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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

Deputy Commissioner of Income Tax, Central Circle, Hubballi vs. Shri Gopal Krishnanatsa Katigar, Hubballi

In the result, the appeal of the Revenue is dismissed

ITA 1143/BANG/2024[2019-20]Status: DisposedITAT Bangalore02 Jun 2025AY 2019-20

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri MV Sheshachala, Sr. AdvocateFor Respondent: Shri D.K. Mishra, CIT (DR)
Section 131(1)Section 132Section 132(4)Section 153C

unaccounted interest income of ₹1,63,16,719/- in cash, generated from the unexplained cash investments. This amount was treated as ‘income from other sources’ and added to the total income of the assessee. 14. The aggrieved assessee preferred an appeal before the learned CIT(A). 15. The assessee before

Deputy Commissioner of Income Tax, Central Circle, Hubballi vs. Shri Gopal Krishnanatsa Katigar, Hubballi

In the result, the appeal of the Revenue is dismissed

ITA 1142/BANG/2024[2018-19]Status: DisposedITAT Bangalore02 Jun 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

Section 131(1)Section 132Section 132(4)Section 153C

unaccounted interest income of %1,63,16,719/- in cash, generated from the unexplained cash investments. This amount was treated as ‘income from other sources’ and added to the total income of the assessee. 14. The aggrieved assessee preferred an appeal before the learned CIT(A). 15. The assessee before

Deputy Commissioner of Income Tax, Central Circle, Hubballi vs. Shri Gopal Krishnanatsa Katigar, Hubballi

In the result, the appeal of the Revenue is dismissed

ITA 1141/BANG/2024[2017-18]Status: DisposedITAT Bangalore02 Jun 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri MV Sheshachala, Sr. AdvocateFor Respondent: Shri D.K. Mishra, CIT (DR)
Section 131(1)Section 132Section 132(4)Section 153C

unaccounted interest income of ₹1,63,16,719/- in cash, generated from the unexplained cash investments. This amount was treated as ‘income from other sources’ and added to the total income of the assessee. 14. The aggrieved assessee preferred an appeal before the learned CIT(A). 15. The assessee before

Deputy Commissioner of Income Tax, Central Circle, Hubballi vs. Shri Gopal Krishnanatsa Katigar, Hubballi

In the result, the appeal of the Revenue is dismissed

ITA 1140/BANG/2024[2016-17]Status: DisposedITAT Bangalore02 Jun 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri MV Sheshachala, Sr. AdvocateFor Respondent: Shri D.K. Mishra, CIT (DR)
Section 131(1)Section 132Section 132(4)Section 153C

unaccounted interest income of ₹1,63,16,719/- in cash, generated from the unexplained cash investments. This amount was treated as ‘income from other sources’ and added to the total income of the assessee. 14. The aggrieved assessee preferred an appeal before the learned CIT(A). 15. The assessee before

Deputy Commissioner of Income Tax, Central Circle, Hubballi vs. Shri Gopal Krishnanatsa Katigar, Hubballi

In the result, the appeal of the Revenue is dismissed

ITA 1139/BANG/2024[2015-16]Status: DisposedITAT Bangalore02 Jun 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri MV Sheshachala, Sr. AdvocateFor Respondent: Shri D.K. Mishra, CIT (DR)
Section 131(1)Section 132Section 132(4)Section 153C

unaccounted interest income of ₹1,63,16,719/- in cash, generated from the unexplained cash investments. This amount was treated as ‘income from other sources’ and added to the total income of the assessee. 14. The aggrieved assessee preferred an appeal before the learned CIT(A). 15. The assessee before

Deputy Commissioner of Income Tax, Central Circle, Hubballi vs. Shri Gopal Krishnanatsa Katigar, Hubballi

In the result, the appeal of the Revenue is dismissed

ITA 1138/BANG/2024[2014-15]Status: DisposedITAT Bangalore02 Jun 2025AY 2014-15

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri MV Sheshachala, Sr. AdvocateFor Respondent: Shri D.K. Mishra, CIT (DR)
Section 131(1)Section 132Section 132(4)Section 153C

unaccounted interest income of ₹1,63,16,719/- in cash, generated from the unexplained cash investments. This amount was treated as ‘income from other sources’ and added to the total income of the assessee. 14. The aggrieved assessee preferred an appeal before the learned CIT(A). 15. The assessee before

