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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

Sh. Trilok Chand Sain, Dausa vs. ITO, Ward-1(2), Alwar

In the result, appeal of the assessee is allowed

ITA 1264/JPR/2024[2012-13]Status: DisposedITAT Jaipur04 Apr 2025AY 2012-13

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

For Appellant: Shri P.C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 131Section 143(3)Section 144Section 144rSection 148Section 250Section 263

declaring total income of Rs.2,56,110/- comprising of salary income of Rs.37,500/-, business income of Rs.1,40,200/- and income from other sources 5 Shri Trilok Chand Sain, Dausa. of Rs.78,410/-. The income from othersources includes the facilitation charges received by the assessee in respect of land

DCIT, Central Circle-1, Jaipur vs. Vidhushi Kothari, Jaipur

ITA 1032/JPR/2024[2015]Status: DisposedITAT Jaipur04 Apr 2025
For Appellant: Shri P.C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT
Section 132Section 142(1)Section 143(2)Section 143(3)Section 153ASection 250Section 68Section 69C

ground. 3. The brief facts of the case are that the assessee is an Individual and derives income from salary, house property and income from other sources during the year under consideration. The appellant filed her return of income on 31.08.2015 declaring total income of Rs. 27,12,600/-. Search

M/S. Seth B D Goyal Charitable Trust, Kolkata vs. I.T.O. Ward - 1(3), Exemption, Kolkata

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

ITA 2267/KOL/2024[2020-2021]Status: DisposedITAT Kolkata04 Apr 2025AY 2020-2021

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 11Section 143(1)Section 143(1)(a)Section 250

item in the return which is inconsistent with another entry of the same or some other item in such return for example, income from other sources are deducted from business income but not declared under income from other sources. • Disallowance of set-off of loss in the financial year which

Shri Palash Kumar Kapas, Howrah vs. ACIT, Cir. 47, Kolkata

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

ITA 1419/KOL/2023[2017-18]Status: DisposedITAT Kolkata04 Apr 2025AY 2017-18

Bench: Shri Duvvuru Rl Reddy(Kz) & Shri Rakesh Mishra

Section 142(1)Section 143(2)Section 144Section 144(1)Section 250Section 68

business receipts. Therefore, the Ld. AO held that the cash deposit of Rs. 34,86,700/- during the whole FY 2016-17 represented income from undisclosed sources and the assessee had concealed his true income which otherwise was taxable at a higher rate ... perused. As stated by the appellant, he had offered Rs. 621,378 as income from business and offered Rs. 40,85,340/- as income from other sources. The Page 4 of 10 I.T.A. No.: 1419/KOL/2023 Assessment Year: 2017-18 Shri Palash Kumar Kapas. individual statement of the appellant shows that

Gnanasekaran, Cuddalore vs. ACIT, CC-1(1), Chennai

In the result, appeals of the assessee are allowed for statistical purposes

ITA 2099/CHNY/2024[2021-22]Status: DisposedITAT Chennai04 Apr 2025AY 2021-22

Bench: Shri Manu Kumar Giri & Shri Amitabh Shukla

For Appellant: Mr. P.M. Kathir, AdvocateFor Respondent: Nr. Shivanand K.Kalakeri, CIT
Section 132Section 143(2)Section 153ASection 56Section 69

loan/credit to Shri Seshadri was a standalone transaction and nit his regular business activity and hence, interest @ 1% on Rs.3000000/- is treated as income under other sources u/s.56 of the Act. 6. Aggrieved assessee challenged the order of assessment u/s.153A before the CIT(A), who rejected the contentions ... rate of 6% on the turnover. He has separately shown the interest income from Mr. Seshadri under the head income from other sources. It is acknowledgment by the appellant that his business activities and money lending activity to Mr. Seshadri is separate and are not mixed. In this situation

Gnanasekaran, Cuddalore vs. ACIT, CC-1(1), Chennai

In the result, appeals of the assessee are allowed for statistical purposes

ITA 2098/CHNY/2024[2020-21]Status: DisposedITAT Chennai04 Apr 2025AY 2020-21

Bench: Shri Manu Kumar Giri & Shri Amitabh Shukla

For Appellant: Mr. P.M. Kathir, AdvocateFor Respondent: Nr. Shivanand K.Kalakeri, CIT
Section 132Section 143(2)Section 153ASection 56Section 69

loan/credit to Shri Seshadri was a standalone transaction and nit his regular business activity and hence, interest @ 1% on Rs.3000000/- is treated as income under other sources u/s.56 of the Act. 6. Aggrieved assessee challenged the order of assessment u/s.153A before the CIT(A), who rejected the contentions ... rate of 6% on the turnover. He has separately shown the interest income from Mr. Seshadri under the head income from other sources. It is acknowledgment by the appellant that his business activities and money lending activity to Mr. Seshadri is separate and are not mixed. In this situation

