“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

Irula Snake Catchers Industrial Co-Op. Society Ltd., Chennai vs. ITO, Ward-22(1), Chennai

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

ITA 1790/CHNY/2025[2020-21]Status: DisposedITAT Chennai11 Feb 2026AY 2020-21

Bench: Shri Manu Kumar Giri & Shris.R.Raghunathaआयकरअपीलसं. (Ita No.1790/Chny/2025 "नधा"रणवष"/Assessment Years: 2020-21 Irula Snake Catchers Industrial Co- V. Income Tax Officer, Operative Society Ltd, Non-Coporate Ward 22(1), Mahabalipuram Road, Tambaram Vadanemmli Village, Perur Post, Chennai-603 104 [Pan:Aaaai 7894 M] (अपीलाथ"/Assessee) (""यथ"/Respondent)

For Appellant: Mr. G Baskar, Advocate &For Respondent: Mr. Gouthami Manivasagam

Section 80PSection 80P(2)(a)

disallowed Rs.1,21,269/- out of the total interest income of Rs.1,74,067/- earned from the savings bank account, treating it as income from other sources and holding it to be ineligible for deduction u/s. 80P. In doing so, the Assessing Officer relied on the judgment ... Assessing Officer disallowed a sum of Rs.1,21,269/- out of the total interest income of Rs.1,74,067/-, treating the same as “income from other sources” and holding that such interest was not eligible for deduction under section 80P, relying upon the judgment of the Hon’ble Supreme Court

Sri Guru Vappathina Swamy Pathina Sahakara Sangha Niyamitha, Opp Oppathina Sangha Matt, Hosadurga vs. Income Tax Officer, Ward, Chitradurga

The Appeal of the Assessee is allowed holding that Assessee is entitled to deduction u/s

ITA 2483/BANG/2025[2022-23]Status: DisposedITAT Bangalore11 Feb 2026AY 2022-23

Bench: Shri Prashant Maharishi, Vice –Assessment Year : 2022-23 M/S. Sri Guru Vappathina Swamy Pathin Sahakara Sangha The Income Tax Officer, Niyamitha, Ward-1, Opp Oppathina Sangha Matt, Vs. Chitradurga. Hosadurga – 577 501. Pan: Aaaas3998Q Appellant Respondent

For Appellant: Ms. Shreesha, CA

Section 143(3)Section 56Section 57Section 80P(2)(a)Section 80P(2)(d)

also incorrect in holding that such interest income of the Assessee is chargeable to tax u/s. 56 of the Income Tax Act as income from other sources and further the Assessee is entitled to deduction u/s. 57 of the Act as cost of funds. 3. The brief facts ... earned interest income from commercial banks on which deduction is not allowable and further such income is chargeable to tax under the head income from other sources and amount be categorized as business from other profession. The Assessee made a detailed submission stating that Assessee is entitled to the deduction

Sabrunnisa Israr Ahmad Shaikh, Bhiwandi vs. ITO Ward 1(1), Kalyan

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

ITA 8620/MUM/2025[2017-18]Status: DisposedITAT Mumbai11 Feb 2026AY 2017-18

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailsabrunnisa Israr Ahmad Shaikh 928/I, Ansar Apartment, New Gauripada, Vidyashram Post Office, Bhiwandi, Mumbai- 421305 ............... Appellant Pan: Ausps3051R

For Appellant: Ms. Deepa Khare, AdvFor Respondent: Shri Pravin Salunkhe, Sr. DR

Section 142(1)Section 143(2)Section 143(3)Section 250Section 69A

lakh deposited during the demonetisation period. As the assessee during the assessment proceedings offered INR 2,27,332 for taxation under the head “income from other sources” for the year under consideration, the AO restricted the addition only to an extent of INR 9,72,668 under section ... account of the cash deposited during the demonetisation period by treating the same as income from undisclosed sources. 5. The learned CIT(A), vide impugned order, dismissed the appeal filed by the assessee on this issue and held that the total income for the past three years preceding the demonetisation

