“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, Ballari vs. Ms Al Badar Educational and Charitable Trust, Ballari

In the result, the appeals of the revenue are allowed and the

ITA 1483/BANG/2024[2017-18]Status: DisposedITAT Bangalore22 Apr 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Prakash Chand Yadav

Section 12ASection 133ASection 143(1)Section 164(2)

assessee is carrying out charitable activity in the field of education by running a Dental Science College and is also having income from other sources. For the AY 2016-17 assessee has filed return of income on 29.9.2016. The same was processed u/s. 143(1) of the Act. Thereafter

Al-Badar Educational and Charitable Trust, Kalaburagi vs. Deputy Commissioner of Income Tax, Central Circle, Bellary

In the result, the appeals of the revenue are allowed and the

ITA 1410/BANG/2024[2016-17]Status: DisposedITAT Bangalore22 Apr 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Prakash Chand Yadav

Section 12ASection 133ASection 143(1)Section 164(2)

Amarjit Singh HUF, Baghapurana, Moga vs. ITO Ward 1, Moga

In the result, the appeal of the assessee bearing ITA Nos

ITA 307/ASR/2024[2020-21]Status: DisposedITAT Amritsar21 Apr 2025AY 2020-21

Bench: Manoj Kumar Aggarwal & Sh. Udayan Das Gupta

Section 143(3)Section 144BSection 250Section 270A

Faceless Appeal Centre has erred in upholding the addition made by AO amounting to Rs. 15,00,000/- treating the agricultural income as income from other sources. 4. That on the facts and circumstances of the case the CIT(A) NFAC, has erred in confirming the addition, as there

The Barnala Primary Cooperative Agricultural Development Bank Limited, Barnala vs. Income Tax Officer, Barnala

The appeal stand allowed in terms of our above order

ITA 983/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh21 Apr 2025AY 2020-21

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.983/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2020-21) The Barnala Primary Cooperative Ito Agricultural Development Bank Ltd. Barnala 148101. बनाम/ Vs. Dhanaula Road Opp. Pspcl Office, Barnala.148001. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaaat-4569-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Deepak Aggarwal(Adv.) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 02-04-2025 घोषणाकीतारीख /Date Of Pronouncement : 21-04-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2020-21 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] Dated 05-08-2024 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S. 143(3) Of The Act On 21-09-2022. The Sole Grievance Of The Assessee Is Rejection Of Claim U/S 80P(2)(A)(I) For Rs.168.23 Lacs. Having Heard Rival Submissions & Upon Perusal Of Case Records, The Appeal Is Disposed-Off As Under.

For Appellant: Sh. Deepak Aggarwal(Adv.) – Ld. ARFor Respondent: Smt. Kusum Bansal (CIT) – Ld. DR

Section 143(3)Section 5Section 80P(2)(a)

society engaged in the business of banking or providing credit facilities to its members. The Ld. AO also held that the assessee has income from other sources from Rs.132.36 Lacs in the shape of interest on deposits from bank, commission income, dividend income and interest on investment. Finally, the deduction

Mr. Ashwin Rajendra Bade, Kolhapur vs. Assistant Commissioner of Income-Tax, Central Circle, Kolhapur

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

ITA 1892/PUN/2024[2019-20]Status: DisposedITAT Pune21 Apr 2025AY 2019-20

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita. No.1892/Pun/2024 Assessment Year : 2019-20

For Appellant: Shri Bhuvanesh KankaniFor Respondent: Shri Ramnath Murkunde

Section 115BSection 133ASection 142(1)Section 143(2)Section 143(3)Section 250Section 271ASection 69A

course of assessment proceedings, ld. AO observed that the assessee has himself admitted and offered the additional income declared under the head ‘Income from other sources’ in his computation statement and paid due taxes. The observation of ld. AO summarizing the assessment reads as under : “1. The assessee accepted ... capital by the above amount. This is self admission. Sec.69A clearly applies. The assessee himself shown the additional income under the head "income from other sources' in his computation of income. He has not included the additional income in P&L account. 2 The assessee did not offer any explanation

Income Tax Officer, Ward-1, Ichalkaranji vs. Sanjay Ghodawat Buildcon LLP, Chipri

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

ITA 1337/PUN/2024[2015-16]Status: DisposedITAT Pune21 Apr 2025AY 2015-16

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1337/Pun/2024 Assessment Year : 2015-16

