“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

M.P. Veerachandra Chettiyar, Kadavanthara vs. ITO, Ward-1(5), Range-1, Non Corporate Ward-1(50, Kochi

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

ITA 557/COCH/2024[2014-15]Status: DisposedITAT Cochin27 Jan 2025AY 2014-15

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.Assessment Year : 2014-15

For Respondent: Smt. Divya Ravindran

Section 56(2)(vii)

pursuant to the order of the Ld.CIT(A), had verified the documents and added an amount of Rs. 63,90,000/- as income from other sources. The assessee explained the fact that he had purchased the properties as trading stock which was purchased for a very cheap rate because

Punalur Service Cooperative Bank Ltd, Punalur vs. Income Tax Officer, Ward 2, Kollam

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

ITA 668/COCH/2023[2017-18]Status: DisposedITAT Cochin27 Jan 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am & Shri Soundararajan K., Jm Assessment Year: 2017-18 Punalur Service Co-Op. Bank Ltd. Punalur Post, Kollam 691305 [Pan: Aagas6524C] .......... Appellant Vs. The Income Tax Officer Ward - 2, Kollam .......... Respondent

For Appellant: Shri Santosh P. Abraham, AdvocateFor Respondent: Shri Sanjit Kumar Das, CIT-DR

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

Prem Lata Pandya, Jaipur vs. Deputy Commissioner of Income Tax, Central Circle-4, Jaipur

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

ITA 1471/JPR/2024[2019-20]Status: DisposedITAT Jaipur27 Jan 2025AY 2019-20

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR, JM आयकर अपील सं. / ITA No. 1471/JPR/2024 निर्धारण वर्ष / Assessment Year :2019-20 Prem Lata Pandya बनाम Deputy Commissioner of 302, Raj Mension, D-299, Vs. Income Tax, Tulsi Marg Bani Park, Central Circle-4, Jaipur. Jaipur अपीलार्थी / Appellant प्रत्यर्थी / Respondent स्थायीलेखा सं./ जीआईआर सं./ PAN/GIR No.:ACXPJ9951A निधर्धारिती की ओरसे / Assessee by : Sh. S.L.Poddar, Adv. राजस्व की ओरसे / Revenue by: Sh. Gautam Singh

For Appellant: Sh. S.L.Poddar, AdvFor Respondent: Sh. Gautam Singh Choudhary, JCIT

Section 115BSection 127Section 132ASection 142(1)Section 143(2)Section 143(3)Section 69A

High Court that once the income was offered during survey as business income, the same cannot be treated as income from other sources and provisions of Sec. 69 will not be applicable. (6) Amitabh B Parekh Navsari Vs. Department of Income Tax (ITAT Ahmedabad (ITA No.3138/Ahd/2008 dated 21/01/2011 ... other than business income. During the course of search also no any such evidence was found that the assessee is having any unaccounted income from other sources. The assessee has explained the source that it is out of withdrawal from various bank accounts. But to purchase peace of mind

Suresh Kumar Saini, Jaipur vs. NFAC, Delhi

16. For the foregoing discussion and findings, this appeal deserves to be allowed

ITA 1256/JPR/2024[2016-17]Status: DisposedITAT Jaipur27 Jan 2025AY 2016-17

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Sh. Neeraj Gupta, C.AFor Respondent: Sh. Anup Singh, Addl.CIT

Section 143(3)Section 148Section 234ASection 250Section 271(1)Section 271(1)(c)Section 69

second addition of Rs. 5,48,550/-, i.e. income claimed by the assessee from agriculture, but assessed by the Assessing Officer as income from other sources, Learned CIT(A) rejected the same for the reasons recorded therein and upholding the reasons recorded by the Assessing Officer. 4. In view ... assessee as regards loans and advances from the agriculturists. It is ordered accordingly. 2nd Addition Whether a case of agriculture income or income from other sources:- 15. As is available from the assessment order, the assessee, in his reply to the notice u/s 148 of the Act, claimed that during

