“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

V S Trust, Chennai vs. ITO, Ncw-3(5), Chennai

In the result, the appeal of the assessee is allowed

ITA 2633/CHNY/2025[2022-23]Status: DisposedITAT Chennai28 Jan 2026AY 2022-23

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.Vikram VijayaraghavanFor Respondent: Mr.Shiva Srinivas, CIT

Section 234DSection 250Section 270ASection 56(2)(vii)Section 56(2)(x)

making an addition of INR 15,78,40,401/- on account of shares of various companies settled/ contributed to the Appellant as ‘Income from other sources’ under section 56(2)(x) of the IT Act. 4. On the facts and in the circumstances of the case ... addition of INR 12,00,00,000/- in relation to advance tax payment claimed as refund in the return of Income as ‘income from other sources’ under section 56(2)(x) of the IT Act. 10. On the facts and in the circumstances of the case

Ministry of Communications Employees Co-Operative Housing Society Limited, Bangalore vs. Pr. Commissioner of Income Tax, Bengaluru-1, Bengaluru

In the result, the appeal of the assessee is hereby dismissed

ITA 1120/BANG/2025[2020-21]Status: DisposedITAT Bangalore28 Jan 2026AY 2020-21

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2020-21

For Appellant: Shri Aprameya, AdvocateFor Respondent: Shri Subramanian, JCIT

Section 143(3)Section 144BSection 263Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

According to the Ld. PCIT, such interest income ought to have been assessed under the head “Income from Other Sources” and taxed under section 56 of the Act. 4.1 In response to the SCN issued by the Ld. PCIT, the assessee submitted that it is a housing co-operative society ... operative society from investment of surplus or idle funds, even when placed with co-operative banks, partakes the character of “Income from Other Sources” and is taxable under section 56 of the Act, and is not eligible for deduction under section 80P(2)(a)(i) of the Act. Consequently

Vikas Agarwal, Sambhal vs. Income Tax Officer, Sambhal

In the result, the appeal of the assessee is allowed

ITA 6268/DEL/2025[2014-15]Status: DisposedITAT Delhi28 Jan 2026AY 2014-15

Bench: Shri Mahavir Singh, Hon’Ble Vice- & Smt. Renu Jauhri, Hon’Ble

For Appellant: Shri Mohd. Saim, AdvocateFor Respondent: Shri Ajay Kumar Arora, Sr. DR

Section 147Section 148Section 2(14)Section 2(14)(iii)Section 250Section 56(2)(vii)

fifty thousand rupees, the stamp duty value of such property as exceeds such consideration shall be income chargeable to tax under the head "Income from other sources". 6.3.5 In the instant case, the appellant has purchased agricultural land having 1.216 Hectares, Khasra No: 298 situated at Village Begumpur, Dist: Sambhal

Suresh Chand Goel, New Delhi vs. ITO Ward-47(1), New Delhi

In the result, Appeal of the Assessee in ITA Nos

ITA 4379/DEL/2025[2009-10]Status: DisposedITAT Delhi28 Jan 2026AY 2009-10

Bench: Shri M. Balaganesh & Shri Raj Kumar Chauhanassessment Year : 2009-10 Suresh Chand Goel, Vs. Income Tax Officer, C/O 9, Atta-Ur-Rehman Lane, Ward 47(1), Civil Lines, New Delhi. New Delhi – 110 054. Pan: Afipg7505H

For Appellant: Shri S.B. Gupta, CAFor Respondent: Shri Nitin Kumar Jaiman, Sr. DR

Section 131Section 132ASection 143(2)Section 147Section 148Section 250

personally because he had never met him. It was further stated that the amount of Rs.77,88,000/- should not be treated as ‘Income from other sources’ and need not be added to the total income. The ld. AO did not find this reply satisfactory and concluded that the loan

Phi Seeds Pvt. Ltd., Hyderabad vs. DCIT, Circle- 19(2), New Delhi

In the result, the appeal of the Assessee is allowed

ITA 7655/DEL/2017[2012-13]Status: DisposedITAT Delhi28 Jan 2026AY 2012-13

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumar

For Appellant: Sh. Ajay Vohra, Sr. Adv., Sh. Aditya VohraFor Respondent: Ms. Monika Singh, CIT(DR)

