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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

Nik Family Trust, Mumbai vs. Deputy Commissioner of Income Tax- Circle 23(1), Mumbai

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 403/MUM/2025[2021-22]Status: DisposedITAT Mumbai08 May 2025AY 2021-22

Bench: Hon’Ble Shri Sandeep Gosainnik Family Trust Vs. Dcit, Circle – 23(1) C-7, Ishwar Niwas Sick Piramal Chamber. Nagar, Vp Raod, Girgaon. Pan/Gir No. Aadtn2244C (Applicant) (Respondent) Assessee By Shri Dharan Gandhi A/W Shri Ashutosh Patare Revenue By Shri Avinash Karpe, Sr. Dr Date Of Hearing 01.05.2025 Date Of Pronouncement 08.05.2025 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order 24.12.2024 Passed U/S 250 Of The Income Tax Act, 1961 (‘The Act’), By The National Faceless Appeal Centre, Delhi (Nfac) For The Assessment Year 2021-22. 2. The Only Effective Issue Raised In The Present Appeal Regarding Levying Of Surcharge. In This Regard It Is Submitted That Assessee Is A Discretionary Trust, Eligible To File Return In Itr-5, The Assessee Had Filed Its Return Of 2 Nik Family Trust, Mumbai

Section 143(1)Section 164Section 2Section 2(1)Section 250

return of 2 NIK Family Trust, Mumbai income for the year under consideration declaring income of Rs. 32,57,110/- consisting of income from other sources and capital gains. However, in the intimation u/s 143(1) of the Act, surcharge has been charged even though total income of the assessee

Horizon Dream Homes Private Limited, Mumbai vs. Assisstant Commissioner 12(2)(2), Mumbai

In the result the appeal filed by the assessee is partly

ITA 5934/MUM/2024[2011-12]Status: DisposedITAT Mumbai08 May 2025AY 2011-12

Bench: Shri Vikram Singh Yadav & Shri Raj Kumar Chauhan

Section 14Section 143(1)Section 143(2)Section 143(3)Section 148Section 154Section 156Section 68

unsecured loans amounting to Rs.11,36,500/- and commission on sham transaction on unsecured loans amounting to Rs.362,592/- under the head “income from other sources and assessed income was determined at Rs.2,56,71,892/- wherein tax @30% was levied amounting to Rs.77 ... good self has in Para 9 of the assessment order assessed the income unsecured loan u/s.68 amounting to Rs.2,41,72,800 under Income From Other Sources. The said loans were taken for the purpose of business & were also utilized for the purpose of business. Your good self has disallowed

Dropti Devi, Behror vs. Income Tax Officer, Ward 1(3), Alawar, Alwar

In the result, the appeal of the assessee is partly allowed

ITA 1223/JPR/2024[2011-12]Status: DisposedITAT Jaipur07 May 2025AY 2011-12

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Vedant Agarwal, AdvocateFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR
Section 139(1)Section 142(1)Section 147Section 148Section 194ASection 250

shown u/s 44AD not explained, Rs. 15,53,500/- on account of unexplained cash deposit in bank and Rs. 16,469/- on account income from other sources and assessed the total income at Rs. 17,58,520/-. Aggrieved by the order of AO, the assessee preferred an appeal before

Chandrakant Viththal Bhopi, Raigad vs. ITO Ward 1, Panvel

In the result, the appeal filed by the assessee is allowed

ITA 2405/PUN/2024[2016-17]Status: DisposedITAT Pune07 May 2025AY 2016-17

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2016-17 Chandrakant Viththal Bhopi Ito, Ward-1, Panvel At Chinchpada, Post Panvel, Tal. Vs. Panvel, Dist. Raigad – 410206 Pan: Bjdpb7610L (Appellant) (Respondent) Assessee By : Shri Nikhil S Pathak & Ajinkya M Vaishampayan Department By : Shri Ramnath P Murkunde Date Of Hearing : 05-05-2025 Date Of Pronouncement : 07-05-2025 O R D E R