Gnanasekaran, Cuddalore vs. ACIT, CC-1(1), Chennai

In the result, appeals of the assessee are allowed for statistical purposes

ITA 2097/CHNY/2024[2019-20]Status: DisposedITAT Chennai04 Apr 2025AY 2019-20

Bench: Shri Manu Kumar Giri & Shri Amitabh Shukla

For Appellant: Mr. P.M. Kathir, AdvocateFor Respondent: Nr. Shivanand K.Kalakeri, CIT
Section 132Section 143(2)Section 153ASection 56Section 69

loan/credit to Shri Seshadri was a standalone transaction and nit his regular business activity and hence, interest @ 1% on Rs.3000000/- is treated as income under other sources u/s.56 of the Act. 6. Aggrieved assessee challenged the order of assessment u/s.153A before the CIT(A), who rejected the contentions ... rate of 6% on the turnover. He has separately shown the interest income from Mr. Seshadri under the head income from other sources. It is acknowledgment by the appellant that his business activities and money lending activity to Mr. Seshadri is separate and are not mixed. In this situation

Gnanasekaran, Cuddalore vs. ACIT, CC-1(1), Chennai

In the result, appeals of the assessee are allowed for statistical purposes

ITA 2096/CHNY/2024[2018-19]Status: DisposedITAT Chennai04 Apr 2025AY 2018-19

Bench: Shri Manu Kumar Giri & Shri Amitabh Shukla

For Appellant: Mr. P.M. Kathir, AdvocateFor Respondent: Nr. Shivanand K.Kalakeri, CIT
Section 132Section 143(2)Section 153ASection 56Section 69

loan/credit to Shri Seshadri was a standalone transaction and nit his regular business activity and hence, interest @ 1% on Rs.3000000/- is treated as income under other sources u/s.56 of the Act. 6. Aggrieved assessee challenged the order of assessment u/s.153A before the CIT(A), who rejected the contentions ... rate of 6% on the turnover. He has separately shown the interest income from Mr. Seshadri under the head income from other sources. It is acknowledgment by the appellant that his business activities and money lending activity to Mr. Seshadri is separate and are not mixed. In this situation

Gnanasekaran, Cuddalore vs. ACIT, CC-1(1), Chennai

In the result, appeals of the assessee are allowed for statistical purposes

ITA 2095/CHNY/2024[2018-18]Status: DisposedITAT Chennai04 Apr 2025AY 2018-18

Bench: Shri Manu Kumar Giri & Shri Amitabh Shukla

For Appellant: Mr. P.M. Kathir, AdvocateFor Respondent: Nr. Shivanand K.Kalakeri, CIT
Section 132Section 143(2)Section 153ASection 56Section 69

loan/credit to Shri Seshadri was a standalone transaction and nit his regular business activity and hence, interest @ 1% on Rs.3000000/- is treated as income under other sources u/s.56 of the Act. 6. Aggrieved assessee challenged the order of assessment u/s.153A before the CIT(A), who rejected the contentions ... rate of 6% on the turnover. He has separately shown the interest income from Mr. Seshadri under the head income from other sources. It is acknowledgment by the appellant that his business activities and money lending activity to Mr. Seshadri is separate and are not mixed. In this situation

Thiruvengadamudaliar Ramalingam, Arni vs. PCIT (Central), Chennai

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

ITA 1830/CHNY/2024[2020-21]Status: DisposedITAT Chennai04 Apr 2025AY 2020-21

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.1830/Chny/2024 िनधा:रण वष: /Assessment Year: 2020-21 Thiruvengadamudaliar Ramalingam The Principal Commissioner Of No.4, Big Sayakara Street, Vs. Income Tax (Central), Kosapalayam, Chennai-1. Arni – 632 301. [Pan: Aacpr 1690P]

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Shri R. Clement Ramesh Kumar, CIT
Section 133ASection 142(1)Section 143(3)Section 263Section 69B

record. The assessee has filled return of income of Rs.57,40,432/-, which included income from House property of Rs.12,68,680/-, income from other sources of Rs ,6,01,041/- and income from business (TCR Silks) of Rs.40,55,711/-. The assessee has admitted excess stock at Rs.92 ... find merit in the Ld AR’s argument as the AO has reduced income from house property and income from other sources from the computation of total income and these two issues are not in appeal before Ld CIT(A). The explanation 1(c) of section

The Tatta Niwashi Co Operative Housing Society Ltd, Mumbai vs. ITO Ward 27(3)(1), Mumbai

In the result appeal filed by the assessee stands allowed for statistical purposes