Section 10(1)Section 143Section 143(3)Section 144CSection 144C(15)Section 92C

business income as against exempt agricultural income claimed by the assessee u/s. 10(1) of the Act and income from other sources. Against the above, assessee preferred the appeal before the Ld. CIT(A), who vide his impugned order dated 03.10.2017 by following his predecessor’s order in earlier years

Shirol Taluka Khajagi Shikshak Sevkanchi Shakari Pat Sanstha Maryadit, Jaysingpur (Rural) vs. Incometax Officer Ichalkaranji, Ichalkaranji

In the result, the appeal of the assessee is allowed

ITA 2665/PUN/2025[2015-16]Status: DisposedITAT Pune27 Jan 2026AY 2015-16

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.2665/Pun/2025 Assessment Year : 2015-16

For Appellant: Shri Pramod ShingteFor Respondent: Date of hearing

Section 147Section 148Section 2(19)Section 250Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

attributable to the activities of the society, thus disallowed the said sum and added back to the total income of the assessee as income from other sources u/s.56 of the Act. 4. Aggrieved assessee preferred appeal before ld.CIT(A) and the ld.CIT(A) upheld the action

Kishor Jagannath Satav, Pune vs. ITO Ward 12(4), Pune

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

ITA 2196/PUN/2025[2014-15]Status: DisposedITAT Pune27 Jan 2026AY 2014-15

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.2196/Pun/2025 धििाारण वर्ा / Assessment Year : 2014-15 Kishor Jagannath Satav, The Income Tax Officer, Fadai Chowk, Nagar Road, Ward – 12(4), Pune Wagholi, Taluka-Haveli, Vs. Pune-412207 Pan : Etaps5826K अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Digambar Surwase Department By : Shri Manish Mehta Date Of Hearing : 20-01-2026 Date Of 27-01-2026 Pronouncement : आदेश / Order Per Astha Chandra, Jm : The Appeal Filed By The Assessee Is Directed Against The Order Dated 22.01.2025 Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi [“Cit(A)/Nfac”] Pertaining To Assessment Year (“Ay”) 2014-15. 2. There Is A Delay Of 176 Days In Filing Of This Appeal Before The Tribunal For Which The Assessee Has Filed An Affidavit Explaining The Reasons For Such Delay. After Hearing Both The Sides, We Are Of The View That The Delay Is Attributable To The Sufficient Cause. We, Therefore, In Light Of The Decisions Of The Hon'Ble Supreme Court In The Case Of Collector, Land Acquisition Vs. Mst. Katiji & Ors. (1987) 167 Itr 471 (Sc) & In The Case Of Inder Singh Vs. The State Of Madhya Pradesh Reported In 2025 Live Law (Sc) 339, Condone The Said Delay & Proceed To Decide The Appeal.

For Appellant: Shri Digambar SurwaseFor Respondent: Shri Manish Mehta

Section 143(3)Section 148Section 234ASection 234BSection 250

addition of Rs.55,50,500/- to the returned income of the assessee on account of transfer of tenancy rights under the head „income from other sources‟. The Ld. CIT(A)/NFAC confirmed the addition made by the Ld. AO as the assessee failed to file any submission/replies before

Mahadev Tukaram Kurale, Kolhapur vs. ITO, Wrd-1(5), Kolhapur

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

ITA 2078/PUN/2025[2020-21]Status: DisposedITAT Pune27 Jan 2026AY 2020-21

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

For Respondent: Shri Basavaraj Hiremath

Section 147Section 148Section 148ASection 69A

circumstances of the case and in Law, the Ld. AO erred in making addition to total income of Rs.2,96,714/- as 2 income from other sources without considering facts and circumstances of the case. 3. On the facts and circumstances of the case

Karuppanna Gounder Paramasivam, Erode vs. DCIT, Circle-1, Erode

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

ITA 3363/CHNY/2025[2017-18]Status: DisposedITAT Chennai27 Jan 2026AY 2017-18

Bench: Ms. Padmavathy S & Shri Manu Kumar Giri

For Appellant: MR. S. Senthil Kumar, Adv

Section 143(3)Section 14ASection 69

total income of Rs. NIL. During the year, the Assessee had declared income from Profit and Gains from business and profession and income from other sources. 3. The Assessment Order has been passed u/s.143(3) dated 23.12.2019 making an addition of Rs.92,36,863.00/- u/s 69(A) being unexplained money