Prem Chand Gupta, Alwar vs. ITO Ward 2(3), Alwar

16. For the foregoing discussion and findings, this appeal deserves to be allowed

ITA 1251/JPR/2024[2012-13]Status: DisposedITAT Jaipur27 Jan 2025AY 2012-13

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Sh. Neeraj Gupta, C.AFor Respondent: Sh. Anup Singh, Addl.CIT

Section 143(3)Section 148Section 234ASection 250Section 271(1)Section 271(1)(c)Section 69

Pani Purvatha Karmachari Sahakari Pat Sanstha Maryadit Kolhapur, Kolhapur vs. Income Tax Officer, Kolhapur

In the result, appeal of the assessee is allowed

ITA 2663/PUN/2024[AY 2018-19]Status: DisposedITAT Pune27 Jan 2025

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2663/Pun/2024 िनधा"रण वष" / Assessment Year: 2018-19 Pani Purvatha Karmachari V The Income Tax Officer, Sahakari Pat Sanstha Maryadit S Kolhapur. Kolhapur, 431-E Tej Apartment, Basant – Bahar Road, Shahupuri, Kolhapur – 416001. Pan: Aaaap1588M Appellant/ Assessee Respondent / Revenue Assessee By None. Revenue By Shri Harshit Dilip Bari – Addl.Cit(Dr) Date Of Hearing 23/01/2025 Date Of Pronouncement 27/01/2025 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(Appeal)[Nfac] Passed U/Sec.250 Of The Income Tax Act, 1961, For The A.Y.2018-19 Dated 21.11.2024. The Assessee Has Raised The Following Grounds Of Appeal :

Section 139(1)Section 250Section 80PSection 80P(2)(a)Section 80P(2)(d)

held that interest income of Rs.8,47,807/- is not eligible for deduction under section 80P of the Act and treated it as income from other sources. Ld.CIT(A) confirmed the assessment order. 4.2 Thus, it is an admitted fact that assessee is a Co-operative Credit Society, registered under

Rekha Kishore Bari, Dhule vs. Assessing Officer-NFAC, Delhi

In the result appeal of the assessee is partly allowed for statistical purpose

ITA 1667/PUN/2024[2020-21]Status: DisposedITAT Pune27 Jan 2025AY 2020-21

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1667/Pun/2024 िनधा"रण वष" / Assessment Year: 2020-21 Rekha Kishore Bari, V The Assessing Officer- Datta Bari Bhavan, S Nfac. Opp.Rana Pratap Statute, Dhule – 424001. Pan: Abepb3597J Appellant/ Assessee Respondent / Revenue Assessee By Shri Bhuvanesh Kankani – Ar Revenue By Shri Sandeep P Sathe – Jcit(Dr) Date Of Hearing 09/12/2024 Date Of Pronouncement 27/01/2025 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 Assessment Year 2020-21 Dated 19.07.2024 Passed U/Sec.250 Of The Income Tax Act, 1961, Emanating From The Assessment Order U/S 143(3) R.W.S. 144B Of The Act, Dated 31/08/2022. The Assessee Has Raised The Following Grounds Of Appeal :

Section 143(3)Section 250Section 3GSection 56(2)

cannot be dealt in manner similar to that of principal sum of compensation. i.e., if interest so received is to be considered as 'Income from other sources', in that case, our submission would be, 5.2. Firstly, it be please noted that, NHAI has challenged the enhanced compensation received ... Aurangabad. 4.4 The Assessing Officer in the Assessment Order dated 31/08/2022, held that the 50% of the Interest on Compensation is taxable as Income from Other Sources. The Assessing Officer(AO) also did not allowed expenditure claimed by the assessee in the revised return. ITA No.1667/PUN/2024 [A] 4.4.1 Aggrieved

