“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

Assistant Commissioner of Income Tax, Circle-2(1), Hyderabad vs. Jsw Energy (Utkal) Limited, Hyderabad

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

ITA 36/HYD/2024[2016-17]Status: DisposedITAT Hyderabad11 Feb 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Rakesh Joshi, C.AFor Respondent: : Shri B. Bala Krishna, CIT-DR

Section 142(1)Section 143(3)Section 147Section 148

that the assessee had claimed deduction on account of interest expenditure of Rs.28,86,53,896/- under the head of ‘income from other sources’, out of interest income from bank Fixed Deposit Receipts (“FDRs”). Since the assessee had not commenced its business till

Asst. Commissioner of Income Tax, Central Circle-3(1), Hyderabad vs. B.Ramalinga Raju, Hyderabad

In the result, the appeal of Revenue in ITA No

ITA 57/HYD/2020[2002-03]Status: DisposedITAT Hyderabad11 Feb 2025AY 2002-03

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri K.C. Devdas, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR

Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 148(2)

Assessing Officer in respect to irrevocable loss to the tune of Rs.2,36,84,000/- and the contention on account of unexplained income from other sources were examined by the Assessing Officer after recording the satisfaction during the course of assessment, however, these two were having live link with ... individual hands. Hence, an amount of Rs.45,87,20,000/- is treated as. unexplained income of Sri B. Ramalinga Raju under the head Income from Other Sources and the same is brought to tax accordingly. 8.3 From the above discussion, it is clear that the assessee Sri B. Ramalinga Raju

Asst. Commissioner of Income Tax, Central Circle-3(1), Hyderabad vs. B.Ramalinga Raju, Hyderabad

In the result, the appeal of Revenue in ITA No

ITA 55/HYD/2020[2002-03]Status: DisposedITAT Hyderabad11 Feb 2025AY 2002-03

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri K.C. Devdas, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR

Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 148(2)

Hiranand Family Trust, Mumbai vs. Income Tax Officer, Ward 17(3)(1), Kautilya Bhavan

In the result, the appeal of the assessee is allowed

ITA 6335/MUM/2024[2018-2019]Status: DisposedITAT Mumbai11 Feb 2025AY 2018-2019

Bench: Ms. Kavitha Rajagopal & Smt. Renu Jauhrihiranand Family Trust V/S. Ito Ward 17(3)(1), Mumbai 6Th Floor, Mistry Bhavan, बनाम Kautilya Bhavan, Bandra Dinshaw Vaccha Road, Kurla Complex, Bandra Churchgate, Mumbai- East, Mumbai-400051 400020 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Mumh10606B Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Hemanshu Joshi

Section 139(9)Section 250Section 270ASection 44A

inadvertently submitted a revised return in which the interest amount of Rs. 99,62,600/- did not get posted in the ‘Schedule of Income from other sources’ even though the information about interest income was included and shown in the Schedule of Profit and Loss account

Jsc Ogcc Kazstroy Service Project Office, Gurgaon vs. DCIT Intl. Taxation, Gurgaon

In the result, appeal of the assessee is allowed

ITA 2228/DEL/2023[2020-21]Status: HeardITAT Delhi11 Feb 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalita Nos.2228 & 2229/Del/2018 & 7004 & 7005/Del/2019 [Assessment Year : 2014-15 & 2015-16 & 2014-15 & 2015-16] Kaajal Aijaz Ilmi, Vs Acit, C/O-Rra Tazindia, D-28, Central Circle-20, South Extension, Part-1, New Delhi New Delhi-110049. Pan-Aabpi4222R Appellant Respondent Appellant By Shri Rakesh Gupta, Adv., Shri Somil Agarwal, Adv. & Shri Deepesh Garg, Adv. Respondent By Ms. Monika Singh, Cit Dr Date Of Hearing 17.07.2025 Date Of Pronouncement 30.07.2025

Section 1Section 132Section 132(1)Section 143(2)Section 153ASection 153DSection 250Section 271(1)(c)Section 56(1)(vii)

year under appeal, the assessee had earned income of heard “Salaries” at INR ITA Nos.2228 & 2229/Del/2018, 7004 & 7005/Del/2019 52,15,594/- and “Income from other sources” at INR 7,16,584/-. Assessee in her capital account shown a gift of INR 65,61,314/0 from Dr. Mohd. Aijaj Ilmi

