“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

Pandian Abilash, Chennai vs. ITO, Ncw-4(1), Chennai

In the result, appeal filed by the assessee is allowed

ITA 188/CHNY/2025[2015-16]Status: DisposedITAT Chennai05 May 2025AY 2015-16

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr.S. Kaarthick, AdvocateFor Respondent: Ms.Anitha, Addl.CIT

Section 148Section 271(1)(c)Section 44A

response to which, the assessee is noted to have filed RoI wherein the AO noted that the assessee has shown ‘income from other sources’ of Rs.3,12,240/- and didn’t disclose any ‘income from business & profession’. The AO noted that the total amount credited in his bank account

The Secondary Teachers Co-Operative Credit Society Limtied, Dharwad vs. Income Tax Officer, Ward-1(1), Hubli

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

ITA 2383/BANG/2024[2021-22]Status: DisposedITAT Bangalore05 May 2025AY 2021-22

Bench: Shri Waseem Ahmedassessment Year: 2021-22

For Appellant: Shri Atul Alur, AdvocateFor Respondent: Shri Ganesh R Gale, Standing Counsel for Dept

Section 57(2)Section 80PSection 80P(2)(a)Section 80P(2)(d)

claim of deduction to the extent . Page 3 of 6 of interest income of Rs. 1,72,339/- and treated the same income from other sources. 6. The aggrieved assessee preferred an appeal before the learned CIT(A)/NFAC. The assessee in the 1st grounds of appeal raised before

K.N.Krishnamurthy, Mumbai vs. Mum-W-(251)(93), Bengaluru

The appeal of the appellant is dismissed

ITA 5694/MUM/2024[2022-23]Status: DisposedITAT Mumbai05 May 2025AY 2022-23

Bench: Smt. Kavitha Rajagopal (Jm) & Shri Omkareshwar Chidara (Am) K.N. Krishnamurthy Ito 42(2)(3) I-15, Mahindra Park Mumbai. Narayan Nagar, Lbs Vs. Marg, Ghatkopar West Mumbai-400 086. Pan : Aaepk7294A Appellant Respondent

For Appellant: Shri Kiran UnavekarFor Respondent: Shri K.N. Krishamurthy

Section 234B

Bank account. The appellant himself argued the case in ITAT. 2. The only ground of appeal is reproduced for clarity : A.Y. 2022-23 “Income from other sources includes interest income from Bank savings accounts. The credit of interest amount in the savings accounts can be calculated only after the interest

Krishnagopal Tilakraj Kapoor, Ghatkopar East vs. Assisstant Commissioner of Income Tax, Grant Road

The appeal of the appellant is partly allowed as above for statistical purposes

ITA 1111/MUM/2024[2012-13]Status: DisposedITAT Mumbai05 May 2025AY 2012-13

Bench: Shri Sandeep Gosain (Jm) & Shri Omkareshwar Chidara (Am) Krishnagopal Tilakraj Kapoor Acit 14(2)(1) Flat No. 13, Plot No. 353 Matru Mandir Triveni Building, Vallabh Vs. Building Baugh Exten. Lane Grant Road Ghatkopar East Mumbai-400 Mumbai-400 077. 007. Pan : Aahpk0342G Appellant Respondent

For Appellant: Shri Krish DesaiFor Respondent: Shri Hemanshu Joshi

Section 14Section 14A

does not have any business income. The sources of income of appellant are –income from salary, income from house property, capital gains and income from other sources. The appellant has charged interest expenditure to his personal capital account and not claimed any expenditure in the profit and loss account –actually

Dy. Commissioner of Income Tax, Mumbai vs. Sbi Life Insurance Company Limited, Mumbai

In the result, the Revenue's appeal for the

ITA 4247/MUM/2023[2020-2021]Status: DisposedITAT Mumbai05 May 2025AY 2020-2021

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhail

For Appellant: Shri Farooq IraniFor Respondent: Dr. Kishor Dhule, CIT-DR

Section 10Section 10(34)Section 14ASection 250Section 44

defined u/s 2(228) viz. interest on securities and income accrued to and claimed exempt by assessee u/s 10(38) viz. dividend is 'income from other sources' under provisions of the Act." 4. "Whether the income claimed by assessee from business of insurance under section 44 of the Act read ... Schedule of the Act read with section 2(11) of Insurance Act, 1938 (4 of 1938) includes 'dividend income", 'income from house property', 'income from other sources' and income from capital gains' within the meaning of provisions of the IT Act, 1961" 5. "Whether the provisions of Section