Jile Singh, Faridabad vs. Income Tax Officer, Faridabad

In the result, appeal of the assessee is allowed

ITA 2223/DEL/2025[2017-18]Status: DisposedITAT Delhi02 Jun 2025AY 2017-18

Bench: Sh. Satbeer Singh Godaraita No. 2223/Del/2025 : Asstt. Year : 2017-18 Jile Singh, Vs Income Tax Officer, H. No. 68, Sotai, Near Mahipal Ward-51(3), Nambardar, Ballabgarh, Faridabad, Faridabad, Haryana-121002 Haryana-121004 (Appellant) (Respondent) Pan No. Fzsps8684G Assessee By: None Revenue By : Sh. Akhilesh Kumar Yadav, Sr. Dr Date Of Hearing: 02.06.2025 Date Of Pronouncement: 02.06.2025 Order

For Appellant: NoneFor Respondent: Sh. Akhilesh Kumar Yadav, Sr. DR
Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 263Section 28Section 56(2)(viii)

taxmann.com 301 (Del.) wherein the department has succeeded before their lordships that the impugned interest component ought to be assessed as income from “other” sources only. 5. I have given my thoughtful consideration to the assessee’s pleadings and Revenue’s foregoing vehement contention. It emerges that this tribunal ... part of enhanced compensation as envisaged in section 5 Jile Singh 45(5) of the Act to 'revenue receipt' chargeable to tax as income from other sources. The view taken by the Ld. AO that interest under section 28 of Land Acquisition Act received by the assessee is exempt under

Seabird Marine Services Private Limited, Jamnagar vs. ACIT, Circle - 1, Jamnagar, Jamangar

ITA 83/RJT/2025[2017-18]Status: DisposedITAT Rajkot30 May 2025AY 2017-18

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 83/Rjt/2025 (निर्धारण वर्ष/Assessment Year: (2017-18) Seabird Marine Services Pvt. Vs. Ltd. Office No. 309 & 310, Centroid Luxuria, Nr. Crystal Mall, Khodiyar Colony, Aerodrome Road, Jamnagar 361006 Assistant Commissioner Of Income-Tax, Circle-1, Jamnagar, Aayakar Bhawan, Nr. Subhash Bridge, Jamnagar -Rajkot Highway, Jamnagar स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaccs 9869 C (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Appellant By : Shri S. N. Soparkar, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. Cit-Dr Date Of Hearing : 30/04/2025 Date Of Pronouncement : 30/05/2025 Per Dr. A. L. Saini, Am: आदेश / Order Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2017-18, Is Directed Against The Order Passed By The National Faceless Appeal Centre (Nfac), Dehi/ Commissioner Of Income Tax (Appeal) [In Short 'Ld. Cit(A)'], Dated 02.01.2025, Which In Turn Arises Out Of An Assessment Order Passed By The Assessing Officer, Under Section 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”), Vide Order Dated 31.12.2019. 2. Grounds Of Appeal Raised By The Assessee Are As Follows: “All The Below Mentioned Grounds Of Appeal Are Independent & Without Prejudices To Each Other.

For Appellant: Shri S. N. Soparkar, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT-DR
Section 114Section 115JSection 143(3)

that the income received by the assessee-company from its investment in the UTI has been declared by the company itself as an 'income from other sources' which head of income is different from income from 'Profits and gains of business or profession' and under section 32AB, income from business

Monarch Corporation, Surat vs. DCIT, Circle-2(3), Surat

In the result, assessee’s appeal is allowed

ITA 725/SRT/2024[2016-17]Status: DisposedITAT Surat30 May 2025AY 2016-17

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं./Ita No.725/Srt/2024 Assessment Year : 2016-17 (Hybrid Hearing) Monarch Corporation Deputy Commissioner Of Income- बनाम/ F.P. 40, T.P. 10, Beside Tax, Circle-2(3), Surat/Assistant Vs. Kalpvrukh Garden, Commissioner Of Income-Tax, Gauravpath Pal, Surat-394230 Circle-2(1)(1), Surat Aayakar Bhawan, Near Majura Gate, Opp. New Civil Hospital, Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aazfm 1036 B (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Appellant By Shri Hiren M. Diwan, Ca राज" की ओर से /Respondent By Shri Mukesh Jain, Sr-Dr सुनवाई की तारीख/Date Of Hearing 20/03/2025 उद्घोषणा की तारीख/Date Of Pronouncement 30/05/2025

Section 115BSection 143(3)Section 250Section 68

erred in law and on facts in upholding the action of the ld. AO of treating the income of Rs.98,00,000/- as income from other sources. ITA No.725/Srt/2024 A.Y.16-17 Monarch Corporation 3) The ld. CIT(A) has erred in law and on facts in upholding the action ... shown as additional business income. In response to the show cause notice as to why the above income should not be treated as “income from other sources” the assessee submitted that the above amount represents income from real estate. The assessee had negotiated to purchase a piece of land which

Assistant Commissioner of Income Tax, Panchkula Circle, Panchkula vs. The Haryana State Co-Operative Agriculture and Rural Development, Panchkula