Muthurathinam, Tiruppur vs. ITO, Ward-1(2), Tiruppur

In the result, appeal filed by the assessee is allowed

ITA 2656/CHNY/2024[2013-14]Status: DisposedITAT Chennai27 Jan 2025AY 2013-14

Bench: Hon’Ble Shri Manoj Kumar Aggarwal & Hon’Ble Shri Manu Kumar Giriआयकरअपील सं./ Ita No.2656/Chny/2024 (िनधा"रणवष" / Assessment Year: 2013-2014) Muthurathinam, Vs. The Income Tax Officer, 27/29, Kumarappapuram, Ward 1(2) 1St Street, Rayapuram Extension, Tirupur. Tirupur 641 601. [Pan: Avypm 0862D] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. S. Sridhar, (Erode) Advocate By Virtual. ""यथ" क" ओर से /Respondent By : Ms. Anitha, Irs, Addl. Cit. सुनवाई क" तार"ख/Date Of Hearing : 31.12.2024 घोषणा क" तार"ख /Date Of Pronouncement : 27.01.2025 आदेश / O R D E R Per Manu Kumar Giri () This Penalty Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] Dated 21.08.2024 For Assessment Year 2013-14. 2. The Issue Sought To Be Urged By The Assessee In This Appeal Is Whether The Cit(A) Was Justified In Upholding The Penalty Under Section 271(1)(C) Of The Income Tax Act, 1961 ["Act"] By Ignoring The Fact That The Assessing Officer (‘Ao’ In Short) In Assessment Order Dated 28.09.2021 Has Satisfied That Penalty Proceeding Is Being Initiated Separately For “Furnishing Of Inaccurate Particulars Of Such Income” Where As Penalty Order U/S 271(1)(C) Dated 04.01.2022 Levied Penalty For “Concealment Of Income”, Although In The Notice Under Section 274 Read With Section 271(1) (C), The Ao Has Marked The Specified Limb As “That You Have Furnished Inaccurate Particulars Of Such Income”.

For Appellant: Shri. S. Sridhar, (Erode) Advocate by virtualFor Respondent: Ms. Anitha, IRS, Addl. CIT

Section 143(2)Section 143(3)Section 148Section 151Section 271Section 271(1)Section 271(1)(c)Section 274Section 44A

Return on 24.07.2020 declaring total income of Rs. 26,46,770/- by disclosing additional income of Rs.19,98,843/- under the head "Income from other sources". Thereafter, notices u/s. 143(2) and 142(1) were issued and the appellant had submitted his replies. The assessment was completed ... assessing officer treated the additional income of Rs.19,98,843 offered by the appellant as 'business income' as against his claim as "Income from Other Sources" in the return of income. Penalty proceedings under section 271(1)(c) were separately initiated for 'furnishing. inaccurate particulars of such income vide notice

M/S. Hind Mercantile Corporation P. Ltd., Namakkal vs. DCIT, CC-1(4), Chennai

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

ITA 1967/CHNY/2024[2016-17]Status: DisposedITAT Chennai27 Jan 2025AY 2016-17

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita No.1967/Chny/2024 िनधा"रण वष" /Assessment Year: 2016-17

For Respondent: Shri R. Clement Ramesh Kumar, CIT

Section 143(3)Section 153CSection 56(2)(ix)

therefore, initiated proceedings u/s. 153C of the Act in the case of assessee and added cash received amounting to Rs.26.40 Crores as income from other sources u/s. 56(2)(ix) of the Act. Being aggrieved, the assessee filed appeal before

Puran K Jain (HUF), Mumbai vs. Income Tax Officer, Ward 41 (2) (4 ), Mumbai

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

ITA 3800/MUM/2024[2017-18]Status: DisposedITAT Mumbai27 Jan 2025AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankarpuran K Jain (Huf) Vs Income-Tax Officer, Wad-41(2)(4) 17/253, Tagore Nagar, Vikhroli Mumbai, (East), Mumbai-400 083 Kautilya Bhavan, Bkc, Bandra (East), Pan: Aajhp2523E Mumbai-400051 Appellant Respondent

For Appellant: Shri Anant PaiFor Respondent: Shri Kiran Unavekar SR DR

Section 143(3)Section 250Section 44A

business income amount to Rs.2,45,543/-. During assessment, the Ld.AO found that the assessee declared only the interest under the head ‘Income from other sources’. No business income was declared. During the assessment proceedings, the assessee submitted the month-wise list for sale and purchase of the goods