For Appellant: Shri Nikhil S Pathak &For Respondent: Shri Ramnath P Murkunde
Section 11Section 142(1)Section 147Section 148Section 148ASection 151Section 2(14)Section 28Section 56(2)(viii)

Form 4 26AS Therefore, the entire amount of interest received by the assessee is found to be taxable in assessee's hands, as income from other sources. Secondly, it is pointed out assessee is not eligible for deduction u/s 10(37) as the said deduction applies only to capital gains ... Rs.1,30,02,544/- is treated as deduction and the balance amount of Rs.1,30,02,544/- is hereby to be treated as income from other sources. Penalty proceedings u/s 271(1)(c) are initiated separately for concealment of income.‖ 7. In appeal, the Ld. CIT(A) / NFAC upheld

Contai Rotary Community Welfare Trust, Meinipur vs. I.T.O., Ward 1(1), Exemption, Kolkata

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

ITA 52/KOL/2025[2018-19]Status: DisposedITAT Kolkata07 May 2025AY 2018-19

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarmai.T.A. No.52/Kol/2025 Assessment Year: 2018-19 Contai Rotary Community Welfare Trust………………………..………….……Appellant Rathtala, P.O. Contai, Dist. Purba Medinipur, W.B. – 721401. [Pan: Aaatc7008C] Vs. Ito, Ward-1(1), Exemption, Kolkata…..……....….….. ……………….........…..Respondent Appearances By: Shri Miraj D. Shah, Ar, Appeared On Behalf Of The Appellant. Shri Raja Sengupta, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : May 06, 2025 Date Of Pronouncing The Order : May 07, 2025 Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 08.11.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Is A Charitable Trust & Registered U/S 12A Of The Act. The Assessee Filed Its Return Of Income For The Assessment Year 2018-19 By Declaring Nil Income Which Was Processed U/S 143(1) Of The Act. Subsequently, The Case Of The Assessee Was Selected For Scrutiny Under Cass To Examine Certain Issues Particularly The Expenses Claimed Under The Head Of ‘Income From Other Sources’. Notice U/S 143(2) Of The Act Was Issued To The Assessee Requiring Submission Of Certain Documents But No Response Was Received. Thereafter, A Notice U/S 142(1) Of The Act Was Issued Calling For Details Of Expenses Claimed U/S 57 Of The Act But The Assessee Again Failed To Respond. Thereafter, The Assessing Officer Issued Reminder To

Section 12ASection 142(1)Section 143(1)Section 143(2)Section 144Section 250Section 57

case of the assessee was selected for scrutiny under CASS to examine certain issues particularly the expenses claimed under the head of ‘income from other sources’. Notice u/s 143(2) of the Act was issued to the assessee requiring submission of certain documents but no response was received. Thereafter ... under the best judgment provision u/s 144 of the Act. While framing the assessment order, the Assessing Officer noted that the assessee declared income from various sources which are as under: Interest from S.B A/c 1,374 Registration charges 22,91,714 Incentive 1,750 Honorarium to Doctor

Dhatrigram Niralgachi Samabay Krishi Unnayan Samity Limited, West Bengal, Purba Bardhaman vs. Income Tax Officer, Ward-1(3), Burdwan

Appeal of the assessee is allowed

ITA 2557/KOL/2024[2017-18]Status: DisposedITAT Kolkata07 May 2025AY 2017-18

Bench: SHRI PRADIP KUMAR CHOUBEY, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 250Section 80P

bank is income from Business or Profession. Learned Commissioner of Income Tax (Appeals), Income Tax Department considers interest received from Axis bank as income from other sources based on the judgment delivered by Hon'ble Apex Court in the case of the Totgar's Co-operative Sale Society

K. Venkatesan (HUF), Salem vs. ACIT, Circle 1(1) Salem, Salem

Appeal of the assessee is allowed

ITA 2945/CHNY/2024[2023-24]Status: DisposedITAT Chennai07 May 2025AY 2023-24

Bench: Shri Manu Kumar Giri & Shri Jagadish

For Appellant: Mr. P.M. Kathir, AdvocateFor Respondent: Mr. P.Vijaideepan, JCIT
Section 10(37)Section 143(1)Section 143(1)(a)Section 194I

said transaction. The assessee filed return of income for AY 2023-24 declaring income from house property of Rs.8,40,000/-, income from other sources (interest income) of Rs.3,82,524/- and agricultural income of Rs.4,13,150/-. The assessee had not shown any capital gains on the sale

