Section 80A(2) of the Income Tax Act

Income-tax Act, 2025: s.122

Section 80A(2) falls under section 80A of the Income-tax Act, 1961, which corresponds to section 122 (Deductions to be made in computing total income) of the Income-tax Act, 2025.

Read section 122 of the 2025 Act

Correspondence checked against the ICAI tabular mapping of the two Acts and the BharatTax.co section commentary.

The decision most relied on for Section 80A(2) is CIT v. Kotagiri Industrial Co-operative Tea Factory Ltd. (224 ITR 605), cited in 25 of the 26 judgments on BharatTax that turn on this section.

Leading authorities on Section 80A(2)

CIT v. Kotagiri Industrial Co-operative Tea Factory Ltd.
224 ITR 605 · 1997 · Supreme Court
25
citing judgments

Gross total income must be computed by setting off losses, including brought-forward losses and unabsorbed depreciation, before any deductions under Chapter VI-A can be considered. Deductions under Chapter VI-A are only available if the resulting gross total income is positive.

CIT v. Sona Koyo Steering Systems Ltd.
321 ITR 463 · 2010 · High Court
18
citing judgments

Each industrial undertaking must be considered independently when calculating deductions under Section 80-I of the Income-tax Act, 1961, even if the assessee has multiple units and incurs losses in one unit while making profits in another.

IPCA Laboratory Ltd. v. Dy. Commissioner of Income Tax, Mumbai
12 SCC 742 · 2004 · Reported
10
citing judgments

When computing deductions under Section 80HHC, profits from the export of self-manufactured goods and trading goods cannot be considered separately if there is a loss in one, and the deduction is admissible if the overall business income is positive after set-off.

CIT v. RPG Telecom Ltd. (Kar)
292 ITR 355 · 2007 · Reported
9
citing judgments
CIT v. Nima Specific Family Trust
248 ITR 29 · 2001 · High Court
8
citing judgments
CIT v. Sundravel Match Industries Pvt Ltd. (MAD)
245 ITR 605 · 2000 · Reported
7
citing judgments
Commissioner of Income-Tax, Tamil Nadu- III, Madras v. Madras Motors (P) Ltd.
150 ITR 150 · 1984 · Reported
3
citing judgments
Commissioner of Income-Tax v. Lucky Laboratories Ltd.
284 ITR 435 · 2006 · High Court
3
citing judgments

Judgments on Section 80A(2)

Section 80A(2) Income Tax Act (2025: s.122) — Case Laws | BharatTax