panaji07 Jan 2026AY 2018-19

Bench: Shri Pavan Kumar Gadalei T A. Nos.274,275 & 276/Pan/2025 (A.Y. 2015-16,2017-18 & 2018-19 ) Shri Jinnappanna Chougule Vs I T O, Lalbahadur Credit Souhard National E Assessment . Sahakari Niyamit, Centre, 2471,Lalbahadur Delhi. Akkamahadevi Chowk, Shirguppi Athani, Belagavi-591242, Karnataka. Pan .No. Aagas8466F (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

Section 80P(2)(a)

Shri Jinnappanna Chougle Lalbahadur Credit Souhard Sahakari Sangh Niyamit. both the categories of socities should be restricted to the income forming part of gross total income. And these grounds of appeal are partly allowed for statistical purpose.” 8. Therefore, considering the facts, circumstances, submissions and the ratio of the judicial

Shri Jinnappanna Chougule Lalbahadur Credit Souhard Sahakari Sangh Niyamit, 2471, Lalbahadur Akkamahadevi Chowk, Shirguppi Ath vs. Income Tax Officer, Belgaum

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

ITA 275/PAN/2025[2017-18]Status: DisposedITAT Panaji07 Jan 2026AY 2017-18

Section 80P(2)(a)

Shri Jinnappanna Chougule Lalbahadur Credit Souhard Sahakari Sangh Niyamit, Belgaum vs. Income Tax Officer, Belgaum

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

ITA 274/PAN/2025[2015-16]Status: DisposedITAT Panaji07 Jan 2026AY 2015-16

Section 80P(2)(a)

Chintan Dwarkadas Chotai, Junagadh vs. DCIT/ACIT Cir 1(1), RKT, Rajkot

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

ITA 636/RJT/2025[2019-20]Status: DisposedITAT Rajkot07 Jan 2026AY 2019-20

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

For Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 132Section 147Section 148Section 270ASection 272A(1)(d)Section 80G

delay in filing of the appeal. That the Ld.AR further explained that the Assessee filed Return of Income for A.Y.2019-20 on 28.08.2019 declaring gross total income of Rs.23,79,754/- and after claiming deductions under Chapter-VIA of Rs.2,72,482/-, total income is declared to Rs.21 ... appeal of the assessee, observing as follows: “3. The appellant is a salaried individual, earning more than Rs. 2lac per annum his gross total income is around Rs. 24Lac. Apparently, he is a well educated person. The appellant is also aware of the benefits of section 80G of Income

Angalakshmi Spinning Mill, Coimbatore vs. DCIT, Non Corporate Circle-4, Coimbatore

The Appeal is dismissed qua the issue of the extent of deduction under Section 80-IA of the Act

ITA 2260/CHNY/2025[2018-19]Status: DisposedITAT Chennai07 Jan 2026AY 2018-19

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2260/Chny/2025 िनधा#रण वष# /Assessment Year: 2018-19

For Appellant: Mr. A. Arjun Raj, C.A (virtual)For Respondent: Ms. Latchana, JCIT

Section 143(2)Section 153(1)Section 234ASection 250Section 801ASection 80I

assessee and held that interest income which is to be taxed under the head income from other sources cannot be included in the gross total income against which deduction under section 80IA of the Act is to be claimed. Accordingly the AO restricted the deduction u/s.80IA and made addition towards ... based on the workings as extracted in the earlier part of this order the actual deduction is claimed is restricted the Gross Total Income of Rs.2,49,74,166 . The A.O. held that the assessee has included the interest income as part of the business income against which the deduction

Shree Hatkeshwara Translines, Pune vs. Ass Commissioner, Income Tax Department Pune

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

ITA 2284/PUN/2025[2018-19]Status: DisposedITAT Pune06 Jan 2026AY 2018-19

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2284/Pun/2025 Assessment Year : 2018-19

For Appellant: Shri Vihit ShahFor Respondent: Shri Sanjay Dhivare

Section 143(2)Section 143(3)Section 250

Interest expense actually incurred (32,87,776) Not accepted based on decision of Hon Supreme Court in Goetze (I) Ltd. Vs. CIT 4 Gross Total Income (6,02,56,373) 4. Assessee craves the right to present any other/additional Ground of Appeal and/or supporting Case Law(s) in support

Icici Securities Limited, Mumbai vs. Principal Commissioner of Income Tax, Mumbai -4, Mumbai

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

ITA 3766/MUM/2025[2020-21]Status: DisposedITAT Mumbai06 Jan 2026AY 2020-21

Bench: SHRI AMIT SHUKLA (Judicial Member), SMT RENU JAUHRI (Accountant Member)