Amsteel Castings Private Limited, Chennai vs. Dy. Commissioner of Income Tax, Corporate Circle 1(1), Chennai

In the result, appeal of the assessee is allowed

ITA 3129/CHNY/2025[2021-2022]Status: DisposedITAT Chennai27 Jan 2026AY 2021-2022

Bench: Shri George George Kand Ms. Padmavathy.Sआयकर अपील सं./Ita No.3129/Chny/2025 िनधा"रण वष" /Assessment Year: 2021-22

For Respondent: Ms. R. Kavitha, Addl. CIT

Section 170ASection 250

while passing the order has considered the inter company dividend to the tune of Rs.1,73,50,000/- as income from other sources in the hands of the assessee. The assessee filed an appeal before the CIT(A) contending that the intercompany dividend gets nullified post merger and therefore ... treatment of the dividend by the AO as income from other sources is not correct. The CIT(A) however dismissed the said contention stating that, in the order of NCLT dated 06.04.2022 there is no specific finding on the treatment to be given for inter company dividend and that

The Ksrtc Employee Credit Co-Op Society Limited, Bagalkot vs. Income Tax Officer, Ward-1, Bagalkot

ITA 2274/BANG/2025[2017-18]Status: DisposedITAT Bangalore27 Jan 2026AY 2017-18

Bench: Shri Prashant Maharishi, Vice –Assessment Year :2017-18 M/S. The Ksrtc Employee Credit Co-Op Society Ltd., The Income Tax Officer, Aradhana Lodge, Near Busstand, Ward-1, Vs. Bagalkot, Karnataka – 587 101. Bagalkot. Pan: Aaaat4128M Appellant Respondent

For Appellant: None

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

assessment proceedings noted that Assessee has interest income from Bagalkot District Co-operative Bank and other Co-operative Banks which are taxable as income from other sources in view of the Hon’ble Karnataka High Court decision in case of Totgars Co-operative Sale Society dated 16.06.2017. Therefore ... However, he noted that Assessee is entitled to expenses out of the income chargeable to tax under the head income from other sources. The Ld. Assessing Officer noted that Assessee has earned interest income from fixed deposits of Rs. 37,14,879/- which is 31.24% of the gross receipts

Adarsha Souharda Sahakari Niyamit Sirsi, Sirsi vs. Pr. Commissioner of Income Tax, Huballi

ITA 1165/BANG/2025[2020-21]Status: DisposedITAT Bangalore27 Jan 2026AY 2020-21

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Sri Prakash Hegde, A.RFor Respondent: Sri Shivanand H Kalakeri, D.R

Section 142(1)Section 143(2)Section 143(3)Section 263Section 80P(2)(a)

Rs.65,88,141/- which according to him did not constitute business income and therefore the same needed to be taxed under the head “Income from other Sources” u/s 56 of the Act. Hence, the said amount would be ineligible for deduction u/s 80P(2)(a)(i) of the Act, which ... failed to examine and considered the same in the total income under the head income from other sources in view of the decision of the Hon'ble Supreme Court in the case of Totagars Co-operative Sale Society Limited vs. Income Tax Officer reported in 322 ITR 283 (SC) which

Alka Ashok Jagtap, Kalyan vs. Income Tax Officer, Kalyan

ITA 7524/MUM/2025[2009-10]Status: DisposedITAT Mumbai27 Jan 2026AY 2009-10

Bench: Shri Amit Shukla& Shri Makarand Vasant Mahadeokaralka Ashok Jagtap Income Tax Office C-304, Regency Avenue Rani Mansion Syndicate, Murbad Road, Vs. Kalyan, Kalyan Kalyan West, Thane- 421301, Kalyan Pan/Gir No. Ahtpj7760J (Applicant) (Respondent) Assessee By Shri Sunil Jain Revenue By Shri Surendra Mohan, Sr Dr Date Of Hearing 22.01.2026 Date Of Pronouncement 27.01.2026

