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“income from other sources”

Income HeadsSection 56Section 568,248 judgments

The decision most relied on for income from other sources is Jute Corporation of India Ltd. v. CIT (187 ITR 688), cited in 1,372 judgments on BharatTax.

Leading authorities on income from other sources

Jute Corporation of India Ltd. v. CIT
187 ITR 688 · 1991 · Supreme Court
1,372
citing judgments

The Commissioner of Income Tax (Appeals) possesses co-terminus powers with the Assessing Officer and can direct the Assessing Officer to perform actions he failed to do, but cannot introduce a new source of income in the assessment. The appellate assessment must be confined to the items of income that were the subject matter of the original assessment.

Totgars Co-operative Sale Society Ltd. v. ITO
322 ITR 283 · 2010 · Supreme Court
1,283
citing judgments

The interest income earned by a cooperative society from investing its surplus funds in fixed deposits with banks is not "derived from" its eligible business activities and is taxable as "income from other sources" under Section 56, thus not qualifying for deduction under Section 80P.

K.P. Varghese v. ITO
131 ITR 597 · 1981 · Supreme Court
989
citing judgments

An addition to income cannot be made merely on the basis of a difference in valuation of assets or a Valuation Officer's report without establishing actual understatement of consideration or the source of unexplained funds through proper enquiry. The Assessing Officer must conduct proper enquiry and satisfy the conditions for making such additions.

GE India Technology Centre Pvt. Ltd. v. CIT
327 ITR 456 · 2010 · Supreme Court
663
citing judgments

Tax must be deducted at source from payments made to a non-resident under Section 195 only if such payment is chargeable to tax in India. The Assessing Officer bears the onus to establish that the payments made are indeed chargeable to tax under the Income Tax Act.

Commissioner of Income Tax v. Nova Promoters and Finlease (P) Ltd.
342 ITR 169 · 2012 · High Court
658
citing judgments

To make an addition under Section 68 for unexplained cash credits, the Assessing Officer must conduct proper inquiry into the identity, genuineness, and creditworthiness of the creditor, especially concerning share application money. The assessee's initial discharge of burden by providing necessary details shifts the onus back to the AO for further investigation, including the source of source.

Tuticorin Alkali Chemicals & Fertilizers Ltd. v. CIT
227 ITR 172 · 1997 · Supreme Court
621
citing judgments

Interest income earned on deposits, particularly before the commencement of business operations or as a requirement for business licensing, is taxable as "income from other sources" under Section 56, and cannot be treated as business income or set off against interest on borrowed funds.

Kale Khan Mohammad Hanif v. CIT
50 ITR 1 · 1963 · Supreme Court
581
citing judgments

The assessee bears the onus of proving the source and nature of any sum of money or receipt found to have been received by them. If the assessee fails to satisfactorily explain the receipt, the Income-tax Officer is entitled to treat it as taxable income.

Liberty India v. CIT
317 ITR 218 · 2009 · Supreme Court
571
citing judgments

The Supreme Court clarified that for profits and gains to be eligible for deductions under sections like 10B, 80IA, or 80IB, the income must be "derived from" or have a direct nexus to the eligible business activity. Income from incidental sources like the sale of scrips/licenses or interest on employee loans is generally not considered as derived from the eligible business for such deductions.

Judgments citing income from other sources

Savita Sanjay Marghade, Durg, Chhattisgarh vs. Income Tax Officer, Bhilai

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

ITA 849/RPR/2025[2013-14]Status: DisposedITAT Raipur17 Feb 2026AY 2013-14

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 849/Rpr/2025 (िनधा"रण वष" Assessment Year: 2013-14) Savita Sanjay Marghade, Mig-658, Vs Income Tax Officer, Aaykar Bhavan, Padmanabhpur, Durg, Chhattisgarh. Opposite Geet Talkies, 491001 New Civic Centre, Sector 6 Bhilai Nagar, Chhattisgarh. 490006 Pan: Aktpm6715H (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : None. राज" की ओर से / Revenue By : Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 10/02/2026 घोषणा की तारीख / Date Of : 17/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: This Appeal For Assessment Year (‘Ay’) 2013-14 Filed By The Assessee Is Directed Against The Order Dated 17.10.2025 Of The Commissioner Of Income Tax (Appeals), [‘Cit(A)’], National Faceless Appeal Centre (‘Nfac’), Delhi Passed Under Section 250 Of The Income Tax Act, 1961 (‘Act’).

For Appellant: NoneFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 148Section 249(3)Section 250

appellant. 2. The learned Assessing Officer erred in law and on facts in making the addition of Rs.55,25,350 under the head income from other sources on account of acquired contract of sale purchase of equity shares, without appreciating the fact that the set amount only represented the market

Karadi Path Education Company Private Limited, Chennai vs. Commissioner, Chennai

ITA 1848/CHNY/2025[2018-2019]Status: DisposedITAT Chennai17 Feb 2026AY 2018-2019

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1848/Chny/2025 निर्धारण वर्ष / Assessment Year: 2018-19 Karadi Path Education Company Private Limited, 3A No.11, Dev Regency, I Main Road, Gandhi Nagar, Adyar, Chennai - 600 020. [Pan: Aaeck-2995-D] (अपीलार्थी/Appellant) Dcit, Vs. Corporate Circle -4(1), Chennai. (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Shri. Pradhan Priya Dass, C.A. (By Virtual) प्रत्यर्थी की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/Date Of Hearing : 27.11.2025 घोषणा की तारीख/Date Of Pronouncement : 17.02.2026 आदेश /O R Der Per S. R. Raghunatha, Am: This Appeal By The Assessee Is Filed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, (In Short “Ld.Cit(A)”) For The Assessment Year 2018-19, Dated 29.04.2025 In Respect Of The Order Of The National E-Assessment Centre, Delhi (In Short 'Ao') Passed U/S.143(3) Of The Income Tax Act, 1961 ( In Short ‘The Act') Dated 28.04.2021. :-2-:

For Appellant: Shri. Pradhan Priya Dass, C.A. (by Virtual)For Respondent: Ms. Gouthami Manivasagam, JCIT
Section 143(3)Section 56(2)(vii)Section 56(2)(viib)

where a private company receives consideration for the issue of shares exceeding the face value, the excess over the FMV is taxable as income from other sources. The provision uses the term "issue of shares," which is exhaustive and covers all forms, including conversion of loans into equity. No restriction