Section 143(3)Section 144BSection 263Section 36(1)(iii)Section 37(1)Section 80G

Limited Explanation 2 thereto. It was further submitted that the deduction claimed under section 80G was not from business income, but from the gross total income under Chapter VIA, which operates in a distinct statutory field. The assessee also placed on record donation certificates evidencing that the donations were made ... claim for deduction u/s.80G on a donation should be voluntary. It is independent of computation of business income as it is allowed from Gross Total Income. The assessee had disallowed the CSR expenses while computing business income. Further, there is no dispute that the assessee has filed complete details

Ishares Core Msci Total International Stock Etf (As A Successor to Ishare Core Taotal International Stock Mauritius Company ), Mumbai vs. Dy CIT (Int. Tax)-2(2)(1), Mumbai

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

ITA 6774/MUM/2025[2023-24]Status: DisposedITAT Mumbai02 Jan 2026AY 2023-24

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailishares Core Msci Emerging Markets Etf (As A Successor To Ishares Core Emerging Markets Mauritius Company) C/O Ernst & Young Llp, 17Th Floor, The Ruby, 29, Senapati Bapat Marg, ............... Appellant Dadar (West), Mumbai - 400028 Pan : Aafci3337N V/S Deputy Commissioner Of Income Tax (International Tax) - 2(2)(2) Room No.606, 6Th Floor, Kautilya Bhavan, ……………… Respondent C-41 To C-43, G-Block, Bandra Kurla Complex, Bandra (East), Mumbai – 400051 Ishares Msci All Country Asia Ex Japan Etf C/O Ernst & Young Llp, 17Th Floor, The Ruby, 29, Senapati Bapat Marg, Dadar (West), Mumbai - 400028 Pan : Aabti7439L ............... Appellant

For Appellant: Shri Pranav GandhiFor Respondent: Shri Satya Pal Kumar, CIT-DR

Section 143(3)Section 144C(13)Section 144C(5)Section 70Section 70(2)

respectively in the computation sheet appended to the impugned order as against allowing the same in the impugned order; 14. erred in computing gross total income as Rs. 4,88,17,61,36,880 in the computation sheet as against Rs. 2,44,71,11,79,000 determined ... Investment Company Mauritius Ltd(supra). In our considered view the answer is against revenue. The exempted income is not a part of taxable Gross Total Income. The non-grandfathered LTCG will be adjusted with brought forwarded loss, following the order of Goldman Sachs Investments (Mauritius) Ltd.(supra). The orders which

Ishares Core Msci Emerging Markets Etf (As A Successor to Ishares Core Emerging Markets Mauritius Company, Mumbai vs. DCIT (Tp) 2(2)(2), Mumbai

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

ITA 6051/MUM/2025[2023-24]Status: DisposedITAT Mumbai02 Jan 2026AY 2023-24

For Appellant: Shri Pranav GandhiFor Respondent: Shri Satya Pal Kumar, CIT-DR

Section 143(3)Section 144C(13)Section 144C(5)Section 70Section 70(2)

Ishares Msci All Country Asia Ex Japan Etf, Mumbai vs. DCIT (Int. Tax)-2(2)(2), Mumbai

ITA 6050/MUM/2025[2022-23]Status: DisposedITAT Mumbai02 Jan 2026AY 2022-23

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Pranav GandhiFor Respondent: Shri Satya Pal Kumar, CIT-DR

Section 143(3)Section 144C(13)Section 144C(5)Section 70Section 70(2)

Manisha Kamalkar Sadavarte, Navi Mumbai vs. Income Tax Officer, Ward - 28(2)(2), Mumbai, Navi Mumbai

In the result, the appeal of the assessee is allowed

ITA 3729/MUM/2025[2017-18]Status: DisposedITAT Mumbai01 Jan 2026AY 2017-18

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhailassessment Year : 2017-18 Manisha Kamalkar Sadavarte, Income Tax Officer, 4B, Room No. 24, Ward-28(2)(2), Shree Pranav Chs, Vs. Tower-6, Sector-10, Koparkhairne, Vashi Railway Station, Navi Mumbai-400709. Commercial Complex, Pan : Duhps2971A Vashi, Navi Mumbai-400703. (Appellant) (Respondent) For Assessee : Shri Ketan Vajani For Revenue : Shri Pravin Salunkhe, Sr.Dr Date Of Hearing : 08-12-2025 Date Of Pronouncement : 01-01-2026 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-National Faceless Appeal Centre (Nfac), Delhi [„Ld.Cit(A)‟], Dated 26-03-2025, Pertaining To Assessment Year (Ay) 2017-18, Wherein The Assessee Has Taken The Following Grounds Of Appeal:

For Appellant: Shri Ketan VajaniFor Respondent: Shri Pravin Salunkhe, Sr.DR

Section 144Section 69A

year 2016-17. Further, the assessee has also received management consultancy fees from EMS-Himal Hydro JV. It was submitted that assessee‟s gross total income was below the maximum amount not chargeable to tax, hence, no return of income was filed by the assessee in respect of tuition income