For Appellant: Shri Arvind DesaiFor Respondent: Shri Prashanth GS

Section 142(1)Section 144Section 263Section 40Section 46A(3)Section 57

erred in directing the JAO to consider the plea of the assessee for deduction u/s 57 of the Act and re-compute the income from other source. 2. On the facts and in the circumstances of the case and in law, the Ld. CIT (Appeals) erred in ignoring the fact ... that addition of interest income of Rs.4.90.58.992/- under the head income from other sources 2 Sanjay Ghodawat Buildcon LLP was made by the AO only after providing opportunity to the assessee and considering all the facts of the case. 3. On the facts and in the circumstances of the case

Dy. Commissioner of Income Tax, Circle-1(1), Hyderabad vs. Union Bank of India, Hyderabad

In the result, the appeal of revenue is partly allowed for statistical

ITA 316/HYD/2019[2015-16]Status: DisposedITAT Hyderabad21 Apr 2025AY 2015-16

For Appellant: Shri S. Ananthan, C.A. &For Respondent: Ms. M Narmada, CIT-DR

Section 143(3)Section 14ASection 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)Section 36(1)(vila)

that the issue was as to whether income by way of interest on securities shall be chargeable to income tax under the head ‘income from other sources' or it is to fall under the head ‘profits and gains of business and profession'. The Board, going by the decision of this

Union Bank of India (Erstwhile-Andhra Bank), Mumbai vs. Dy. Commissioner of Income Tax, Circle-1(1), Hyderabad

In the result, the appeal of revenue is partly allowed for statistical purposes

ITA 193/HYD/2019[2015-16]Status: DisposedITAT Hyderabad21 Apr 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri S. Ananthan, C.A. &For Respondent: Ms. M Narmada, CIT-DR

Section 143(3)Section 14ASection 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)Section 36(1)(vila)

that the issue was as to whether income by way of interest on securities shall be chargeable to income tax under the head ‘income from other sources’ or it is to fall under the head ‘profits and gains of business and profession’. The Board, going by the decision of this

ITO Ward-46(1), Kolkata vs. Aloke Kumar Banerjee, Howrah

In the result, appeal of the revenue is dismissed

ITA 861/KOL/2024[2011-12]Status: DisposedITAT Kolkata21 Apr 2025AY 2011-12

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyआयकर अपील सं/Ita No.861/Kol/2024 (नििाारण वर्ा / Assessment Year : 2011-2012) Ito, Ward-46(1), Kolkata Vs Aloke Kumar Banerjee, Unit No.A/08/05, Kolkata West International City, Howrah Amta Road & Bombay Road Crossing Salap More, Howrah-711409 Pan No. :Ailpb 4570 D (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri Anuj Musaddi, Ar राजस्व की ओर से /Revenue By : Shri Sailen Samadder, Addl. Cit-Sr. Dr सुनवाई की तारीख / Date Of Hearing : 20/02/2025 घोषणा की तारीख/Date Of Pronouncement : 21/04/2025 आदेश / O R D E R Per Rajesh Kumar, Am : This Is An Appeal Filed By The Revenue Against The Order Dated 15.02.2024 Passed By The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, For The Assessment Year 2011-2012, On The Following Grounds :- 1. Whether On The Facts & Circumstances Of The Case, The Ld Cit(A) Was Right In Law As Well As On Facts In Deleting The Addition Of Rs. 2,87,12,120/- As Unexplained Cash Deposited In Bank Accounts Without Considering The Facts That The Asseseee Failed To Reconcile The Cash Deposit Of Rs. 2,87,12,210/-. 2. Whether On The Facts & Circumstances Of The Case, The Ld Cit(A) Was Right In Law As Well As On Facts In Deleting The Addition Of Rs. 1,71,925 As Difference In Capital Account As Unexplained Cash Credit Into Books Of Assesee U/S 68 Of The It Act, Without Considering The Facts That The Difference Of Rs. 171925/- Could Not Be Explained By The Assessee.