Shree Sarvodaya Sahakari Mandali Ltd., Vadodara vs. NFAC, Delhi Present Jurisdiction the Dy.CIT, Circle-2(1)(1), Vadodara

In the result, both the appeals of the assessee are allowed

ITA 1349/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad24 Jan 2025AY 2017-18

Bench: Dr.Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Viranch Modi, A.RFor Respondent: Ms. Ketaki Desai, Sr. DR

Section 143(3)Section 147Section 80Section 80PSection 80P(2)(d)

plea that interest earned on deposits kept with and on saving bank accounts kept with Co-operative banks is chargeable under the head “Income from other sources” and eligible for deduction u/s.80P of the Act. 2.02 Your appellant further submits that out of funds received from its member i.e operational

Shree Sarvodaya Sahakari Mandali Ltd., Vadodara vs. NFAC, Delhi Present Jurisdiction the Dy. CIT, Cicle-2(1)(1), Vadodara

In the result, both the appeals of the assessee are allowed

ITA 1348/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad24 Jan 2025AY 2016-17

Bench: Dr.Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Viranch Modi, A.RFor Respondent: Ms. Ketaki Desai, Sr. DR

Section 143(3)Section 147Section 80Section 80PSection 80P(2)(d)

Jitendra Prakashchandra Shah, Ahmedabad vs. ACIT, Circle-1(1)(1), Ahmedabad

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

ITA 1083/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad24 Jan 2025AY 2018-19

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Anil Kshtriya, A.RFor Respondent: Shri B.P. Srivastava, Sr. DR

Section 36(1)(iii)Section 57

facts of the case are that the case of the assessee was selected for limited scrutiny on the issue of interest deduction against “income from other sources”. For the impugned year under consideration, the assessee had received interest income of Rs. 52,893/- from various concerns to whom the assessee ... assessee submitted that while preparing the return of income, interest expenses of Rs. 59,25,359/- has been wrongly claimed against “income from other sources”, instead of making such claim under the head “income from business or profession” under Section 36(1)(iii) of the Act since the same

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

In the result, appeal filed by the assessee in ITA

ITA 365/HYD/2018[2014-15]Status: DisposedITAT Hyderabad24 Jan 2025AY 2014-15

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.350 & 351/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Dy. C. I. T. Vs. Andhra Bank Circle-1(1) Hyderabad Hyderabad [Pan : Aabca7375C] (Appellant) (Respondent) आ.अपी.सं /Ita No.364 & 365/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Union Bank Of India Vs. Dy. C. I. T. (Erstwhile Andhra Bank) Circle-1(1) Mumbai Hyderabad [Pan : Aaacu0564G (Aabca7375C)] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.Ananthan & Smt.Lalitha Rameswaran, Ar रधजस् व द्वधरध/Revenue By: Shri K.Meghnath Chowhan, Cit-Dr सुिवधई की तधरीख/Date Of 05/11/2024 Hearing: घोर्णध की तधरीख/Date Of 24/01/2025 Pronouncement: आदेश/Order Per Manjunatha G., A.M

For Appellant: Shri S.Ananthan &For Respondent: Shri K.Meghnath Chowhan

Section 143(3)Section 36(1)Section 36(1)(viii)

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, appeal filed by the assessee in ITA

ITA 364/HYD/2018[2013-14]Status: DisposedITAT Hyderabad24 Jan 2025AY 2013-14

For Appellant: Shri S.Ananthan &For Respondent: Shri K.Meghnath Chowhan

Section 143(3)Section 36(1)Section 36(1)(viii)

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

In the result, appeal filed by the assessee in ITA

ITA 351/HYD/2018[2014-15]Status: DisposedITAT Hyderabad24 Jan 2025AY 2014-15

For Appellant: Shri S.Ananthan &For Respondent: Shri K.Meghnath Chowhan

Section 143(3)Section 36(1)Section 36(1)(viii)