D L Tanumal Private Limited, Mumbai vs. PCIT -4, Mumbai

In the result, appeal of the assessee is allowed

ITA 2564/MUM/2025[2014-15]Status: DisposedITAT Mumbai07 May 2025AY 2014-15

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri Madhur Agrawal & Mr. Hitesh Trivedi, A/RFor Respondent: Smt. Sanyogita Nagpal, CIT D/R
Section 147Section 154Section 263Section 68

However, while computing the total income, the AO has not reduced the amount from the business income and also added the same as income from other sources resulting into double taxation of the said income. 6.1. The contention of the assessee was accepted by the AO, who vide order dated

Assistant Commissioner of Income Tax, Circle-1(1), Vijayawada vs. The Krishna District Milk Producers Mutually Aided Co Op Union Limited, Vijayawada

In the result, appeal of the revenue is dismissed

ITA 370/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam06 May 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Hon’Ble

Section 133(6)Section 143(2)Section 143(3)Section 68Section 80P(2)(d)

that the interest income earned on investment of surplus funds which are not immediately required for business purposes, is taxable under the head ‘Income from Other Sources’. 5. Any other ground that may be urged at the time of appeal hearing.” 5. Ground Nos. 1 & 5 are general in nature

Amit Meharda, Jaipur vs. ACIT, Circle 6, Jaipur

In the result, the appeal of the assessee is allowed

ITA 380/JPR/2025[2016-17]Status: DisposedITAT Jaipur06 May 2025AY 2016-17
For Appellant: Shri Mukesh Khandelwal, CAFor Respondent: Shri Gautam Singh Choudhary
Section 142(1)Section 69A

assessee by observing as under:- "The rival submissions are considered. It is found that the appellant had declared income from house property and income from other source being interest from bank during the year, therefore the necessity of maintaining cash book is not there. However, there was substantial amount ... following written submission; Written Submissions May it please yourhonour, Brief facts of the case :- The appellant earns income from rent and income from other sources during the year under consideration. He had filed his ITR for the relevant assessment year on 19.03.2018 vide e filing acknowledgment no. 462520430190318 declaring

V R Auto Services, Nashik vs. ACIT, Circle 1, Nashik

In the result, appeal of the assessee is allowed

ITA 42/PUN/2025[2017-18]Status: DisposedITAT Pune06 May 2025AY 2017-18

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.42/Pun/2025 Assessment Year : 2017-18

For Appellant: Shri Pramod ShingteFor Respondent: Shri Ganesh B Budruk
Section 115BSection 143Section 250Section 69A

Cash balance as on 08/11/2016 of Rs. 6,32,731/-) is brought to tax under the head Income from other sources as unexplained cash u/s. 68 and tax rates applicable as per provisions of section 115BBE of the Act. 3.11 From the above it is clear that the assessee

Sunil Hari Bendale, Jalgaon vs. Deputy Commissioner of Income Tax, CPC, Bengaluru

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

ITA 1570/PUN/2024[2017-18]Status: DisposedITAT Pune06 May 2025AY 2017-18

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1570/Pun/2024 धििाारण वषा / Assessment Year: 2017-2018 Vs Dcit, Cpc, Sunil Hari Bendale, At Post Sangvi, Yawal, Bengaluru Jalgaon-425326 Maharashtra Pan-Bpepb8394E Appellant Respondent

For Appellant: Rohan PathakFor Respondent: Mrs. Indira Adakil
Section 143(1)Section 143(1)(A)Section 154Section 44A

upholding the assessment for AY 2017-18, which incorrectly treated the appellant's entire (100%) contract receipts of Rs. 845,000 as "Income from Other Sources" instead of business income, and in failing to consider the associated business expenses and actual profit margins in determining the taxable income ... presumptive taxation basis @ 8.12% of the gross receipts of Rs. 8,45,000/- The assessee inadvertently declared the income under the Head Income from other sources. However 3 the CPC made the addition of total gross receipts of Rs. 8,45,000/- and treated it as total income. 5. Further