For Appellant: Shri Anuj Musaddi, ARFor Respondent: Shri Sailen Samadder, Addl. CIT-Sr. DR

Section 68

facts in deleting the addition of Rs. 9,94,405/- (7.96.725/- + 1,97.680) as income from FD & Misc income in the head of income from other sources, without considering the facts that the assessee did not consider the amount as income from other source. 2. In Ground No.1, the revenue ... which was made by the AO on account of income received by the assessee from FD & miscellaneous income under the head of income from other sources. 13. The AO during the course of assessment proceedings observed that the assessee has earned f Rs.7,96,725/- and Rs.1,97,680/- which

Sen Ferro Alloys (P) Ltd., Kolkata vs. A.C.I.T., CC - 4(3), Kolkata

In the result, appeal of the assessee is allowed

ITA 2376/KOL/2024[2021-2022]Status: DisposedITAT Kolkata21 Apr 2025AY 2021-2022

Bench: SHRI RAJESH KUMAR (Accountant Member)

For Appellant: Shri Somnath GhoshFor Respondent: Ms. MadhumitaDas, Addl.CIT

Section 132Section 142(1)Section 143(3)Section 69C

manufacturing of Sponge Iron and trading coal and has shown mainly, income under the head profits & gains from business or profession and income from other sources. The case of the assessee was selected for scrutiny through CASS and statutory notices were duly issued and served on the assessee. In para

Danayya Hiremath, Near Post Office Navanagar Bagalkota vs. Income Tax Officer, Ward 1 & Tps, Bagalkot, Aayakar Bhavan

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

ITA 48/BANG/2025[2015-16]Status: DisposedITAT Bangalore21 Apr 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2015-16

For Appellant: Sri Siddesh Gaddi, A.RFor Respondent: Smt. Srinandini Das, D.R

Section 115BSection 142(1)Section 144Section 147Section 148Section 250Section 69

also added the bank interest amounting to Rs.1,58,816/- as the assessee has not offered the same to tax under “income from other sources” and accordingly assessed on a total income of Rs.7,44,04,381/-. 4. Aggrieved by the assessment completed u/s 147 r.w.s

Chandrakala Narala, Bengaluru vs. Income Tax Officer, Ward-5(3)(3), Bangalore

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

ITA 2575/BANG/2024[2016-17]Status: DisposedITAT Bangalore21 Apr 2025AY 2016-17

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan Kassessment Year : 2016-17

For Appellant: Shri. Pranit Tanna, CAFor Respondent: Smt. Neha Sahay, JCIT(DR)(ITAT), Bangalore

Section 144Section 147Section 148Section 234BSection 249(4)(b)Section 250Section 271(1)(b)Section 282ASection 69A

unexplained income under section 69A of the Act and AO found that the bank has credited interest income of Rs.94,384/- which was income from other sources and added to the total income of the assessee. Resultantly, the assessed income was arrived at Rs.69,16,384/-. 4. Aggrieved from

Mr. Madeneralu Annegowda Subbegowda, Chikmagalur vs. Income Tax Officer, Ward-2, Chickmagalur

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

ITA 2352/BANG/2024[2017-18]Status: DisposedITAT Bangalore21 Apr 2025AY 2017-18

Bench: Shri Waseem Ahmedassessment Year: 2017-18

For Appellant: Shri N Ramaraju, C.AFor Respondent: Shri Ganesh R Gale, Standing Counsel for Dept

Section 115BSection 142(1)Section 250Section 69

entire deposit of Rs. 15,28,500 was unexplained investment. Accordingly, it was brought to tax under section 69 of the Act as income from other sources and made taxable under section 115BBE of the Act. 4. The aggrieved assessee preferred an appeal before the learned CIT(A)/NFAC

Prathamik Krushi Coop Limited, Bagalkot vs. Income Tax Officer, Ward-1 & Tps, Bagalkot

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

ITA 2344/BANG/2024[2017-18]Status: DisposedITAT Bangalore21 Apr 2025AY 2017-18

Bench: Shri Waseem Ahmedassessment Year: 2017-18

For Appellant: Shri Varun Bhat, CAFor Respondent: Shri Ganesh R Gale, Standing Counsel for Dept

Section 68

therefore provisions of section 115BBE of the Act will have no application so as to treat the income of the assessee as income from other sources. Hon'ble Kolkata Tribunal in the case of CIT v. Associated Transport Pvt. Ltd. reported in 84 Taxman 146 on identical facts took ... sufficient cash in hand in the books of account of the assessee, that there was no reason to treat the cash deposits as income from undisclosed sources. The Hon'ble Vishakapatnam Tribunal in the case of ACIT v. Hirapanna Jewelers in ITA No. 253/Viz/2020 on identical facts held that when

Beejady Fishermen Co-Op. Society Limited, Udupi vs. Income Tax Officer, Ward-1., Udupi