Section 143(1)Section 143(3)Section 147Section 148Section 154Section 271(1)(c)Section 274

return of income:  Long Term Capital Gain (LTCG) of Rs. 6,47,054/-,  Short Term Capital Gain (STCG) of Rs. 72,596/-, and  income from other sources of Rs. 52,180/-. Thus, the amounts which were subjected to dispute were already disclosed in the return of income, though claimed under ... Assessing Officer had made the following additions for A.Y. 2009– 10: i. unexplained investment in shares of Rs. 6,36,866/-; and ii. income from other sources of Rs. 72,596/-. Penalty proceedings were initiated with reference to the above additions. 16. However, in the common quantum appellate order dated

Luvkesh Textile Industries Pvt Ltd, Mumbai vs. DCIT Circle 4(2)(1), Mumbai

In the result the both the appeals are allowed for statistical purposes

ITA 6054/MUM/2025[2018-19]Status: DisposedITAT Mumbai27 Jan 2026AY 2018-19

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankarluvkesh Textile Industries Pvt. Deputy Commissioner Ltd. Of Income Tax Circle 201, Maxheal House, Swami 4(2)(1) Vs. Ayyappa Mandir Marg, Bangur Aayakar Bhavan, Nagar, Goregaon West, Maharishi Karve Road, Mumbai - 400104 Mumbai - 400020 Pan: Aaacl7421K (Appellant) (Respondent) Deputy Commissioner Of Lukesh Textile Industries Income Tax Circle Private Limited 4(2)(1) Vs. 21/22 A Chunawal Ind Estate, 640 Aayakar Bhavan, Condivita Lane, Andheri East, Maharishi Karve Road, Mumbai - 400020 Mumbai - 400020 Pan: Aaacl7421K (Appellant) (Respondent) Present For: Assessee By : Shri A. L. Sharma, Ar Revenue By : Shri Surendra Mohan, Sr. Dr Date Of Hearing : 04.12.2025 Date Of Pronouncement : 27.01.2026 आदेश / O R D E R Per Prabhash Shankar [A.M.] :- The Instant Appeals Have Been Preferred By Both The Assessee & The Revenue Which Emanate From The Appellate Order Passed By The Ld. Cit(A)/National Faceless Appeal Centre (Nfac), Delhi, [Hereinafter Referred To As “Cit(A)”] With Regard To The Assessment Order Passed Under Luvkesh Textile Industries Pvt. Ltd. Section 147 R.W.S. 144 Of The Income Tax Act 1961, (In Short ‘The Act’) Dated 22.03.2024 A.Y. 2018-19. 2. The Revenue Has Raised Following Grounds Of Appeal :

For Appellant: Shri A. L. Sharma, ARFor Respondent: Shri Surendra Mohan, Sr. DR

Section 131Section 147Section 69C

expenditure claimed. It was proposed to treat the same as unexplained expenditure u/s 69C of the Act and assessed under the head “Income from Other Sources”. However, the assessee did not file it reply on the date of the hearing. The assessee sought further time to provide information. The request

DCIT-421, Mumbai vs. Lukesh Textile Industries Private Limited, Mumbai

In the result the both the appeals are allowed for statistical purposes

ITA 5924/MUM/2025[2018-19]Status: DisposedITAT Mumbai27 Jan 2026AY 2018-19

For Appellant: Shri A. L. Sharma, ARFor Respondent: Shri Surendra Mohan, Sr. DR

Section 131Section 147Section 69C

Shri Ankur Chandulal Shah, Mumbai vs. The ACIT, Circle-19(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 5901/MUM/2025[2017-18]Status: DisposedITAT Mumbai27 Jan 2026AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

Section 144Section 57

made by the Assessing Officer by disallowing deduction of interest expenditure claimed under 2 Ankur Chandulal Shah the head “Income from Other Sources” under section 57(iii) of the Act. 3. The brief factual matrix qua the issue is that the assessee is an individual and is working ... interest aggregating to ₹1,06,30,156. Accordingly, the assessee had offered the net interest income of ₹70,51,426 under the head “Income from Other Sources”. This position was duly reflected 3 Ankur Chandulal Shah in the computation of total income, wherein the assessee had specifically disclosed interest received