Prem Parkash, New Delhi, Delhi vs. Income Tax Officer, Ward 54(1), Delhi, New Delhi

In the result, the appeal of the assessee is partly allowed as indicated above

ITA 8356/DEL/2025[2017-18]Status: DisposedITAT Delhi11 Feb 2026AY 2017-18

Bench: Shri C.N. Prasadassessment Year 2017-18 Prem Prakash Vs. Income Tax Officer A-32, 2Nd Floor, Amar Ward- 54(1) Colony, Lajpat Nagar-4, Delhi New Delhi-110024 Pan No.Agwpp9248D Appellant Respondent Appellant Sh. Akshat Jain, Ca Sh. Rajat Jain, Ca Respondent Sh. Manoj Kumar, Sr. Dr

Section 147Section 148

after claiming indexed cost of acquisition at Rs.5,08,794/- and indexed cost of improvement of Rs.77,16,709/-apart from declaring income from other sources of Rs.12,737/-. However, the AO denied 50% of indexed cost of improvement and made addition of Rs.38,58,354/- on the ground that

Income Tax Officer, Ward-20(1), Delhi vs. Prem Softech Private Limited, Udyog Vihar, Gurugram

The appeal of the revenue is dismissed

ITA 3160/DEL/2024[2014-15]Status: DisposedITAT Delhi11 Feb 2026AY 2014-15

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

For Appellant: Sh. Manish Jaggi, DirectorFor Respondent: Sh. Ajay Kumar Arora, Sr. DR

Section 144BSection 147Section 147rSection 194ASection 194C

r.w.s. 144 of the IT Act on 29.03.2022 by treating Rs.12,30,00,000/- as unexplained investment and Rs.14,87,177/ as income from other sources. He assessed the total income of the assessee at Rs.12,45,13,710/-. 5. The addition were deleted by Ld. CIT(A) making following

Surendranagar District Co Op Producers Union Limited, Surendranagar vs. Assistant Commissioner of Income Tax, Surendranagar Circle

In the result, appeal filed by the assessee is allowed

ITA 429/RJT/2025[2014-15]Status: DisposedITAT Rajkot10 Feb 2026AY 2014-15

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 429/Rjt/2025 ("नधा"रणवष"/Assessment Year: (2014-15) Surendranagar District Co. Op. Acit, Circle, Producers Union Ltd. Vs. Surendranagar-363035 Plot No.249, Phase 2 Gidc Market Yard Circle, Sursagar Dairy, Wadhwan Road, Surendranagar-363035 (Guj) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaas8375B (अपीलाथ"/Assessee) (""यथ"/Respondent) Assessee By : Shri Kalpesh Doshi, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : Heard On 09/10/2025, Refixed For Clarification On 03.11.2025 & Finally Heard On 02.02.2026 : 10/02/2026 Date Of Pronouncement Order Per, Dr. Arjun Lal Saini, A.M.:

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 142(1)Section 143(2)Section 143(3)Section 234ASection 250Section 271(1)(c)Section 80P(2)(b)Section 80P(2)(d)

part of net profit from "Business & Profession" and also assessed the same income as income under the head "Income from other sources" and therefore the said income has been taxed twice. 4. That, the Ld. CIT(A) has wrongly confirmed the disallowance of deduction of interest earned from Co-operative ... Business & Profession" and also assessed the same income Page 7 of 25 Surendranagar Dist. Co-op. Milk Producer as income under the head "Income from other sources" and therefore the said income has been taxed twice. 12. We have heard both the parties. Learned Counsel for the assessee reiterated

Shri Kamlesh Vashrambhai Ramani, Rajkot-Gujarat vs. The Deputy Commissioner of Income Tax, Central Circle-2, Rajkot-Gujarat