Appeal is allowed

ITA 596/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh30 May 2025AY 2017-18

Bench: BEFORE: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

banks. 13. The Ld. AO disallowed deduction claimed u/s 80P(2)(a)(i) in respect of the said interest, holding it to be “income from other sources” not eligible for deduction. 14. The Ld. CIT(A) confirmed the action of the ld. AO and held that: “Punjab National Bank, State ... eligible for deduction u/s 80P(2)(a)(i) and 80P(2)(d) of the Act. This amount is to be taxed as income from other sources and no deduction u/s 80P is allowed on this amount.” 14.1 In regard to above, the Ld. Counsel for the assessee in its submission

The Haryana State Co-Operative Agriculture and Rural Development, Panchkula vs. Deputy Commissioner of Income Tax, Circleu��, Panchkula

Appeal is allowed

ITA 595/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh30 May 2025AY 2017-18

banks. 13. The Ld. AO disallowed deduction claimed u/s 80P(2)(a) (i) in respect of the said interest, holding it to be “income from other sources" not eligible for deduction. 14. The Ld. CIT(A) confirmed the action of the Id. AO and held that: “Punjab National Bank, State ... eligible for deduction u/s 80P(2)(a) (i) and 80P(2)(d) of the Act. This amount is to be taxed as income from other sources and no deduction u/s 80P is allowed on this amount." 14.1 In regard to above, the Ld. Counsel for the assessee in its submission

Assistant Commissioner of Income Tax, Panchkula Circle, Panchkula vs. The Haryana State Co-Operative Agriculture and Rural Development, Panchkula

Appeal is allowed

ITA 594/CHANDI/2024[2016-17]Status: DisposedITAT Chandigarh30 May 2025AY 2016-17

Bench: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

banks. 13. The Ld. AO disallowed deduction claimed u/s 80P(2)(a)(i) in respect of the said interest, holding it to be “income from other sources” not eligible for deduction. 14. The Ld. CIT(A) confirmed the action of the ld. AO and held that: “Punjab National Bank, State ... eligible for deduction u/s 80P(2)(a)(i) and 80P(2)(d) of the Act. This amount is to be taxed as income from other sources and no deduction u/s 80P is allowed on this amount.” 14.1 In regard to above, the Ld. Counsel for the assessee in its submission

The Haryana State Co-Operative Agriculture and Rural Development, Panchkula vs. Deputy Commissioner of Income Tax, Circle, Panchkula

Appeal is allowed

ITA 593/CHANDI/2024[2016-17]Status: DisposedITAT Chandigarh30 May 2025AY 2016-17

Bench: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

banks. 13. The Ld. AO disallowed deduction claimed u/s 80P(2)(a)(i) in respect of the said interest, holding it to be “income from other sources” not eligible for deduction. 14. The Ld. CIT(A) confirmed the action of the ld. AO and held that: “Punjab National Bank, State ... eligible for deduction u/s 80P(2)(a)(i) and 80P(2)(d) of the Act. This amount is to be taxed as income from other sources and no deduction u/s 80P is allowed on this amount.” 14.1 In regard to above, the Ld. Counsel for the assessee in its submission

The Haryana State Co-Operative Agriculture and Rural Development, Panchkula vs. Deputy Commissioner of Income Tax, Circle, Panchkula

Appeal is allowed

ITA 592/CHANDI/2024[2016-17]Status: DisposedITAT Chandigarh30 May 2025AY 2016-17

Bench: BEFORE: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

banks. 13. The Ld. AO disallowed deduction claimed u/s 80P(2)(a)(i) in respect of the said interest, holding it to be “income from other sources” not eligible for deduction. 14. The Ld. CIT(A) confirmed the action of the ld. AO and held that: “Punjab National Bank, State ... eligible for deduction u/s 80P(2)(a)(i) and 80P(2)(d) of the Act. This amount is to be taxed as income from other sources and no deduction u/s 80P is allowed on this amount.” 14.1 In regard to above, the Ld. Counsel for the assessee in its submission

Assistant Commissioner of Income Tax, Panchkula Circle, Panchkula vs. The Haryana State Co-Operative Agriculture and Rural Development, Panchkula

Appeal is allowed

ITA 591/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh30 May 2025AY 2015-16

Bench: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

banks. 13. The Ld. AO disallowed deduction claimed u/s 80P(2)(a)(i) in respect of the said interest, holding it to be “income from other sources” not eligible for deduction. 14. The Ld. CIT(A) confirmed the action of the ld. AO and held that: “Punjab National Bank, State ... eligible for deduction u/s 80P(2)(a)(i) and 80P(2)(d) of the Act. This amount is to be taxed as income from other sources and no deduction u/s 80P is allowed on this amount.” 14.1 In regard to above, the Ld. Counsel for the assessee in its submission