ACIT, Central Circle-3(1), Hyderabad vs. Sri Chaitanya Educational Committe, Vijayawada

In the result, the appeal filed by the Revenue is dismissed

ITA 325/HYD/2023[2012-13]Status: DisposedITAT Hyderabad06 May 2025AY 2012-13

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: Shri AV Raghuram, AdvocateFor Respondent: MS. M. Narmada, CIT-DR
Section 11Section 12Section 12ASection 13(1)(c)Section 13(3)

there are four heads of income viz., 'salaries', income from house property', 'profits and gains of business or profession' and capital gains and income from other sources. In the instant case considering the activity of the assessee the other income which has to be taxed at normal rates

M/S. La Opala RG Ltd., Kolkata vs. D.C.I.T., Circle - 11(1), Kolkata

ITA 1891/KOL/2024[2017-2018]Status: DisposedITAT Kolkata06 May 2025AY 2017-2018

Bench: Shri Pradip Kumar Choubey & Shri Sanjay Awasthi

For Appellant: Shri A. K. Tulsyan, FCAFor Respondent: Smt. Monalisha Pal Mukherjee, JCIT, Sr. DR
Section 250Section 80ISection 80l

IN THE INCOME TAX APPELLATE TRIBUNAL “B BENCH KOLKATA BEFORE SHRI PRADIP KUMAR CHOUBEY, JUDICIAL MEMBER AND SHRI SANJAY AWASTHI

Evershine No II Co-Op Hsg So Limited, Mumbai vs. ITO Ward 25(1)(1), Mumbai

The appeal of the appellant is allowed

ITA 819/MUM/2025[2014-15]Status: DisposedITAT Mumbai06 May 2025AY 2014-15

Bench: Smt. Beena Pillai, Jm & Shri Omkareshwar Chidara, Am

For Appellant: Shri Bhupendra ShahFor Respondent: Shri Pravin Salukhe
Section 143(1)Section 154Section 234ASection 80P(2)(d)

granting deduction u/s 80P(2)(d) amounting to Rs. 4,55,531/- thereby passing rectification order u/s 154 by way of income from other sources in respect of interest earned on fixed deposit from/with Co-operative banks by also overlooking the fact that debatable addition cannot be sustained ... granting deduction u/s 80P(2)(d) amounting to Rs. 4,55,531/- thereby passing rectification order u/s 154 by way of income from other sources in respect of interest earned on fixed deposit from/with Co-operative banks thereby 2 Evershine No. II Cooperative Housing Society Limited rejecting case laws

Md. Shanawaj Rizwi, Purnea vs. ACIT, CC-2, Patna

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 560/PAT/2024[2017-18]Status: DisposedITAT Patna05 May 2025AY 2017-18

Bench: The Ld. Cit(A) Where Also He Could Not Succeed & The Addition Was Confirmed.

Section 133Section 147Section 148Section 250Section 56(2)(vii)

between actual consideration Rs.60.00 Lacs and the stamp value Rs. 75.00 Lacs of immovable assets 3acre land at Marocha Ujiyarpur, Purnea, is treated income from other sources in view of provisions of section 56(2)(vii)(b)(ii) of I.T. Act 1961, therefore the addition is upheld and accordingly

Shashi Prabha Singhania, Neemuch vs. Income-Tax Officer Neemuch, Neemuch

ITA 800/IND/2024[2018-19]Status: DisposedITAT Indore05 May 2025AY 2018-19

Bench: Bhagirath Mal Biyani & Shri Paresh M Joshi

Section 142(1)Section 143(2)Section 250Section 253Section 44ASection 80CSection 80D

आयकर अपीलीय अधिकरण, इंदौर न्यायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE BHAGIRATH MAL BIYANI, ACCOUNTANT

