“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

Dy. Commissioner of Income Tax, Pune vs. Dilip Motilalji Chordia, Pune

In the result, the appeal filed by the Revenue as well as

ITA 1486/PUN/2024[2017-18]Status: DisposedITAT Pune22 Dec 2025AY 2017-18

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1486/Pun/2024

Section 143(2)Section 143(3)Section 250(4)Section 44ASection 96

Disallowances/Additions Income from sale of TDR [Para 5.3] | ₹5,31,95,834 E Income from other sources 14,20,893 Gross Total income 5,31,83,716 Less : Deduction under Chapter VI- A claimed 1,62,538 E Total Assessed Income 5,30,21,178 G Rounded

Jammanahally Prathamika Krishi Pattina Sahakara Sangha, Ballupet vs. Income Tax Officer, Ward-2, Hassan

In the result ITA No. 192/Bangalore/2025 filed by the assessee is allowed

ITA 341/BANG/2025[2017-18]Status: DisposedITAT Bangalore22 Dec 2025AY 2017-18

Bench: Shri Prashant Maharishi

For Appellant: Shri S.V. Ravishankar, AdvocateFor Respondent: Shri Ganesh R. Ghale, Advocate, Standing Counsel

Section 143(3)Section 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 ... 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

Jammanahally Prathamika Krishi Pattina Sahakara Sangha, Sakleshpur vs. Income Tax Officer, Ward -2, Hassan

In the result ITA No. 192/Bangalore/2025 filed by the assessee is allowed

ITA 192/BANG/2025[2017-18]Status: DisposedITAT Bangalore22 Dec 2025AY 2017-18

Bench: Shri Prashant Maharishi

For Appellant: Shri S.V. Ravishankar, AdvocateFor Respondent: Shri Ganesh R. Ghale, Advocate, Standing Counsel

Section 143(3)Section 80

U.P.Cooperative Federationltd, Lucknow vs. ITO-2(3), Lucknow

In the result, the appeal of the assessee is dismissed

ITA 260/LKW/2023[2003-14]Status: DisposedITAT Lucknow19 Dec 2025AY 2003-14

Bench: Shri Kul Bharat & Shri Anadee Nath Misshraआयकर अपील सं/ Ita No.260/Lkw/2023 ननिाारण वर्ा/ Assessment Year: 2003-04 U.P. Cooperative Federation V. Income Tax Officer-2(3) Ltd Pratyaksh Kar Bhawan, Pcf Building, 32, Station Road, 57, Ram Tirath Marg, Lucknow-226004. Hazratganj, Lucknow- 226001. Pan:Aaaau0373P अपीलार्थी/(Appellant) प्रत्यर्थी/(Respondent) अपीलार्थी कक और से/Appellant By: Shri D. D. Chopra, Advocate प्रत्यर्थी कक और से /Respondent By: Shri Neeraj Kumar, Cit(Dr) सुनवाई कक तारीख / Date Of Hearing: 22 09 2025 घोर्णा कक तारीख/ Date Of 19 12 2025 Pronouncement: आदेश / O R D E R

For Appellant: Shri D. D. Chopra, AdvocateFor Respondent: Shri Neeraj Kumar, CIT(DR)

Section 142Section 142(2)(a)Section 153(2)(a)Section 271Section 80PSection 80P(2)

dated 25.8.2014 has allowed the claim of deduction under section 80P (2) but the same has not been allowed to the extent of Gross Total Income as already held by the learned C.I.T.(Appeals)/ITAT/High Court for the assessment year 2009-10 and A.Y. 2010-11 as also followed ... same was accordingly allowed to the extent of claim made. However, the impugned additions had resulted in an increase in the ‘gross total income’ of the appellant. The additions made b. It is the submission of the Appellant that the Ld. AO and CIT(A) has erred in allowing

Deepalaxmi Nagari Patsanstha Maryadit, Sangamnagar vs. ITO Ward 2, Aurangabad

ITA 2323/PUN/2024[2020-21]Status: DisposedITAT Pune19 Dec 2025AY 2020-21

Bench: Justice (Retd.) C V Bhadang & Shri R. K. Panda

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri A D Kulkarni

Section 142(1)Section 143(2)Section 56Section 80PSection 80P(1)(a)Section 80P(2)Section 80P(2)(a)Section 80P(2)(c)

assessee society is engaged in providing banking / credit facilities to its members. It filed its return of income on 13.10.2018 declaring gross total income of Rs.65,21,355/- and total income of Nil after claiming deduction of Rs.65,21,355/- u/s 80P of the Income Tax Act, 1961 (hereinafter referred