Dy. Commisioner of Income Tax, Mumbai vs. Sbi Life Insurance Co. Ltd., Mumbai

In the result, the Revenue's appeal for the

ITA 4208/MUM/2023[2018]Status: DisposedITAT Mumbai05 May 2025

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhail

For Appellant: Shri Farooq IraniFor Respondent: Dr. Kishor Dhule, CIT-DR

Section 10Section 10(34)Section 14ASection 250Section 44

Dy. Commissioner of Income Tax, Mumbai, Income Tax Department, DCIT vs. Sbi Life Insurance Company Ltd., Mumbai

In the result, the Revenue's appeal for the

ITA 4185/MUM/2023[2019]Status: DisposedITAT Mumbai05 May 2025

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhail

For Appellant: Shri Farooq IraniFor Respondent: Dr. Kishor Dhule, CIT-DR

Section 10Section 10(34)Section 14ASection 250Section 44

DCIT-1(3)(1), Mumbai vs. Sbi Life Insurance Company Ltd., Mumbai

In the result, the Revenue's appeal for the

ITA 1428/MUM/2023[2017-18]Status: DisposedITAT Mumbai05 May 2025AY 2017-18

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhail

For Appellant: Shri Farooq IraniFor Respondent: Dr. Kishor Dhule, CIT-DR

Section 10Section 10(34)Section 14ASection 250Section 44

DCIT-1(3)(1), Mumbai vs. Sbi Life Insurance Company Ltd., Mumbai

In the result, the Revenue's appeal for the

ITA 1427/MUM/2023[2016-17]Status: DisposedITAT Mumbai05 May 2025AY 2016-17

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhail

For Appellant: Shri Farooq IraniFor Respondent: Dr. Kishor Dhule, CIT-DR

Section 10Section 10(34)Section 14ASection 250Section 44

DCIT-1(3)(1), Mumbai vs. M/S Sbi Life Insurance Co. Ltd, Mumbai

In the result, the Revenue's appeal for the

ITA 1392/MUM/2023[2015-16]Status: DisposedITAT Mumbai05 May 2025AY 2015-16

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhail

For Appellant: Shri Farooq IraniFor Respondent: Dr. Kishor Dhule, CIT-DR

Section 10Section 10(34)Section 14ASection 250Section 44

Rajesh Kumar Jaiswal, Allahabad vs. Deputy/ACIT(Central), Allahabad

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

ITA 16/ALLD/2023[2018-19]Status: DisposedITAT Allahabad02 May 2025AY 2018-19

Bench: the query raised by the assessing authority vide questionnaire issued under section 142 (1) dated 23.01.2021, in assessment proceedings for the AY 2018-19.

For Appellant: Sh. Nikhil Agarwal & Ms. VidishaFor Respondent: Sh. A.K. Singh, Sr. DR

Section 115Section 115BSection 142Section 24Section 250Section 68Section 69

Rs.1,62,63,120/- of which business income of Rs.1,12,95,684/-, income from house property of Rs.25,86,697/- and income from other sources of Rs.25,11,693/- were disclosed. The case was subsequently taken up for scrutiny. During the course of assessment, the ld. AO observed that ... section 115BBE. The ld. Sr. DR further submitted that the assessee says that he had explained the sources from undisclosed business income / rental income. But the source did not mean the head of income. He submitted that the details of disclosure had to include the source from which the black

Shree Samprat Coop Hsg Soc Limited, Ahmedabad vs. Income Tax Officer Ward 3(3)(5), Ahmedabad

The appeal of the assessee is allowed for statistical

ITA 470/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad01 May 2025AY 2017-18

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokar

For Appellant: Shri Prashant Shrivastav, ARFor Respondent: Ms.Bhavnasingh Gupta, Sr.DR