Surinder Kumar Malhotra, Delhi vs. National Faceless Assessment Center, Delhi

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

ITA 6370/DEL/2025[2018-19]Status: DisposedITAT Delhi27 Jan 2026AY 2018-19

Bench: Shri Mahavir Singh, Hon’Ble & Mrs. Renu Jauhri, Hon’Ble

For Appellant: Sh. Sombir Singh, CAFor Respondent: Shri Ajay Kumar Arora, Sr. DR

Section 234ASection 250Section 68

after deducting the cost of acquisition were eligible to be treated as Capital Gains, taxable under the head "Capital Gains" and not under "Income from Other Sources" or "Unexplained Income." (iv) The Assessing Officer failed to specify the nature of addition (whether under section 68, 69, or 69C), which renders

Ajit Nagari Sahakari Pat Sanstha Ltd, Pune vs. DCIT, Cir-7, Pune

In the result, appeal of the Assessee is partly allowed

ITA 2318/PUN/2025[2022-23]Status: DisposedITAT Pune23 Jan 2026AY 2022-23

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2318/Pun/2025 निर्धारण वषा / Assessment Year: 2022-23 Ajit Nagari Sahakari Pat V Dcit, Sanstha Ltd., S Circle-7, Pune. Rashtrawadi Bhavan, Hudco Road, Saswad, Tal-Khed, Pune – 412301. Pan: Aaaaa6401E Appellant/ Assessee Respondent /Revenue Assessee By Smt Deepa Khare Revenue By Smt Neha Thakkar – (Virtual) On Rotation Duty Date Of Hearing 22/01/2026 Date Of Pronouncement 23/01/2026 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.2022-23 Dated 10.01.2025 Emanating From The Assessment Order Passed Under

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

claimed in respect of such income. 2. The ld CIT(A) erred in law and on facts in assessing interest income as income from other sources as against business income without appreciating that the said income is attributable to the activities of extending credit facilities to the members

Income Tax Officer Ward 1 Satara, Satara vs. Karad Patan Taluka Prathmik Shikshak Sahakari Society Limitedty, Karad

In the result, Revenue’s Appeal is dismissed

ITA 2289/PUN/2025[2020]Status: DisposedITAT Pune23 Jan 2026

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2289/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Income Tax Officer, V Karad Patan Taluka Prathmik Ward-1, Satara. S Shikshak Sahakari Society Limited, 190 B Shaniwar Peth, Opp.Shivneri Lodge, Karad, Satara – 415110 Pan: Aaaak0559R Appellant / Assessee Respondent / Revenue Assessee By Shri Satish U Nade Revenue By Smt Neha Thakur (Virtual) Date Of Hearing 21/01/2026 Date Of Pronouncement 23/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Revenue Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2020-21 Dated 21.08.2025 Emanating From The Assessment Order Passed Under Section 143(3) Read With Section 144B Of The I.T .Act, 1961 Dated

Section 143(3)Section 144BSection 250Section 56Section 57Section 80Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

that the interest income which has been earned by a co-operative society by investing surplus funds would come in the category of 'Income from other sources taxable u/s 56 of the Act and would not qualify for deduction as business income ... activities carried out by the assessee with the non-member Co-operative banks and hence, such interest income needs to be charged as income from other sources under section 56 of the Income Tax Act, 1961. 3. On the facts and circumstances of the case and in law, the learned

M/S. Rallis India Ltd, Mumbai vs. DCIT, 8(1)(1), Mumbai

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

ITA 7255/MUM/2025[2023-24]Status: DisposedITAT Mumbai23 Jan 2026AY 2023-24

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudhary

Section 234CSection 234C(1)(b)Section 80M

Rs.6.76,000/-. 2) Both lower authorities failed to consider that dividend income of Rs.6,76,000/-had been doubly taxed, once under "Income from Other Sources" and once under the head "Profits & Gains from Business & Profession" 3) The learned Commissioner of Income Tax (Appeals) failed to consider the finding ... lakhs under the head “profits and gains from business and profession” wherein the AO has brought it to tax under the head “income from other sources”. It was further submitted that in the process, the AO has taxed the dividend income under the head “income from other sources