Yogendra Prasad Sharma, Patna vs. Dc/Ac Circle-6, Patna

The appeal of the assessee is allowed for statistical purposes

ITA 6/PAT/2025[2017-18]Status: HeardITAT Patna10 Feb 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.06/Pat/2025 Assessment Year: 2017-18 Yogendra Prasad Sharma………………………………………..………….……Appellant 0 Matukdhari Niwas, West Boring Canal Road Boring Road, Patna-800001. [Pan: Aoppd7881R] Vs. Dc/Ac, Circle-6, Patna……..……....….….. ……………….........……...…..…..Respondent Appearances By: Shri Sagar Warsi, Ar, Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit - Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 06, 2025 Date Of Pronouncing The Order : February 10, 2025 Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against An Order Dated 30.05.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. At The Outset, The Registry Has Informed That There Is A Delay Of 160 Days In Filing The Present Appeal. The Assessee Filed An Application For Condonation Of Delay Stating Reasons For Such Delay. After Considering The Application, We Find Reasonable Cause & The Delay Was Not Intentional. We, Therefore, Condone The Delay In Filing The Appeal & Adjudicate The Appeal On Merits Of The Case. 3. Brief Facts Of The Case Are That The Assessee Is An Individual & Filed His Return Of Income By Declaring Total Income Of Rs.11,32,280/-

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

income of Rs.11,32,280/- I.T.A. No.06/Pat/2025 Assessment Year: 2017-18 Yogendra Prasad Sharma under the head salaries, income from house properly and income from other sources. In addition of this, the assessee has also shown agricultural income of Rs.18,64,000/- during the relevant year. The case

Hinganghat Nagri Sahakari Pat Sanstha, Hinganghat vs. Income Tax Officer Ward-1, Wardha

In the result, appeal by the assessee for A

ITA 569/NAG/2024[2022-23]Status: DisposedITAT Nagpur10 Feb 2025AY 2022-23

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

For Appellant: Shri Suyash RankaFor Respondent: Shri Abhay Y. Marathe

Section 56Section 80P

That the Ld. Commissioner (Appeals) has erred in Law as well as in Facts by sustaining the addition of Rs.41,88,448/- as Income from other Source of Income and the attributes of activity carried out by the Appellant. 2. That the Ld. Commissioner (Appeals) has erred ... extent of Rs.41,88,448/- in respect of interest income by treating interest income received on FD of Nationalized Banks as income from other sources u/s 56 of Income Tax Act, 1960 by wrongly applying ratio laid down by Supreme Court in the case of Totagars Co. Op. sale Society

Hinganghat Nagri Sahakari Pat Sanstha, Hinganghat vs. Income Tax Officer Ward-1, Wardha

In the result, appeal by the assessee for A

ITA 568/NAG/2024[2020-21]Status: DisposedITAT Nagpur10 Feb 2025AY 2020-21

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

For Appellant: Shri Suyash RankaFor Respondent: Shri Abhay Y. Marathe

Section 56Section 80P

Hinganghat Nagri Sahakari Pat Sanstha, Hinganghat vs. Income Tax Ward-1, Wardha

In the result, appeal by the assessee for A

ITA 567/NAG/2024[2018-19]Status: DisposedITAT Nagpur10 Feb 2025AY 2018-19

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

For Appellant: Shri Suyash RankaFor Respondent: Shri Abhay Y. Marathe

Section 56Section 80P

Hinganghat Nagri Sahakari Pat Sanstha, Hinganghat vs. Income Tax Ward-1, Wardha

ITA 566/NAG/2024[2015-16]Status: DisposedITAT Nagpur10 Feb 2025AY 2015-16

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

For Appellant: Shri Suyash RankaFor Respondent: Shri Abhay Y. Marathe

Section 56Section 80PSection 80P(1)

Panjabrao Deshmukh Nagari Sahakaripat Sanstha Maryadit Buldana, Buldana vs. Income Tax Officer Ward-2, Khamgaon

In the result, ITA.No.531/NAG

ITA 531/NAG/2024[2020-21]Status: DisposedITAT Nagpur10 Feb 2025AY 2020-21

Bench: Shri V. Durga Rao & Shri Khettra Mohan Roy

For Appellant: Shri K.P. Dewani, AdvocateFor Respondent: Shri Abhay Y. Marathe, Sr DR

Section 147Section 69Section 80P

amount received from the Members of Co-operative Society is assessable under the Head “Income from Business” and not under the Head “Income from other sources” and following the decision of The Ismailia Urban Co-operative Society vs. ITO in ITA.No.122/Nag./2023, dated 18.06.2024, held that assessee is eligible

Panjabrao Deshmukh Nagari Sahakaripat Sanstha Maryadit Buldana, Buldana vs. Income Tax Officer Ward-2, Khamgaon