The Haryana State Co-Operative Agriculture and Rural Development, Panchkula vs. Deputy Commissioner of Income Tax, Circle, Panchkula

Appeal is allowed

ITA 590/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh30 May 2025AY 2015-16

Bench: BEFORE: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

banks. 13. The Ld. AO disallowed deduction claimed u/s 80P(2)(a)(i) in respect of the said interest, holding it to be “income from other sources” not eligible for deduction. 14. The Ld. CIT(A) confirmed the action of the ld. AO and held that: “Punjab National Bank, State ... eligible for deduction u/s 80P(2)(a)(i) and 80P(2)(d) of the Act. This amount is to be taxed as income from other sources and no deduction u/s 80P is allowed on this amount.” 14.1 In regard to above, the Ld. Counsel for the assessee in its submission

The Haryana State Co-Operative Agriculture and Rural Development, Panchkula vs. DCIT, Circle, Panchkula

Appeal is allowed

ITA 589/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh30 May 2025AY 2015-16

Bench: BEFORE: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

banks. 13. The Ld. AO disallowed deduction claimed u/s 80P(2)(a)(i) in respect of the said interest, holding it to be “income from other sources” not eligible for deduction. 14. The Ld. CIT(A) confirmed the action of the ld. AO and held that: “Punjab National Bank, State ... eligible for deduction u/s 80P(2)(a)(i) and 80P(2)(d) of the Act. This amount is to be taxed as income from other sources and no deduction u/s 80P is allowed on this amount.” 14.1 In regard to above, the Ld. Counsel for the assessee in its submission

The Haryana State Co-Operative Agriculture and Rural Development, Panchkula vs. DCIT, Circle, Panchkula

Appeal is allowed

ITA 588/CHANDI/2024[2014-15]Status: DisposedITAT Chandigarh30 May 2025AY 2014-15

Bench: BEFORE: SHRI. RAJPALYADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

banks. 13. The Ld. AO disallowed deduction claimed u/s 80P(2)(a)(i) in respect of the said interest, holding it to be “income from other sources” not eligible for deduction. 14. The Ld. CIT(A) confirmed the action of the ld. AO and held that: “Punjab National Bank, State ... eligible for deduction u/s 80P(2)(a)(i) and 80P(2)(d) of the Act. This amount is to be taxed as income from other sources and no deduction u/s 80P is allowed on this amount.” 14.1 In regard to above, the Ld. Counsel for the assessee in its submission

Madhya Gujarat Vij Co. Ltd., Vadodara vs. The Dy.CIT, Circle-2(1)(2), Vadodara

In the result, the appeal being ITA No

ITA 110/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad30 May 2025AY 2021-22

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 109 & 110/Ahd/2025 Assessment Year 2017-18 & 2021-22

For Appellant: Shri M.K. Patel on behalf of Shri Parin Shah A.RFor Respondent: Shri Prathvi Raj Meena, CIT-D.R
Section 115JSection 142(1)Section 143(1)Section 143(3)Section 263

facts has confirmed the additions of the Interest income amounting to 2,62,08,000/- treating the same as income from other sources. 3.0 The learned Commissioner of Income Tax (Appeals) NFAC erred in law and on facts has dismissed the ground relating to erroneous computation of total income ... Rs.1,61,31,26,000/- in respect of variation of subsidy/grant and addition of Rs. 20,79,52,000/- as against variation in income from other sources. 10. Aggrieved by the assessment order, the assessee filed appeal before the CIT(A). The CIT(A) partly allowed the appeal

Madhya Gujarat Vij Co. Ltd., Vadodara vs. The Dy.CIT, Circle-2(1)(2), Vadodara

In the result, the appeal being ITA No

ITA 109/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad30 May 2025AY 2017-18

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 109 & 110/Ahd/2025 Assessment Year 2017-18 & 2021-22

For Appellant: Shri M.K. Patel on behalf of Shri Parin Shah A.RFor Respondent: Shri Prathvi Raj Meena, CIT-D.R
Section 115JSection 142(1)Section 143(1)Section 143(3)Section 263

facts has confirmed the additions of the Interest income amounting to 2,62,08,000/- treating the same as income from other sources. 3.0 The learned Commissioner of Income Tax (Appeals) NFAC erred in law and on facts has dismissed the ground relating to erroneous computation of total income ... Rs.1,61,31,26,000/- in respect of variation of subsidy/grant and addition of Rs. 20,79,52,000/- as against variation in income from other sources. 10. Aggrieved by the assessment order, the assessee filed appeal before the CIT(A). The CIT(A) partly allowed the appeal