Statutory levy is not Income

This ruling reinforces a fundamental principle in tax jurisprudence, tax collected on behalf of the Government is not income. 

The ITAT decisively holds that GST cannot be included in gross receipts for computing presumptive income under Section 44B. 

It further clarifies that deeming provisions must be strictly confined to their scope and cannot be expanded through indirect mechanisms like valuation provisions or accounting standards. 

The decision also reiterates consistency, judicial discipline, and the supremacy of specific provisions over general ones.