Institute Management Committee Iti Jhalawar, Jhalawar vs. ITO Ward Jhalawar, Jhalawar

The appeals of the assessee are hereby allowed

ITA 41/JPR/2025[2014-15]Status: DisposedITAT Jaipur05 May 2025AY 2014-15

Bench: Moving Towards The Facts Of The Case We Would Like To Mention That The Assessee In This Appeal Has Raised The Following Grounds;

For Appellant: Sh. Shrawan Kumar Gupta, AdvFor Respondent: Sh. Gautam Singh Choudhary, JCIT
Section 10Section 144Section 147Section 151Section 234

assessee filed a return of income declaring nil income after claiming exemption u/s.10. During the year, the assessee is in receipt of Income from other sources of Rs 28,50,637/- and the same was claimed exempt u/s.10 of the Act. By virtue of section 139(4C) every educational institution ... u/s10 of the IT Act, 1961. As per the assessment order, during the relevant year, the appellant had received Rs.28,50,637/- as Income from other sources and the same was claimed as exempt income u/s 10 of the IT Act, 1961. As per the assessment order, the appellant

Institute Management Committee Iti Jhalawar, Jhalawar vs. ITO Ward Jhalawar, Jhalawar

The appeals of the assessee are hereby allowed

ITA 39/JPR/2025[2013-14]Status: DisposedITAT Jaipur05 May 2025AY 2013-14

Bench: Moving Towards The Facts Of The Case We Would Like To Mention That The Assessee In This Appeal Has Raised The Following Grounds;

For Appellant: Sh. Shrawan Kumar Gupta, AdvFor Respondent: Sh. Gautam Singh Choudhary, JCIT
Section 10Section 144Section 147Section 151Section 234

assessee filed a return of income declaring nil income after claiming exemption u/s.10. During the year, the assessee is in receipt of Income from other sources of Rs 28,50,637/- and the same was claimed exempt u/s.10 of the Act. By virtue of section 139(4C) every educational institution ... u/s10 of the IT Act, 1961. As per the assessment order, during the relevant year, the appellant had received Rs.28,50,637/- as Income from other sources and the same was claimed as exempt income u/s 10 of the IT Act, 1961. As per the assessment order, the appellant

Mahadeo Krishna Baad, Kolhapur vs. Income Tax Officer, Circle 1, Kolhapur, Aayakar Bhavan

In the result, appeal of the assessee is partly allowed

ITA 519/PUN/2025[2015-16]Status: DisposedITAT Pune05 May 2025AY 2015-16

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.519/Pun/2025 िनधा"रण वष" / Assessment Year: 2015-16 Mahadeo Krishna Baad, V The Income Tax Officer, 596, E-Ward, Parag S Circle-1, Kolhapur. Commercial Arcade, B.J.Chowk, Shahupuri, Kolhapur – 416001. Pan: Aaspb2495A Appellant/ Assessee Respondent / Revenue Assessee By Shri Deepak S. Sasar – Ca & Shri Arpit D. Dambhare – Ca Revenue By Shri Harish Bist – Addl.Cit(Dr) Date Of Hearing 02/04/2025 Date Of Pronouncement 05/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961; Dated 07.11.2024For Assessment Year 2015-16. The Assessee Has Raised The Following Grounds Of Appeal :

Section 145(3)Section 250

CASE AND IN LAW THE LD. ASSESSING OFFICER AND THE HON, COMMISSIONER OF INCOME TAX (APPEALS) ERRED IN CONFIRMING THE ADDITION MADE UNDER INCOME FROM OTHER SOURCES WITHOUT SPECIFYING PARTICULAR SECTION OF THE INCOME TAX ACT 1961. 4. IN THE FACTS AND CIRCUMSTANCES OF THE CASE THE LD. ASSESSING OFFICER ... correctness of the business income from trading in tyres and providing vehicle services, there was no basis to assess the agricultural income as income from other sources. 4.2. It is noted that the appellant claimed to have realised Rs.45,85,500 as gross receipts from the sale of agricultural produce