In the result, appeal filed by the assessee, (in ITA No

ITA 65/RJT/2014[2010-11]Status: DisposedITAT Rajkot10 Feb 2026AY 2010-11

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita No.451/Rjt/2013 (Assessment Years: (2008-2009) Shri Vashrambhai Ghelabhai Ramani, Vs. The Dcit, 22, Ranchodnagar Society, Kuvadava Central Circle-2, Road, Rajkot. Rajkot. "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Bflpr5056N आयकर अपील सं./Ita Nos.65/Rjt/2014 (Assessment Years: (2010-11) & आयकर अपील सं./Ita Nos. 63/Rjt/2014 &407/Rjt/2014 (Assessment Year: 2011-2012) Shri Kamlesh Vashrambhai Ramani, Deputy Commissioner Of Income-Tax, Prop. Marutinandan Petroleum, 22, Vs. Central Circle-2, Ranchodnagar Society,Rajkot. Rajkot. "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahqpr2043D

For Appellant: Shri Samir Bhuptani, ARFor Respondent: Shri Sanjay Kumar, CIT- DR

Section 132Section 143(3)Section 153ASection 271A

case of Madhusudan Dhakad Vs. ITO in ITA No.9/Ind/2022 pronounced on 28.06.2022, wherein it was held that assessee was having agriculture income, as sole source of income and there is no other source of income brought on record by the AO, therefore addition was deleted. Therefore, we note that assessing ... appeal of the assessee, whereby upholding the addition of Rs. 25,00,000/- made by the Assessing Officer, on the alleged ground of income from other sources is unwarranted, unjustified and bad in law. (2) The learned Commissioner of Income Tax (Appeals)-IV, Ahmedabad, has erred in dismissing the appeal

Shri Kamlesh Vashrambhai Ramani, Rajkot-Gujarat vs. The Deputy Commissioner of Income Tax, Central Circle-2, Rajkot-Gujarat

In the result, appeal filed by the assessee, (in ITA No

ITA 63/RJT/2014[2011-12]Status: DisposedITAT Rajkot10 Feb 2026AY 2011-12

For Appellant: Shri Samir Bhuptani, ARFor Respondent: Shri Sanjay Kumar, CIT- DR

Section 132Section 143(3)Section 153ASection 271A

Kamlesh Vashrambhai Ramani, Rajkot-Gujarat vs. The Deputy Commissioner of Income Tax, Central Circle-2, Rajkot-Gujarat

In the result, appeal filed by the assessee, (in ITA No

ITA 407/RJT/2014[2011-12]Status: DisposedITAT Rajkot10 Feb 2026AY 2011-12

For Appellant: Shri Samir Bhuptani, ARFor Respondent: Shri Sanjay Kumar, CIT- DR

Section 132Section 143(3)Section 153ASection 271A

Shri Vashrambhai Ghelabhai Ramani, Rajkot-Gujarat vs. The Deputy Commissioner of Income Tax, Cen.Cir.-2, Rajkot-Gujarat

In the result, appeal filed by the assessee, (in ITA No

ITA 451/RJT/2013[2008-09]Status: DisposedITAT Rajkot10 Feb 2026AY 2008-09

For Appellant: Shri Samir Bhuptani, ARFor Respondent: Shri Sanjay Kumar, CIT- DR

Section 132Section 143(3)Section 153ASection 271A

Rama Met Coke, Digboi vs. ACIT, Central Circle -2, Guwahati

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

ITA 27/GTY/2024[2021-22]Status: DisposedITAT Guwahati10 Feb 2026AY 2021-22

Bench: SHRI GEORGE MATHAN, JUDICIAL MEMBER SHRI LAXMI PRASAD SAHU (Accountant Member)

Section 153ASection 156Section 250Section 251(2)

justified in arbitrarily deciding that the unilateral write off of business creditors by the appellant is to be assessed under the head income from other sources. 7. For that in absence of any material, the Id. CIT(A) was not justified in issuing a notice under section ... justified in arbitrarily deciding that the unilateral write off of business creditors by the appellant is to be assessed under the head 'income from other sources. 7. For that in absence of any material, the id. CIT(A) was not justified in issuing a notice under section

Rama Met Coke, Digboi vs. ACIT, Central Circle -2, Guwahati

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

ITA 26/GTY/2024[2020-21]Status: DisposedITAT Guwahati10 Feb 2026AY 2020-21

Bench: him.