ITA 530/NAG/2024[2016-17]Status: DisposedITAT Nagpur10 Feb 2025AY 2016-17

Bench: Shri V. Durga Rao & Shri Khettra Mohan Roy

For Appellant: Shri K.P. Dewani, AdvocateFor Respondent: Shri Abhay Y. Marathe, Sr DR

IN THE INCOME TAX APPELLATE TRIBUNAL NAGPUR BENCH : NAGPUR BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI KHETTRA MOHAN

Panjabrao Deshmukh Nagari Sahakaripat Sanstha Maryadit Buldana, Buldana vs. Income Tax Officer Ward-2, Khamgaon

In the result, ITA.No.531/NAG

ITA 529/NAG/2024[2014-15]Status: DisposedITAT Nagpur10 Feb 2025AY 2014-15

Bench: Shri V. Durga Rao & Shri Khettra Mohan Roy

For Appellant: Shri K.P. Dewani, AdvocateFor Respondent: Shri Abhay Y. Marathe, Sr DR

Section 147Section 69Section 80P

Panjabrao Deshmukh Nagari Sahakaripat Sanstha Maryadit Buldana, Buldana vs. Income Tax Officer Ward-2, Khamgaon

In the result, ITA.No.531/NAG

ITA 528/NAG/2024[2013-14]Status: DisposedITAT Nagpur10 Feb 2025AY 2013-14

Bench: Shri V. Durga Rao & Shri Khettra Mohan Roy

For Appellant: Shri K.P. Dewani, AdvocateFor Respondent: Shri Abhay Y. Marathe, Sr DR

Section 147Section 69Section 80P

The Cannanore Taluk Co Operative Employees Cooperative Society Ltd, Kannur vs. ITO, Ward 1 & Tps, Kannur

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

ITA 961/COCH/2024[2020-21]Status: DisposedITAT Cochin10 Feb 2025AY 2020-21

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2020-21 Cannanore Taluk Co-Op. Employees .......... Appellant Co-Op. Society Ltd. Caltex, Civil Station Post, Kannur 670002 [Pan: Aabtt4875F] Vs. The Income Tax Officer .......... Respondent Ward - 1 & Tps, Cannore

For Appellant: ------- None -------For Respondent: Smt. Leena Lal, Sr. D.R

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

Bank/State Co-operative Bank, in the facts and circumstances of the case, do come within Section 80P(2)(d). Therefore, the income constitutes income from other sources and the only eligible deduction is covered by Section 80P(2)(d) viz. Interest or dividend derived by the assessee from its investments

Shree Mahaveer I. Dhamani Vikas Society Ltd. Inamdhamani, Sangli vs. ITO W 1 Sangli, Sangli

In the result, appeal of the assessee is allowed

ITA 2809/PUN/2024[2021-22]Status: DisposedITAT Pune10 Feb 2025AY 2021-22

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2809/Pun/2024 िनधा"रण वष" / Assessment Year: 2021-22 Shree Mahaveer Dhamani V The Income Tax Officer, Vikas Society Limited, S Ward-1, Sangli. At Post Inamdhamani, Tal Miraj, Distsangli, Sangli – 416416. Pan: Aawas2530G Appellant/ Assessee Respondent / Revenue Assessee By None Revenue By Miss Indira R Adakil – Addl.Cit(Dr) Date Of Hearing 30/01/2025 Date Of Pronouncement 10/02/2025 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(Appeals)[Nfac] For

Section 10Section 143(3)Section 250Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

case and in law, the Learned CPC and NFAC, erred in taxing the amount of Rs.4,36,926/- by treating the same as income from other sources and, hence not eligible for deduction u/s 80P(2)(a)(i) or even under section 80P(2)(d) without properly appreciating the submissions ... high courts and jurisdictional ITAT benches on identical facts. 2. The reasons assigned for taxing the amount of Rs.4,36,926/- as income from other sources are wrong, insufficient and contrary to the provisions of law and facts on record and, hence, the addition made be deleted in full

Springer Nature Technology and Publishing Solutions Private Limited, Pune vs. The Assistant Commissioner of Income Tax, Circle-1(1), Pune

The appeal of the Assessee is Partly Allowed for

ITA 418/PUN/2023[2017-18]Status: DisposedITAT Pune10 Feb 2025AY 2017-18

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपीलसं. / Ita No.418/Pun/2023 निर्धारणवर्ष / Assessment Year: 2017-18 Springer Nature Technology & Publishing Solutions Pvt. Ltd., Upper Ground Tower 8, Magarpatta City, Pune-411013. Pan: Aaccc8853E Appellant/ Assessee V The Assistant S Commissioner Of Income Tax, Circle-1(1), Pune. Respondent / Revenue Assessee By Shri Vishal Kalra – Ar Revenue By Shri Keyur Patel, Irs –Cit(Dr) Date Of Hearing 19/12/2024 Date Of Pronouncement | 10/02/2025 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(Appeals) [Nfac] For

