Section 80G donation relief must be computed after section 80J deduction, as gross total income is reduced first.

Section 80G donation relief had to be computed after giving effect to the section 80J deduction, because section 80G(4) assigns a special meaning to gross total income for that purpose. The statutory scheme required the section 80J amount to be taken into account first when determining the base for section 80G relief, so a priority order placing section 80G ahead of section 80J was not consistent with the Act. The claim to compute section 80G deduction before section 80J was rejected.

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Issues: Whether, for the relevant assessment year, deduction in respect of donations under section 80G of the Income-tax Act, 1961 could be computed before giving effect to deduction under section 80J, and whether section 80G relief had to be worked out with reference to gross total income after reduction of the section 80J deduction.

Analysis: Section 80G(4) gives a special meaning to gross total income for the purpose of limiting deduction for donations. On the language of the provision, the amount allowable under section 80J is required to be taken into account before determining the gross total income for computation of relief under section 80G. The claimed order of priority placing section 80G ahead of section 80J was therefore inconsistent with the statutory scheme.

Conclusion: The claim for deduction under section 80G before deduction under section 80J was rejected and the assessee did not succeed on this issue.

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