Section 153ASection 156Section 250Section 251(2)

Aurangabad Division Life Insurance Employees Co-Op Credit Society Ltd, Auranbad vs. ITO, Ward-1(1), Aurangabad

In the result, appeal of the assessee is allowed

ITA 3175/PUN/2025[2020-21]Status: DisposedITAT Pune10 Feb 2026AY 2020-21

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.3175/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Aurangabad Divison Life V The Income Tax Officer, Insurance Employees Co-Op S Ward-1(1), Aurangabad. Credit Society Ltd., 11, Jeevan Prakash, Lic Office Building Adalat Road, Kranti Chowk, Aurangabad -431005 Pan: Aaaaa2245A Appellant/ Assessee Respondent /Revenue Assessee By Ca Payal Rathi (Virtual) Revenue By Shri Sadananda – Jcit Date Of Hearing 09/02/2026 Date Of Pronouncement 10/02/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2020-21 Dated 24.09.2025 Emanating From The Assessment Order Passed Under Section 143(3) Read With Section 144B Of The Income Tax Act, 1961

Section 143(3)Section 144BSection 250Section 56Section 66Section 80PSection 80P(2)(a)

Officer held that such interest income which is ITA No.3175/PUN/2025 [A] received by Assessee from investments and deposits needs to be taxed as income from other sources under section 56 of the Act. Assessee filed elaborate submission before the Assessing Officer. However, Assessing Office disallowed assessee’s claim for deduction ... eligible for deduction u/s.80P(2)(a)(i) of the Act, as it is a business income for the assessee and not income from other sources. Accordingly, Assessing Officer is directed to delete the 16 ITA No.3175/PUN/2025 [A] addition. Accordingly, grounds of appeal raised by the assessee are allowed

Marathi Bandhkam Vya vs. Ayik Association, Punevs.ITO, Exemption Ward-1(1), Pune

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

ITA 2310/PUN/2025[2018-19]Status: DisposedITAT Pune10 Feb 2026AY 2018-19

For Appellant: Shri Suhas P. BoraFor Respondent: Shri Milind Debaje (Virtual)

Section 143(2)Section 143(3)

action of the Assessing Officer in treating the interest income earned on Fixed Deposits kept with banks as taxable under the head "Income from Other Sources", by holding that the principle of mutuality is not applicable to such income, without appreciating the peculiar facts of the appellant's case ... above assessed income includes addition of Rs.13,84,970/- being interest income earned on bank fixed deposits & savings bank under the head ‘Income from other sources’. Accordingly, the Assessing Officer rejected the claim of the assessee regarding application of principle of mutuality on Bank interest income & determined it taxable under

Brajbhumi Nirmaan Private Limited, Salt Lake vs. ITO, Ward 2(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2605/KOL/2025[2015-2016]Status: DisposedITAT Kolkata10 Feb 2026AY 2015-2016

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Akkal Dudhwewala, ARFor Respondent: Shri Madanappa Raghuveer, DR

Section 133(6)Section 143(2)Section 56(2)(viib)

Rs.87.30] and accordingly added the excess amount of Rs. 10,21,00,000/- [Rs. 102.10 x 10,00,000 shares] by way of income from other sources u/s 56(2)(viib) of the Act. The Id. CIT (A) confirmed the addition in the appellate proceedings ... prejudice to the generality of the provisions of sub- section (1), the following incomes, shall be chargeable to income-tax under the head "Income from other sources", namely :— (viib) where a company, not being a company in which the public are substantially interested, receives, in any previous year, from