Deepalaxmi Nagari Patsanstha Maryadit, Sangamnagar vs. ITO Ward 2, Ahmednagar

ITA 2322/PUN/2024[2018-19]Status: DisposedITAT Pune19 Dec 2025AY 2018-19

Bench: Justice (Retd.) C V Bhadang & Shri R. K. Panda

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri A D Kulkarni

Section 142(1)Section 143(2)Section 56Section 80PSection 80P(1)(a)Section 80P(2)Section 80P(2)(a)Section 80P(2)(c)

Dy. Commissioner of Income Tax, Satara Circle, Satara vs. Shri Siddhanath Nagari Sahakari Patsanstha Marya Dahiwadi, Man, Satara

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

ITA 1801/PUN/2025[2020-21]Status: DisposedITAT Pune18 Dec 2025AY 2020-21

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.1800 & 1801/Pun/2025 निर्धारण वर्ष / Assessment Years : 2018-19 & 2020-21 Dy. Cit, Satara Circle, Satara अपीलार्थी / Appellant Assessee By : Department By : Date Of Hearing : Date Of Pronouncement : Shri Siddhanath Nagari Sahakari Patsanstha Marya Dahiwadi, Vs. At Post-Dahiwadi, Tal.-Man Satara, Satara-415508 Pan: Aaoas0059G प्रत्यर्थी / Respondent Shri R.C. Doshi Shri S. Sadananda Singh 11-11-2025 18-12-2025 आदेश / Order Per Astha Chandra, Jm : These Two Appeals Filed By The Revenue Are Directed Against The Two Separate Orders Both Dated 19.05.2025 Of The Ld. Commissioner Of Income Tax (Appeals), Nfac, Delhi [“Cit(A)/Nfac"] Pertaining To Assessment Year (“Ay”) 2018-19 & 2020-21. Since The Issue(S) Involved Are Identical, These Were Heard Together & Are Being Disposed Of By This Common Order.

For Appellant: Department byFor Respondent: Date of hearing

Section 133(6)Section 143(3)Section 2(19)Section 80PSection 80P(2)(a)

eligibility, it is unnecessary to probe any further as to whether the co-operative society is classified as X or Y. Thirdly, the gross total income must include income that is referred to in sub-section (2). Fourthly, sub-clause (2)(a)(i) then speaks of a co-operative society ... 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

Dy. Commissioner of Income Tax, Satara Circle, Satara vs. Shri Siddhanath Nagari Sahakari Patsanstha Marya Dahiwadi, Tal. Man Satara

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

ITA 1800/PUN/2025[2018-19]Status: DisposedITAT Pune18 Dec 2025AY 2018-19

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.1800 & 1801/Pun/2025 निर्धारण वर्ष / Assessment Years : 2018-19 & 2020-21 Dy. Cit, Satara Circle, Satara Vs. Shri Siddhanath Nagari Sahakari Patsanstha Marya Dahiwadi, At Post-Dahiwadi, Tal.-Man Satara, Satara-415508 Pan: Aaoas0059G अपीलार्थी / Appellant Assessee By : Shri R.C. Doshi Department By : Shri S. Sadananda Singh Date Of Hearing : 11-11-2025 Date Of Pronouncement : 18-12-2025 प्रत्यर्थी / Respondent आदेश / Order Per Astha Chandra, Jm : These Two Appeals Filed By The Revenue Are Directed Against The Two Separate Orders Both Dated 19.05.2025 Of The Ld. Commissioner Of Income Tax (Appeals), Nfac, Delhi [“Cit(A)/Nfac"] Pertaining To Assessment Year (“Ay”) 2018-19 & 2020-21. Since The Issue(S) Involved Are Identical, These Were Heard Together & Are Being Disposed Of By This Common Order.