Section 142(1)Section 143(2)Section 143(3)Section 57

that the assessee had received interest income of Rs.12,95,860/- on fixed deposits made with banks, which was offered under the head "Income from Other Sources". The assessee claimed deduction of Rs.38,15,283/- under section 57, comprising various maintenance and administrative expenses. The AO held that no expenditure

Kuljeet Singh, Gurgaon vs. ITO, Ward 2(2), Gurgaon

The appeal of the assessee is dismissed

ITA 2981/DEL/2023[2018-19]Status: DisposedITAT Delhi01 May 2025AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year: 2018-19 Kuljeet Singh, Vs Ito, C/O Ca R.S. Poonia, Ward-2(2), D-82-B, Siwad Area, Gurgaon. Krishna Marg, Bapu Nagar, Jaipur – 302015, Rajasthan. Pan: Cphps3205R (Appellant) (Respondent) Assessee By : None Revenue By : Shri Om Prakash, Sr. Dr Date Of Hearing : 01.05.2025 Date Of Pronouncement : 01.05.2025 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Assessee Against The Order Dated 31.08.2023 Of The Commissioner Of Income-Tax (Appeals), Nfac, Delhi (Hereinafter Referred To As The Ld. First Appellate Authority Or ‘The Ld. Faa’, For Short) In Appeal No.Nfac/2017-18/10040192 Arising Out Of The Appeal Before It Against The Order Dated 17.03.2021 Passed U/S 143(3) R.W.S. 143(3A) & 143(3B) Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) By The National Assessment Centre, Delhi (Hereinafter Referred To As The Ld. Ao).

For Appellant: NoneFor Respondent: Shri Om Prakash, Sr. DR

Section 10Section 10(37)Section 143(3)

basis of interest earned by way of enhanced compensation out of compulsory acquisition of agricultural land which the tax authorities have considered as ‘Income from other sources’. In this regard, we find that the Hon’ble P&H, High Court in the case Mahindra Pal Narang vs. CBDT ... 145B of the Income Tax Act and the plea of assessee that interest received on enhanced compensation shall not be assessed as income from other sources in the year in which it is received. Special leave petition against this decision has been dismissed by the Hon’ble Supreme Court

Shri Nidhi Credit Co-Oprative Society Limited, Rajkot vs. ITO 3(1)(1), Rajkot

In the result, appeal filed by the assessee is allowed

ITA 936/RJT/2024[2014-2015]Status: DisposedITAT Rajkot30 Apr 2025AY 2014-2015

Bench: Dr. Arjun Lal Saini, Am. & Shr Dinesh Mohan Sinha, Jm आयकर अपील सं./Ita No.936/Rjt/2024 "नधा"रण वष" / Assessment Year: (2014-15)

For Appellant: Shri J.R. Mankodi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)

Section 142(1)Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)

paper book),and the amount of Rs.18,41,436/- is show by the assessee, in the computation of total income, under the head income from other sources, and claimed the deduction u/s 80P(2)(d) of the Act, at Rs.18,41,436/-. The assessee has also shown, under the head ... income from other sources, amount of Rs.52,350/-, as dividend received from Co-operative Bank and claimed the deduction u/s 80P(2)(d) of the Act. ITA No.936/Rjt/2024 A.Y. 14-15 Sh.Nidhi Credit Co-Op Society Ltd. 24. During the course of hearing, ld Counsel for the assessee, clarified

Shiv Green Energy Private Limited, Jamnagar vs. Principal Commissioner of Income Tax, Jamnagar

In the result, appeals filed by the assessees(ITA No

ITA 595/RJT/2024[2018-19]Status: DisposedITAT Rajkot30 Apr 2025AY 2018-19

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 595/Rjt/2024 "नधा"रणवष" / Assessment Year: (2018-19) (Hybrid Hearing) Shiv Green Energy Pvt. Ltd. Vs. The Principal Commissioner Of Income Tax, 107, Divyam Park, Jamnagar 361001 Opp. H.O. Bhatt Bunglow, Nr. Sanjeevani Medical Store, Jamnagar - 361006 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aascs8645J (Appellant) (Respondent)