Gaurav Vinimay Pvt. Ltd., Kolkata vs. D.C.I.T., Circle - 8(1), Kolkata

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

ITA 2306/KOL/2025[205-2016]Status: DisposedITAT Kolkata10 Feb 2026

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(3)Section 250Section 50DSection 56(2)Section 56(2)(viia)

prejudice to the generality of the provisions of sub-section (1), the following incomes, shall be chargeable to income-tax under the head "Income from other sources", namely:— (viia) where a firm or a company not being a company in which the public are substantially interested, receives, in any previous ... Total 13,23,01,000 8.5.4 The AO treated the difference amounting to Rs.13,23,01,000/- as income under the head "Income from Other Sources". The AO held that the shares were received for inadequate consideration and the differential between the FMV and actual consideration was taxable under section

Patton International Limited, Kolkata vs. ACIT, Circle 7(1), Kolkata

ITA 1045/KOL/2025[2020-2021]Status: DisposedITAT Kolkata10 Feb 2026AY 2020-2021

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 14ASection 250

IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘D' BENCH, KOLKATA Before SHRI SONJOY SARMA, JUDICIAL MEMBER & SHRI RAKESH MISHRA, ACCOUNTANT

Patton International Limited, Kolkata vs. ACIT, Circle 7(1), Kolkata

ITA 1044/KOL/2025[2018-2019]Status: DisposedITAT Kolkata10 Feb 2026AY 2018-2019

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 14ASection 250

IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘D' BENCH, KOLKATA Before SHRI SONJOY SARMA, JUDICIAL MEMBER & SHRI RAKESH MISHRA, ACCOUNTANT

DCIT - 19(1), Mumbai, Lalbaugh vs. Bharat Ramji Bhai Manek, Grant Road Mumbai

In the result, the appeal of the revenue bearing ITA No

ITA 4339/MUM/2025[2014-15]Status: DisposedITAT Mumbai10 Feb 2026AY 2014-15

Bench: SHRI ANIKESH BANERJEE (Judicial Member), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

For Appellant: Shri Ronak DoshiFor Respondent: Shri Leyaqat Ali Aafaqui, (SR DR)

Section 10(38)Section 143(3)Section 250

similar issue, the Hon'ble ITAT, Kolkata in the case of Manoj Jain (HUF) (ITA No. 1782/KOL/2018) treated the penny stock transaction as income from other sources instead of LTCG-a decision upheld by the Hon'ble Calcutta High Court ((2024) 164 taxmann.com 133 (Cal)) and confirmed ... 21636/2024, dated 20.09.2024] upheld the Calcutta High Court's ruling [2024] 164 taxmann.com 133, treating penny stock LTCG as income from other sources due to manipulated trades. In PCIT v. NRA Iron & Steel (P) Ltd. (2019) 103 taxmann.com 48 (SC) Key Point: The Supreme Court affirmed that if SEBI investigations

Satender Kumar, Sarita Vihar vs. Income Tax Officer, Civic Centre

In the result, appeal of the assessee is allowed

ITA 229/DEL/2026[2020-21]Status: DisposedITAT Delhi10 Feb 2026AY 2020-21

Bench: Sh. Satbeer Singh Godaraita No. 229/Del/2026 : Asstt. Year: 2020-21 Satender Kumar, Vs Income Tax Officer, 56, Ali Village, Sarita Vihar, Ward-28(1), New Delhi-110076 New Delhi-110001 (Appellant) (Respondent) Pan No. Afxpk4995C Assessee By: None Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 10.02.2026 Date Of Pronouncement: 10.02.2026 Order This Assessee’S Appeal For Assessment Year 2020-21 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1082434098(1) Dated 10.11.2025, In Proceedings U/S 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: NoneFor Respondent: Sh. Manoj Kumar, 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 ... capital receipt' forming part of enhanced compensation as envisaged in section 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