DCIT, Circle 3 4, Mumbai vs. Tata Consultancy Services Limited, Mumbai

In the result, appeals of both, revenue and assessee are partly

ITA 2244/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Dec 2025AY 2017-18

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Porus Kaka, Sr. AdvocateFor Respondent: Shri Ajay Chandra, CIT DR

Section 92CSection 92C(3)

IN THE INCOME TAX APPELLATE TRIBUNAL “H” BENCH MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT

The Karnataka State Regn and Stamps Department Officials Multi-Purpose Co-Op Society Limited, Bengaluru vs. ACIT, Circle-2(1)(1), Bengaluru

ITA 1518/BANG/2025[2017-18]Status: DisposedITAT Bangalore29 Dec 2025AY 2017-18

Bench: Shri Prashant Maharishi, Vice – & Shri Sandeep Singh Karhail

For Appellant: Shri Pranav Krishna, AdvocateFor Respondent: Shri Subramanian – JCIT DR

Section 57

Pujya Sharanabasaveshwara Pattina Souharda Sahakari Sangha Ni Maski, Maski vs. Income-Tax Office, Ward-1, Raichur

In the result appeal of the assessee is allowed

ITA 1180/BANG/2025[2020-21]Status: DisposedITAT Bangalore29 Dec 2025AY 2020-21

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhailassessment Year : 2020-21

For Appellant: Shri Anil Kumar, CAFor Respondent: Shri Muthu Shankar, CIT(DR)(ITAT), Bengaluru

Section 133Section 143Section 144BSection 263Section 56Section 80

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 ... providing credit facilities to its members by a co-operative society and is Page 9 of 14 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

Ramkrishna Bajaj Charitable Trust, Mumbai vs. Deputy Commissioner of Income-Tax, Circle 26(1), Mumbai

ITA 6544/MUM/2025[2013-14]Status: DisposedITAT Mumbai24 Dec 2025AY 2013-14

Bench: Shri Amit Shukla, Jm & Shri Arun Khodpia, Am

For Appellant: Ms. Vasanti Patel, Adv. & MrFor Respondent: Assessee by

Section 10(34)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 143(3)Section 164(2)Section 35ASection 80

considering assessee’s claim, the AO observed that as per Section 80G(4) of the Act donation made in excess of 10% of gross total income has to be ignored for the purpose of computation of aggregate of sum in respect of which deduction is to be allowed ... Accordingly, he restricted assessee’s claim of deduction u/s. 80G of the Act to the extent of 10% of gross total income or the actual claim whichever is less. 43. In so far as claim of deduction u/s. 80GGA of the Act, the AO observed that such claim

The Shiroda Progressive Urban Multipurpose Cooperative Society Limited, Ponda vs. Income Tax Officer, Panaji

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

ITA 273/PAN/2025[2020-21]Status: DisposedITAT Panaji23 Dec 2025AY 2020-21

Bench: Shri Pavan Kumar Gadalei T A. Nos.272 & 273/Pan/2025 (A.Y. 2018-19 & 2020-21 ) The Shiroda Progressive Urban Vs I T O, Multipurpose Cooperative National E Assessment . Society Limited, Centre, Shop.No.4, Opp: Police Station, Delhi. Shiroda Bhat, Ponda-403103.Goa Pan .No. Aabat7206P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

Section 80P(2)(a)

respect of scheduled bank interest in both the categories of socities should be restricted to the income forming part of gross total income. And these grounds of appeal are partly allowed for statistical purpose.” 8. Hence considering the facts, circumstances, submissions and the ratio of the judicial decisions dealt

The Shiroda Progressive Urban Multipurpose Cooperative Society Limited, Ponda vs. Income Tax Officer, Panaji

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

ITA 272/PAN/2025[2018-19]Status: DisposedITAT Panaji23 Dec 2025AY 2018-19

Section 80P(2)(a)

Lingannagari Parinitha, Hyderabad vs. ITO., Ward-11(4), Hyderabad

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

ITA 990/HYD/2025[2017-18]Status: DisposedITAT Hyderabad23 Dec 2025AY 2017-18

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: CA, Rajnish PissayFor Respondent: Sri Gudimella V P Pavan Kumar, Sr. AR

Section 142(1)Section 144Section 250Section 69A

computation sheet of the Assessment Order, the Assessing Officer has taken income from other sources at Rs.26,44,069 but the gross total income was adopted at Rs.35,74,069/-. Further, an additional amount of Rs.9,30,000/- which had already formed a part of the total deposits made

The Brahmaling Multipurpose Co-Op Society Ltd, Belgaum vs. Income Tax Officer, Ward -3, Belgaum

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

ITA 254/PAN/2025[2017-18]Status: DisposedITAT Panaji22 Dec 2025AY 2017-18

Bench: SHRI PAVAN KUMAR GADALE (Judicial Member)

Section 80PSection 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