For Appellant: Shri Mahesh Paun, Ld. ARFor Respondent: ShriSanjay Pungalia, Ld. CIT. (DR)

Section 143(3)Section 263

been realized, the department cannot take a U turn while framing the assessment of the assessee by taxing the same under the head income from other sources under section 69, 69A and 69B. It has to be assessed under the Head Income from Business. We have explained the source

Ashok Gopaldas Vithlani, Jamkhambhaliya vs. Principal Commissioner of Income Tax, Jamnagar

In the result, appeals filed by the assessees(ITA No

ITA 229/RJT/2024[2017-18]Status: DisposedITAT Rajkot30 Apr 2025AY 2017-18

For Appellant: Shri Mahesh Paun, Ld. ARFor Respondent: ShriSanjay Pungalia, Ld. CIT. (DR)

Section 143(3)Section 263

Asharaf, Mannanchery vs. Income Tax Officer, Alappuzha

In the result, the appeal filed by the assessee stands partly allowed

ITA 235/COCH/2025[2017-2018]Status: DisposedITAT Cochin30 Apr 2025AY 2017-2018

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2017-18 Asharaf .......... Appellant Bismillah Manzil, Mannancherry, Alappuzha 688538 [Pan: Bagpa7886R] Vs. The Income Tax Officer .......... Respondent Ward -1 & Tps, Alappuzha

For Appellant: Shri Bijumon Antony, CAFor Respondent: Smt. Leena Lal, Sr. D.R

Section 139(1)Section 142(1)Section 144Section 44A

hereby confirmed. However, having estimated the income u/s. 44AD, no addition is required to be made under the head ‘income from other sources’. Therefore, I direct the AO to delete the addition of Rs. 3,93,000/- made on account of cash deposits. 8. In the result, the appeal filed

M/S Co-Operative Cane Development Union Gola, Lakhimpur Kheri vs. Income Tax Officer Range-3(4), Lakhimpur Kheri-1

ITA 15/LKW/2023[AY 2018-19]Status: DisposedITAT Lucknow30 Apr 2025

Bench: Sh. Kul Bharat & Sh. Nikhil Choudhary

For Appellant: Sh. Shubham Rastogi, C.AFor Respondent: Sh. Sanjeev Krishna Sharma, Addl CIT DR

Section 80P

same could not be said to be attributable to the activities of the society and would come in the category of, “income from other sources” and should therefore, be taxed accordingly under section 56 of the Act, in view of the decision of the Hon’ble Supreme Court ... Cooperative Credit Society, the interest therefrom could not be regarded as income attributable to business but would in fact be regarded as income from other sources. He noted that the Hon’ble Allahabad High Court in the said case had 7 ITA No.37/LKW/2022, ITA No.15/Lkw/2023 & ITA No.394/ Lkw/2019 M/s Cooperative

M/S Co-Operative Cane Development Union Ltd, Lakhimpur Kheri vs. Income Tax Officer -1, Range-3(4), Lakhimpur Kheri

ITA 37/LKW/2022[2017-2018]Status: DisposedITAT Lucknow30 Apr 2025AY 2017-2018

Bench: Sh. Kul Bharat & Sh. Nikhil Choudhary

For Appellant: Sh. Shubham Rastogi, C.AFor Respondent: Sh. Sanjeev Krishna Sharma, Addl CIT DR

Section 80P

M/S Co-Operative Cane Development Union Ltd., Lakhimpur-Kheri vs. Income Tax Officer-I, Lakhimpur -Kheri

ITA 394/LKW/2019[2016-17]Status: DisposedITAT Lucknow30 Apr 2025AY 2016-17

Bench: Sh. Kul Bharat & Sh. Nikhil Choudhary

For Appellant: Revenue byFor Respondent: Date of hearing

Section 80P

same could not be said to be attributable to the activities of the society and would come in the category of, "income from other sources" and should therefore, be taxed accordingly under section 56 of the Act, in view of the decision of the Hon'ble Supreme Court ... Cooperative Credit Society, the interest therefrom could not be regarded as income attributable to business but would in fact be regarded as income from other sources. He noted that the Hon'ble Allahabad High Court in the said case had pointed out that the assessee was a Cooperative Cane Development