For Appellant: Shri R.C. DoshiFor Respondent: Shri S. Sadananda Singh

Section 133(6)Section 143(3)Section 2(19)Section 80PSection 80P(2)(a)

Dusters Total Solutions Services Private Limited, Bangalore vs. DCIT, Circle-2(1)(2), Bangalore

In the result appeal of the assessee is hereby allowed

ITA 980/BANG/2025[2018-19]Status: DisposedITAT Bangalore18 Dec 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Smt. Kavita Jha, AdvocateFor Respondent: Shri Shivanand H Kalakeri, CIT (DR)

Section 143(3)Section 80J

liability, has wrongly taken the business income at ₹33,39,41,406/- only. This has resulted in an incorrect determination of gross total income at ₹34,43,30,854. The mistake is apparent on the face of record. 17.1 On a careful reading of the assessment order, it is clear

Dusters Total Solutions Services Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-2(1)(1), Bangalore

In the result appeal of the assessee is hereby allowed

ITA 653/BANG/2025[2020-21]Status: DisposedITAT Bangalore18 Dec 2025AY 2020-21

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Smt. Kavita Jha, AdvocateFor Respondent: Shri Shivanand H Kalakeri, CIT (DR)

Section 143(3)Section 80J

Dusters Total Solutions Services Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-2(1)(1), Bangalore

ITA 652/BANG/2025[2018-19]Status: DisposedITAT Bangalore18 Dec 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Respondent: Smt. Kavita Jha, Advocate

Section 143(3)Section 80J

IN THE INCOME TAX APPELLATE TRIBUNAL 'A' BENCH, BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL

Bella Vista Co Operative Housing Society Limited, Mumbai vs. ITO Ward 3(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 6594/MUM/2025[2020-21]Status: DisposedITAT Mumbai17 Dec 2025AY 2020-21

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2020-21 Bella Vista Co-Operative Income Tax Officer, Housing Society Limited, Ward-3(1), 7Th Floor, Bella Vista, Vs. Room No. 3, 6Th Floor, 20A Oswal Park, B Wing, Pokharan Road-2, Ashar It Park, Road No.16Z, Thane, Wagle Industrial Estate, Maharashtra–400601. Thane (West), [Pan: Aadab2432M] Maharashtra-400604. (Appellant) (Respondent) For Assessee : Shri Ritesh Shiyal For Revenue : Shri B. Laxmi Kanth, Sr.Dr Date Of Hearing : 16-12-2025 Date Of Pronouncement : 17-12-2025 Order Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Ld.Addl/Jcit(A)-3, Bengaluru, Dated 26-09-2025, Pertaining To Assessment Year (Ay) 2020-21. 2. The Limited Issue For Consideration In The Present Matter Relates To Claim Of Exemption U/S 80P(2)(D) Of The Act By The Assessee Co-Operative Society In Respect Of Interest Income Earned On Deposits Placed With Co-Operative Banks.

For Appellant: Shri Ritesh ShiyalFor Respondent: Shri B. Laxmi Kanth, Sr.DR

Section 143(1)Section 154Section 80Section 80PSection 80P(1)Section 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

Torrent Power Grid Limited, Ahmedabad vs. The Pr.CIT-3, Ahmedabad

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

ITA 1191/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad16 Dec 2025AY 2020-21

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 142(1)Section 143(3)Section 144BSection 263Section 80G

sums on which deduction shall be allowed to the assessee. Section 80G falls in Chapter VIA, which comes into play only after the gross total income has been computed by applying the computation provisions under various heads of income, including the Explanation 2 to section

Shree Jagadguru Mouneshwar Pattin Sahakari Sangh Niyamit Kerur, Bagalkot vs. Income Tax Officer, Ward-1, Bagalkot

In the result the appeal filed by the assessee is allowed

ITA 1623/BANG/2025[2020-21]Status: DisposedITAT Bangalore15 Dec 2025AY 2020-21

Bench: Shri Prashant Maharishi

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

Vijaya Bank Employees Co-Operative Credit Society, Bangalore vs. The Income Tax Officer, Ward 7(2)(3), Bangalore