ITA 756/MUM/2025[2019-20]Status: DisposedITAT Mumbai04 Apr 2025AY 2019-20

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 143(1)Section 143(1)(a)Section 154

well as interest 6 I.T.A. No.756/Mum/2025 Assessment Year: 2019-20 The Tatta Niwashi Co-operative Housing Society Ltd. paid under the head "income from other sources". Not realizing the negative figure is not accepted by the server and therefore the interest paid shown as Rs.2,33,535/- was rejected

Krishnakant Sharma (Lh of Late Vimaladevi Sharma), Mumabi vs. Income Tax Officer - 23(3)(5), Mumbai

In the result, both the appeals filed by the assessee are allowed

ITA 418/MUM/2025[2012-2013]Status: DisposedITAT Mumbai04 Apr 2025AY 2012-2013

Bench: Shri Br Baskaran & Shri Sandeep Gosain

Section 147Section 250

nature. And therefore, he added the same i.e. Rs.25,21,508/- as revenue receipt in the form of dividend under the head "income from other sources". Aggrieved, the assessee preferred an appeal before the Ld. CIT(A) who confirmed the action of the AO. Aggrieved, the assessee is before ... nature of "dividend" from the housing society and therefore, revenue in nature and so he added it under the head "income of other sources". According to the assessee, the amount received i.e. Rs.25,21,508/- received from the developer as Hardship Compensation on account of re-development

Krishnakant Sharma (Lh of Late Vimaladevi Sharma), Mumbai vs. Income Tax Officer - 23(3)(5), Mumbai

In the result, both the appeals filed by the assessee are allowed

ITA 417/MUM/2025[2011-2012]Status: DisposedITAT Mumbai04 Apr 2025AY 2011-2012

Bench: Shri Br Baskaran & Shri Sandeep Gosain

Section 147Section 250

nature. And therefore, he added the same i.e. Rs.25,21,508/- as revenue receipt in the form of dividend under the head "income from other sources". Aggrieved, the assessee preferred an appeal before the Ld. CIT(A) who confirmed the action of the AO. Aggrieved, the assessee is before ... nature of "dividend" from the housing society and therefore, revenue in nature and so he added it under the head "income of other sources". According to the assessee, the amount received i.e. Rs.25,21,508/- received from the developer as Hardship Compensation on account of re-development

Mahindra Overseas Investment Company (Mauritius) Limited, Mumbai vs. Assistant Director of Income Tax-CPC Bengaluru, Mumbai

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

ITA 1792/MUM/2024[2019-20]Status: DisposedITAT Mumbai04 Apr 2025AY 2019-20

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Smt. Renu Jauhrimahindra Overseas Vs. Acit, Circle -7(1)(1) Investment Company Aayakar Bhavan, Mk (Mauritius) Ltd, Road, Mumbai Ifs Court Bank Street, Tnenteight, Cybercity Mauritius Pan/Gir No. Aalcm8059M (Applicant) (Respondent)

Section 115ASection 143(1)Section 250

entire facts are contained with regard to type of company, residential status, schedule of profit and loss account containing dividend income, details of income from other sources, intimation u/s 143(1) of the Act, which is at paper book page No. 99. 6. After having heard both the parties

Ndtv Networks Ltd., New Delhi vs. DCIT, Circle- 18(1), New Delhi

Appeal is partly allowed

ITA 6647/DEL/2018[2014-15]Status: DisposedITAT Delhi04 Apr 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2014-15 Ndtv Networks Ltd., Vs. Dcit, 207, Okhla Industrial Estate, Circle-18(1), Phase-Iii, New Delhi New Delhi Pan: Aadcn3073A (Appellant) (Respondent)

Section 143(3)Section 14ASection 2(13)Section 37(1)

case there was a profit or loss on sale of shares or it would yield dividend income which would fall under the head 'Income from other sources'. In the case of the assessee it was noted that merely terming the activity of holding of investment as "business

Dy. Commissioner of Income Tax- Central-Circle-2 (1), Nagpur vs. Jaymahakali Shikshan Sanstha, Wardha

In the result, Revenue’s appeal for A

ITA 337/NAG/2023[2019-20]Status: DisposedITAT Nagpur03 Apr 2025AY 2019-20

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mahavir AtalFor Respondent: Shri Sandipkumar Salunke
Section 11Section 12ASection 13(1)(c)Section 13(3)Section 132Section 133ASection 143(3)Section 164(2)Section 69A

learned CIT(A) reclassified the interest income, which was earlier classified as unexplained money under section 69A to the interest income under head income from other sources, assessable as per normal provisions of the statute. The learned CIT(A) was of the opinion that invoking provisions of section

Dy. Commissioner of Income Tax- Central-Circle-2(1), Nagpur vs. Jaymahakali Shikshan Sanstha, Wardha