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

In the result, appeal filed by the assessee in ITA

ITA 350/HYD/2018[2013-14]Status: DisposedITAT Hyderabad24 Jan 2025AY 2013-14

For Appellant: Shri S.Ananthan &For Respondent: Shri K.Meghnath Chowhan

Section 143(3)Section 36(1)Section 36(1)(viii)

ITO 19(2)(4), Mumbai vs. Pallon Shapoorji Mistry, Mumbai

In the result, grounds raised by the Revenue are dismissed

ITA 1408/MUM/2024[2020-21]Status: DisposedITAT Mumbai24 Jan 2025AY 2020-21

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2020-21

For Appellant: Shri Porus Kaka, Sr. Advocate and Shri Divesh Chawla, AdvocateFor Respondent: Shri Jayant Jhaveri, CIT DR

Section 143(3)Section 144Section 145Section 3

section 145 which are reproduced as under: “145. (1) Income chargeable under the head "Profits and gains of business or profession" or "Income from other sources" shall, subject to the provisions of sub-section (2), be computed in accordance with either cash or mercantile system of accounting regularly employed ... income has not been computed in accordance with the standards notified under” 4.9. Sub-section 1 inter alia requires that in respect of income from other sources, the method of accounting could be either cash or mercantile system regularly employed by the assessee subject to income computation and disclosure standards

Excelra Knowledge Solutions Private Limited, Hyderabad vs. DCIT, Circle-8(1), Hyderabad

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

ITA 202/HYD/2023[2020-21]Status: DisposedITAT Hyderabad23 Jan 2025AY 2020-21

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.202/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2020-21) Excelra Knowledge Vs. Dy. Cit Solutions (P) Ltd, Circle 8(1) Hyderabad Hyderabad Pan:Aafcg5715Q (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri H. Srinivasulu, Advocate राज" व "ारा/Revenue By:: Shri Kumar Pranav, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 25/11/2024 घोषणा की तारीख/Pronouncement: 23/01/2025 आदेश/Order Per Vijay Pal Raothis Appeal Filed By The Assessee Is Directed Against The Order Dated10/02/2023 Of The Learned Cit (A)-Nfac Delhi, Relating To A.Y.2020-21. 2. The Assessee Has Raised The Following Grounds:

For Appellant: Shri H. Srinivasulu, AdvocateFor Respondent: : Shri Kumar Pranav, CIT(DR)

Section 10ASection 143(1)Section 438Section 43B

Knowledge Solutions P Ltd “1. Ld A.O/Ld CIT(A), NEAC erred in taxing the interest Income of Rs. 4,40,41,931 under income from other sources and Income from Business. Interest income was credited in P&L a/c. Action of Ld A.O resulted in double addition of same income ... contended that the interest income has already been credited to the P&L Account and therefore, making addition under the head “income from other sources” resulting a double addition of the same income. On these pleadings, we admit the additional grounds raised by the assessee for adjudication on merits

Value Labs LLP, Hyderabad vs. ACIT Circle-8(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 229/HYD/2022[2009-10]Status: DisposedITAT Hyderabad23 Jan 2025AY 2009-10

Bench: Shri Manjunatha. G & Shri K.Narasimha Charyआ.अपी.सं / Ita No. 229/Hyd/2022 ("नधा"रण वष" / Assessment Year: 2009-10) Value Labs Llp, Vs. Acit, Hyderabad. Circle-8(1), [Pan : Aakfv2276K] Hyderabad. अपीलाथ" / Appellant "" यथ" / Respondent

For Appellant: Shri P. Murali Mohan Rao, ARFor Respondent: Shri Suresh Babu KN, Sr. AR

Section 10ASection 41(1)Section 56

directly related to export business of the assessee, and disallowed exemp"on on the interest income by trea"ng the same as income from other sources u/s 56 of the Act and passed assessment order dated 31/03/2013, determining the taxable income of Rs. 5,75,94,250/-, thereby allowing ... learned Assessing Officer, a"er verifica"on of the record, classified the interest amount of Rs. 5,03,74,781/- as income from other sources under Sec"on 56 of the Act. As a result, learned Assessing Officer denied the exemp"on under