In the result the appeal filed by the assessee is allowed

ITA 1524/BANG/2025[2022-23]Status: DisposedITAT Bangalore15 Dec 2025AY 2022-23

Bench: Shri Prashant Maharishiassessment Years 2022-23 Appellant / Assessee Vijaya Bank Employees Cooperative Credit Society, R No 1, 67, Ii Floor, K H Road Shantinagar Bangalore 560027 Karnataka Respondent The Income Tax Officer, Ward 7 (2) (3) Bmtc Building Koramangala Bangalore 560095 Pan Aaaav4696A For Appellant Shri Prasanna N Uralal Advocate For Respondent Shri Ganesh R Ghale, Advocate Date Of Hearing 04-11-2025 Date Of Pronouncement 15-12-2025 O R D E R

Section 139(1)Section 143(2)Section 80PSection 80P(2)(a)Section 80P(2)(d)

said section deals with deductions in respect of income of co-operative societies. Section 80P (1), inter alia, states that where the gross total income of a co-operative society includes any income from one or more specified activities, then such income shall be Page 3 of 13 deducted from ... gross total income in computing the total taxable income of the assessee society. An income, which is attributable to any of the specified activities in section 80P (2) would be eligible for deduction. The word 'income' has been defined under section 2(24)(i) to include profits and gains. This

Sreesharada Credit Co-Operative Society Ltd, Udupi vs. ITO Ward- 1&Tps, Udupi

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

ITA 1316/BANG/2025[2020-21]Status: DisposedITAT Bangalore15 Dec 2025AY 2020-21

Bench: Shri Prashant Maharishi

Section 80

Sreesharada Credit Co-Operative Society Ltd, Udupi vs. ITO Ward- 1&Tps, Udupi

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

ITA 1315/BANG/2025[2018-19]Status: DisposedITAT Bangalore15 Dec 2025AY 2018-19

Bench: Shri Prashant Maharishi

Section 80

Tapas Kundu, Kolkata vs. I.T.O., Ward - 61(3), Kolkata

In the result, appeal of the assessee stands dismissed

ITA 1819/KOL/2025[2017-2018]Status: DisposedITAT Kolkata12 Dec 2025AY 2017-2018

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 1819/Kol/2025 Assessment Year: 2017-2018 Tapas Kundu,………………………..……...……Appellant 237, Dumdum Park, Lake Town, North 24-Parganas, Bangur Avenue S.O., Kolkata-700055 [Pan:Afypk5224R] -Vs.- Income Tax Officer,…………………………..…..Respondent Ward-61(3), Kolkata, Bamboo Villa, Kolkata-700014

Section 139(1)Section 142(1)Section 143(1)Section 143(2)Section 69A

details, clarifications and supporting evidences electronically as well as physically through speed post. The assessee has shown Rs.11,00,070/- as his gross total income. Out of which, Rs.10,24,370/- was declared as income from salary and Rs.75,700/- as income from other sources. The assessee’s salary

Thirumal Arun Mohan Dass, Puducherry vs. The Assistant Commissioner of Income Tax, Circle 1, Puducherry

In the result, the appeal of the assessee for A

ITA 2213/CHNY/2025[2020-21]Status: DisposedITAT Chennai12 Dec 2025AY 2020-21

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2212 & 2213/Chny/2025 िनधा%रण वष% /Assessment Years: 2015-16 & 2020-21

For Appellant: Mr. V. Meenakshi Sundar, C.A *+For Respondent: Ms. Babitha, JCIT

Section 148Section 250

Less: Expenses u/s. 57-estimated 72,50,910 6,30,513 @92% Income from other sources 7,64,235 Gross Total income 24,25,498 Rounded off 24,25,500 10. The Ld. A.R submitted that the other receipts declared by the assessee consists of receipt from LIC India, Puducherry

Thirumal Arun Mohan Dass, Puducherry vs. The Assistant Commissioner of Income Tax, Circle 1, Puducherry

In the result, the appeal of the assessee for A

ITA 2212/CHNY/2025[2015-16]Status: DisposedITAT Chennai12 Dec 2025AY 2015-16

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2212 & 2213/Chny/2025 िनधा%रण वष% /Assessment Years: 2015-16 & 2020-21

For Appellant: Mr. V. Meenakshi Sundar, C.A *+For Respondent: Ms. Babitha, JCIT

Section 148Section 250