Section 10ASection 143(3)Section 250

holding that interest income earned of INR 1,79,01,588 on short term deposits is liable to be taxed under the head 'Income from Other Sources' as against 'Profits of business' as claimed by the Appellant. 3. The learned CIT (Appeals) erred in placing reliance on Jurisdictional ... while computation of deduction under section 10AA of the Act by the Appellant and the assessing officer has also taxed the same as income from other sources. Others 5. Each one of the above grounds of appeal is without prejudice to the other 6. The Appellant craves leave

Shamoon Ahmed Mulla, Thane vs. ITO Ward 2(4), Mumbai

In the result, appeal of the assessee is allowed

ITA 6070/MUM/2024[2015-16]Status: DisposedITAT Mumbai10 Feb 2025AY 2015-16

Bench: Shri Sandeep Gosain & Shri Girish Agrawalassessment Year: 2015-16

For Appellant: Shri Akash Singh, AdvocateFor Respondent: Ms. Monika H. Pande, Sr.DR

Section 143(3)Section 271(1)(c)Section 56(2)(vii)

applicable. Accordingly, the difference of Rs.1,38,38,000/- between the stamp duty value and the actual purchase value was added as income from other sources u/s. 56(2)(vii)(b) while completing the assessment. 4.1. In the penalty proceedings, ld. Assessing Officer noted that valuation report from Valuation Officer ... Tribunal. 5. Thrust of assessee in his appeal is that it has been imposed on income which has been added under the head ‘Income from other sources’ under a deeming provision of section 56(2)(vii)(b) of the Act. According to the assessee, it is a settled position

The DCIT (Int.Taxa.), Vadodara vs. Shri Ajoy Kanaiyalal Khandheria, Vadodara

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

ITA 451/AHD/2019[2014-15]Status: HeardITAT Ahmedabad10 Feb 2025AY 2014-15

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.451/Ahd/2024 िनधा"रण वष" /Assessment Year : 2012-13 Ranjitsinh Narsinh Vaghela The Income Tax Officer बनाम/ 3337, Nr. Palaiya Mahakali Ward-3 V/S. Mandir Gandhinagar Pethapur, Gandhinagar Gandhinagar – 382 610 "थायी लेखा सं./Pan: Afepv 3269 D (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Shri Hardik Vora, Advocate Revenue By : Shri R.N. Dsouza, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 10/01/2025 घोषणा की तारीख /Date Of Pronouncement: 15/01/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: This Appeal Has Been Preferred By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “Cit(A)”], Dated 19/01/2024, For The Assessment Year (Ay) 2012-13, Which Upheld The Order Of The Assessing Officer [Hereinafter Referred To As “Ao”] Dated 30/12/2019, Passed Under Section 144 R.W.S. 147 Of The Income Tax Act, 1961 [Hereinafter Referred To As "The Act"]. Ranjitsinh Narsinh Vaghela Vs. Ito Asst. Year : 2012-13

For Appellant: Shri Hardik Vora, AdvocateFor Respondent: Shri R.N. Dsouza, CIT-DR

Section 10(37)Section 144Section 147Section 148

interest received on compensation in a motor accident claim is part of the compensation itself and, hence, is not taxable as "income from other sources." • Gujarat High Court Decision in the case of Movaliya Bhikhubhai Balabhai v. ITO (Special Civil Application No. 17944 of 2015): The Hon'ble Gujarat High ... assessee after the final judgment. However, the AO held that the interest accrued on FDs is not part of the compensation but constitutes "income from other sources" under Section 56 of the Act. The AO noted that the payment of additional compensation was deposited in the Ranjitsinh Narsinh Vaghela

Satish Prakash Agarwal, Agra vs. The ACIT, Circle 1(2)(1), Agra

In the result, appeal of the assessee is allowed

ITA 113/AGR/2021[2016-17]Status: DisposedITAT Agra07 Feb 2025AY 2016-17

Bench: : Shri Ramit Kocharassessment Year: 2016-17

Section 143(2)Section 143(3)Section 36(1)(iii)

unsecured loans were also utilized for advancing loan to parties from whom interest income was earned and offered for tax under the head 'Income from Other Sources' and therefore the appellant prays to allow further deduction to the extent of interest income of Rs. 13,96,689/- offered ... under the head 'Income from Other Sources'. 5. That on the facts and in the circumstances of the case and in law, the Ld. CIT(A), NFAC erred in not specifically directing the Ld. Assessing Officer to delete the addition of Rs. 10,06,265/- separately made