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

ITA 2197/BANG/2024[2020-21]Status: DisposedITAT Bangalore21 Apr 2025AY 2020-21

Bench: Shri Waseem Ahmed

For Appellant: Shri Mahesh R Uppin, AdvocateFor Respondent: Shri Ganesh R Gale, Standing Counsel for Dept

Section 143(2)Section 57Section 80PSection 80P(2)(a)Section 80P(2)(c)Section 80P(2)(d)

found that the assessee in the return of income itself declared impugned interest income of Rs. 20,39,365/- under the head income from other sources as it was earned from investment or deposit with cooperative bank/other banks. However, the same was claimed as deduction under section ... However, since the above-mentioned income is not eligible under section 80P of the Act and has been rightly assessed under the head ‘Income from Other Sources’, the assessee is entitled to claim deduction of expenditure incurred for earning such income as per section 57 of the Act. Therefore

Beejady Fishermen Co-Operative Society Limited, Kundapura vs. Income Tax Officer, Ward-1 & Tps, Udupi

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

ITA 2196/BANG/2024[2018-19]Status: DisposedITAT Bangalore21 Apr 2025AY 2018-19

Bench: Shri Waseem Ahmed

For Appellant: Shri Mahesh R Uppin, AdvocateFor Respondent: Shri Ganesh R Gale, Standing Counsel for Dept

Section 143(2)Section 57Section 80PSection 80P(2)(a)Section 80P(2)(c)Section 80P(2)(d)

Sri Doddanara Mallappa Manjunatha, Shivamogga vs. Income Tax Officer, Ward-1 & Tps, Shimoga

In the result, appeal filed by the assessee is allowed

ITA 2018/BANG/2024[2018-19]Status: DisposedITAT Bangalore21 Apr 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2018-19

For Appellant: Smt. Sunaina Bhatia, A.RFor Respondent: Sri Ganesh R Gale, Standing Counsel for department

Section 143(2)Section 143(3)Section 250

case. 2. The learned CIT[A] is not justified in sustaining the addition of Rs. 7,48,000/- made under the head Income from "Other Sources" in respect of the agricultural expenses incurred and claimed by the appellant on the mistaken notion that there was a double claim ... r.w.s. 143(3A) & 143 (3B) of the Act on 09.03.2021 by disallowing the expenditure of Rs.7,48,000/- and treated the same as income from “other sources” and added to the total income of the assessee. Sri DoddanaraMallappaManjunath, Shivamogga Page 3 of 6 4. Aggrieved by the order

Sri. Thimmaish Srinivas, Bengaluru vs. Income Tax Officer, Ward-6(2)(5), Bengaluru

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

ITA 1916/BANG/2024[2017-18]Status: DisposedITAT Bangalore21 Apr 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Ms. Sunaina Bhatia, A.RFor Respondent: Sri Ganesh R Gale, Standing counsel for department

Section 115BSection 139(4)Section 143(1)Section 143(2)Section 143(3)Section 250Section 69A

assessment year 2017-18 and has made the following additions to the total income: (1) Agriculture income treated as Income from other sources: The learned AO has also disallowed a sum of Rs.10,12,400/- and taxed the same under income from other sources which was disclosed as agricultural income ... year 2015-16 to assessment year 2019-20 produced before us. The AO has treated this agricultural income of Rs.10,12,400/- as income from other sources. However, the ld. CIT(A) treated Rs.5,00,000/- on an estimate basis as agricultural income and surprisingly treated the balance amount

Sri. Maddur Ananthaswamy Srinath, Chitradurga vs. Income Tax Officer, Ward-1, Chitradurga

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

ITA 1579/BANG/2024[2021-22]Status: DisposedITAT Bangalore21 Apr 2025AY 2021-22

Bench: Shri Waseem Ahmedassessment Year: 2017-18

For Appellant: Shri N Ramaraju, C.AFor Respondent: Shri Ganesh R Gale, Standing Counsel for Dept

Section 115BSection 142(1)Section 250Section 69

ACIT-24(1), Mumbai vs. Dipti Sureshchandra Bajaj, Mumbai

In the result, both the appeals of the Revenue are dismissed

ITA 3769/MUM/2024[2014]Status: DisposedITAT Mumbai21 Apr 2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 10(38)Section 143(3)Section 147Section 148Section 14A

declaring total income of Rs.8,30,970/-. In the computation of income assessee had shown income from business, short term capital gain and income from other sources. In the profit and Rs.10,13,658/- which was shown after deducting loss from currency derivatives of Rs.92,53,287/- and loss from