In the result, Revenue’s appeal for A

ITA 336/NAG/2023[2018-19]Status: DisposedITAT Nagpur03 Apr 2025AY 2018-19

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mahavir AtalFor Respondent: Shri Sandipkumar Salunke
Section 11Section 12ASection 13(1)(c)Section 13(3)Section 132Section 133ASection 143(3)Section 164(2)Section 69A

learned CIT(A) reclassified the interest income, which was earlier classified as unexplained money under section 69A to the interest income under head income from other sources, assessable as per normal provisions of the statute. The learned CIT(A) was of the opinion that invoking provisions of section

Dy. Commissioner of Income Tax- Central-Circle-2(1), Nagpur vs. Jaymahakali Shikshan Sanstha, Wardha

In the result, Revenue’s appeal for A

ITA 335/NAG/2023[2017-18]Status: DisposedITAT Nagpur03 Apr 2025AY 2017-18

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mahavir AtalFor Respondent: Shri Sandipkumar Salunke
Section 11Section 12ASection 13(1)(c)Section 13(3)Section 132Section 133ASection 143(3)Section 164(2)Section 69A

learned CIT(A) reclassified the interest income, which was earlier classified as unexplained money under section 69A to the interest income under head income from other sources, assessable as per normal provisions of the statute. The learned CIT(A) was of the opinion that invoking provisions of section

M/S Mansa Agro Food Processing Pvt . Ltd, Nagpur vs. DCIT, Central Circle -2(2), Nagpur

In the result, appeal of the Assessee is dismissed

ITA 44/NAG/2018[2012-2013]Status: DisposedITAT Nagpur03 Apr 2025AY 2012-2013

Bench: Shri V. Durga Rao, Hon’Ble & Shri K.M. Roy, Hon’Ble Accountant, Member M/S. Mansa Agro Food Processing Pvt. Ltd. V. Dy.Cit – Central Circle – 2(2) 216, Devikripa Society Room No. 207, 2Nd Floor Wardhman Nagar, Nagpur (M.S)– 440006 Aayakar Bhavan Telangkhedi Road, Civil Lines Pan – Aabcm6900D Nagpur – 440001 (Appellant) (Respondent)

Section 131Section 132

details in the form of crop cultivated, details of purchaser of agricultural produce were submitted, hence agricultural income claimed exempt was considered as income from other sources by the Assessing Officer. Assessee carried the matter before Ld.CIT(A). Ld.CIT(A) confirmed the 4. assessment order on the ground that even

Assistant Commissioner of Income Tax, Madurai vs. Arul Raja, Tuticorin

In the result the appeal filed by the Revenue is dismissed

ITA 2845/CHNY/2024[2021]Status: DisposedITAT Chennai03 Apr 2025

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं/.Ita No.: 2845/Chny/2024 िनधा"रणवष" / Assessment Year: 2021-22 Assistant Commissioner Of Arul Raja, Income Tax, V. 43J, Saint Peter Koil Street, Central Circle -2, Tuticorin – 628 001. Madurai – 625 002. [Pan: Aevpr-9611-K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri. Y. Sridhar, F.C.A ""थ" की ओर से/Respondent By : Dr.M.D. Vijay Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 04.03.2025 घोषणा की तारीख /Date Of Pronouncement : 03.04.2025 आदेश/ O R D E R Per S. R. Raghunatha: This Appeal Filed By The Revenue Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-19, Chennai, Dated 09.09.2024 & Pertains To Assessment Year 2021-22. 2. The Revenue Has Raised The Following Grounds Of Appeal: 1. The Order Of The Learned Commissioner Of Income Tax (Appeals) Is Erroneous On Facts Of The Case & In Law. 2. The Ld. Cit (A) Erred In Deleting The Addition Of Rs.67,96,000/- Made Towards Unexplained Money U/S.69A. 2.1 The Ld. Cit (A) Erred In Holding That The Statement Made By The Assessee That The Source For The Cash· Was Withdrawals From Banks As A Plausible Explanation In The Absence Of Proof Evidencing The Transactions & Wrongly Observed That Burden Of Proof Shifted To The Assessing Officer.

For Appellant: Shri. Y. Sridhar, F.C.A ""For Respondent: Dr.M.D. Vijay Kumar, JCIT
Section 131Section 132Section 143(3)Section 69A

from which source the unaccounted cash emanated. 3. The Ld.CIT(A) has erred in deleting the addition of Rs.5,91,500/- made towards income from other sources. 3.1 The CIT(A) erred in not observing that as per the sale deed (Doc No. 1283/2020 dated 23-12-2020), the assessee ... taken as commission or any other. Hence, this amount of Rs.5,91,500/- is treated as the income under the head income from other sources…” 35….. “…41. From the above, the following points are brought forward: (i) The assessee had categorically mentioned that he could produce the cash book