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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

Braham Dutt Vashist, Gurgaon vs. ITO-Ward -1(3), Gurgaon

In the result, appeal of the assessee is allowed

ITA 170/DEL/2026[2014-15]Status: DisposedITAT Delhi10 Feb 2026AY 2014-15

Bench: Sh. Satbeer Singh Godaraita No. 170/Del/2026 : Asstt. Year: 2014-15 Braham Dutt Vashist, Vs Income Tax Officer, C/O Ca M. R. Sahu, Ward-1(3), H. No. 651, 1St Floor, Sector-10A, Gurgaon-122001 Near G. D. Goenka Public School, Gurgaon-122001 (Appellant) (Respondent) Pan No. Affpv0127D Assessee By: Sh. M. R. Sahu, Ca 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 2014-15 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1083989454(1) Dated 23.12.2025, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. M. R. Sahu, CAFor 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

Ramavtar, Rewari vs. ITO, Rewari

In the result, appeal of the assessee is allowed

ITA 140/DEL/2026[2020-21]Status: DisposedITAT Delhi10 Feb 2026AY 2020-21

Bench: Sh. Satbeer Singh Godaraita No. 140/Del/2026 : Asstt. Year: 2020-21 Ramavtar, Vs Income Tax Officer, C/O Anu Jain & Company, Ward-1(3), 272-R, First Floor, Near Palika Near Hindu High School, Complex, Model Town, Rewari, Model Town, Rewari, Haryana-123401 Haryana-123401 (Appellant) (Respondent) Pan No. Apdpa0001R 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/250/2025-26/1083470019(1) Dated 09.12.2025, 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

Shri Jamnadas Virjibhai Bhalodia, Rajkot vs. The ITO, Ward- 1 (1) (2), Rajkot

In the result, appeal of the assessee is partly allowed in above terms

ITA 182/RJT/2024[2017-18]Status: DisposedITAT Rajkot09 Feb 2026AY 2017-18

Bench: Dr. Arjun Lal Sainiआयकरअपील सं. /Ita No.182/Rjt/2024 िनधा"रण वष"/Assessment Year : 2017-18 बनाम/ Shri Jamnadas Virjibhai Bhalodia Income Tax Officer B-602, Pentagon Tower, Opp. Vs Ward – 1(1)(2), Rajkot Speedwell Party Plot, Behind Govani Chhatralay, Rajkot, Gujarat - 360005 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Afzpb6922N (अपीलाथ"/Appellant) (""थ"/Respondent) िनधा"रती की ओर से/Assessee By : Shri Mehul Ranpura, Ld. Ar राज"की ओर से / Revenue By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr सुनवाई की तारीख/Date Of Hearing : 22/01/2026 घोषणा की तारीख/Date Of Pronouncement : 09/02/2026 आदेश/Order Per, Dr. Arjun Lal Saini, A.M:

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 250Section 69A

this notice, the assessee filed e-submission/s as called for during the course of assessment proceedings. The assessee earned agricultural income and income from other sources during the year under consideration. As per the SFT account summary details, the assessee has deposited cash of Rs. 10,46,500/- into ... proprietary business in the name and style, as Star Plastic in around financial year 1992-93. Before that the assessee was deriving income from other sources and from agricultural operations and filing the return of income with the ITO Ward VIII(H), Ahmedabad till A.Y. 1987-88. The ACIT, Investigation

Mahesh Nagari Sahakari Patsanstha Maryadit, Ahilyanagar vs. Pr CIT, Pune-1, Pune

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

ITA 1300/PUN/2025[2020-21]Status: DisposedITAT Pune09 Feb 2026AY 2020-21

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1300/Pun/2025 िनधा"रण वष" / Assessment Year : 2020-21 Mahesh Nagari Sahakari Vs. Pr. Cit, Pune-1. Patsanstha Maryadit, At Post Bhingar, Ahmednagar Camp, S.O. Burhanagar, Ahilyanagar- 414002. Pan : Aadam4172H Appellant Respondent Assessee By : Shri Prasad S. Bhandari (Virtual) Revenue By : Shri Amol Khairnar Date Of Hearing : 02.12.2025 Date Of Pronouncement : 09.02.2026 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 28.03.2025 Passed U/S 263 Of The It Act By Ld. Pr. Cit, Pune-1 [‘Ld. Pcit’] For The Assessment Year 2020-21. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. On The Facts & In The Prevailing Circumstances Of The Case, Respected Pcit Pune 1 Erred Passing The Impugned Revision Order Under Section 263 Without Appreciating The Fact That Interest On The Deposits Made By A Assessee Co-Operative Society Out Of Its Business Proceeds With The Co-Operative Bank Is Eligible

For Appellant: Shri Prasad S. Bhandari (Virtual)For Respondent: Shri Amol Khairnar
Section 143(3)Section 263Section 80PSection 80P(2)Section 80P(2)(d)Section 80P(2)(f)

Taxman 282 (SC) and accordingly held that the interest income earned on surplus funds was taxable under the head ‘Income from other sources’ and the FAO has not verified this aspect. Accordingly, the assessment order dated 23.09.2022 was set-aside to the file of the Assessing Officer to reframe