“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/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 7254/MUM/2025[2021-22]Status: DisposedITAT Mumbai23 Jan 2026AY 2021-22

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

Sharda Chambers Premise Co Op Society Ltd, Mumbai vs. ACIT, 17(3), Mumbai

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

ITA 6554/MUM/2025[2013-14]Status: DisposedITAT Mumbai23 Jan 2026AY 2013-14

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2013-14

For Appellant: Mr. H.N. MotiwallaFor Respondent: Mr. Vikas Chandra, Sr. DR

Section 143(2)

Property" instead of assessed under the head "Income from House Property" instead of assessed under the head "Income from House Property" instead of "Income from other sources" particularly when the said income was "Income from other sources" particularly when the said income was "Income from other sources" particularly when ... agreement with CNIL, treated the said receipt as income chargeable agreement with CNIL, treated the said receipt as income chargeable under the head “Income from other sources”. The assessment was er the head “Income from other sources”. The assessment was er the head “Income from other sources”. The assessment

Rudra Infra Projects, Mumbai vs. Circle1, Thane

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

ITA 5582/MUM/2025[2017-18]Status: DisposedITAT Mumbai23 Jan 2026AY 2017-18

Bench: Shri Vikram Singh Yadav & Ms. Kavitha Rajagopalassessment Year : 2017-18 Rudra Infra Projects, Deputy Commissioner Of B-506, 5Th Floor, Income Tax, Rashmi Crystal, Vs. Circle-1, Sai Compl, Thane. Near Joggers Park, Mira Road (East), Thane-401107. Pan : Aasfr5526L (Appellant) (Respondent) For Assessee : Shri Ronen Joshi For Revenue : Shri Annavaran Kosuri Date Of Hearing : 20-01-2026 Date Of Pronouncement : 23-01-2026 O R D E R Per Vikram Singh Yadav, A.M :

For Appellant: Shri Ronen JoshiFor Respondent: Shri Annavaran Kosuri

Section 143(3)Section 37(1)Section 40Section 57

primary business activities and the income 3 was erroneously offered by the tax consultant in the return of income under the head „Income from Other Sources‟ as against „Income from Business and Profession‟. It was submitted that to execute the said professional assignment, the assessee engaged specialized service providers ... purposes, has incurred certain professional expenses and therefore, the correct head of income should be “income from business/profession” and not “income from other sources” and thus, the expenses so claimed are allowable u/s 37(1) of the Act as incurred wholly and exclusively for the purposes of its professional activities

Jashvantiben Girishbhai Patel, Surat vs. The Income Tax Officer, Ward 2(3)(2), Surat

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

ITA 274/SRT/2025[2015-16]Status: HeardITAT Surat22 Jan 2026AY 2015-16

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 147Section 234ASection 249(4)Section 250Section 250(6)

That the Ld. NFAC has erred in confirming the addition of Rs. 52,35,000/- made by the AO under the head income from other sources of sale proceeds of Agricultural Land sold in which appellant has only 3.33% share which is taxable under the head income from Capital Gain

Deputy Commissioner of Income Tax, Central Cirlce-1(4), Chennai vs. Ramanathan Viswanathan, Chennai

ITA 1597/CHNY/2025[2015-16]Status: DisposedITAT Chennai22 Jan 2026AY 2015-16

For Appellant: Shri. V. Naga PrasadFor Respondent: Smt. E. Pavuna Sundari

Section 132Section 139Section 142(1)Section 153ASection 153CSection 250

completed the assessment(s) u/s 153C of the Act on 31.12.2018 after making addition on account of coal-commission by way of ‘Income from Other Sources’ across all the years. 4. Aggrieved by the order(s) of the AO, the assessee preferred appeal(s) before ... represented coal commission earned by the assessee and added aggregate sum of Rs.550.40 crores in the hands of the assessee by way of ‘Income from Other Sources’ in AYs 2014-15 to 2017-18. Also, the entries titled ‘Power M’ found in the ledger seized from the premises

Deputy Commissioner of Income Tax, Central Circle-1(4), Chennai vs. Ramanathan Viswanathan, Chennai

In the result, all appeals filed by the assessee are allowed and the appeals of the Revenue are dismissed

ITA 1556/CHNY/2025[2016]Status: DisposedITAT Chennai22 Jan 2026

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

For Appellant: Shri. V. Naga PrasadFor Respondent: Smt. E. Pavuna Sundari

Section 132Section 139Section 142(1)Section 153ASection 153CSection 250

153C of the ITA No.1321/Chny/2025 & Others R. Viswanathan :: 4 :: Act on 31.12.2018 after making addition on account of coal-commission by way of ‘Income from Other Sources’ across all the years. 4. Aggrieved by the order(s) of the AO, the assessee preferred appeal(s) before ... represented coal commission earned by the assessee and added aggregate sum of Rs.550.40 crores in the hands of the assessee by way of ‘Income from Other Sources’ in AYs 2014-15 to 2017-18. Also, the entries titled ‘Power M’ found in the ledger seized from the premises

R.Viswanathan, Chennai vs. The Deputy Commissioner of Income Tax, Central Circle-1(4), Chennai

ITA 1324/CHNY/2025[2017-18]Status: DisposedITAT Chennai22 Jan 2026AY 2017-18

For Appellant: Shri. V. Naga PrasadFor Respondent: Smt. E. Pavuna Sundari

Section 132Section 139Section 142(1)Section 153ASection 153CSection 250

completed the assessment(s) u/s 153C of the :: 4 :: Act on 31.12.2018 after making addition on account of coal-commission by way of ‘Income from Other Sources’ across all the years. 4. Aggrieved by the order(s) of the AO, the assessee preferred appeal(s) before ... represented coal commission earned by the assessee and added aggregate sum of Rs.550.40 crores in the hands of the assessee by way of ‘Income from Other Sources’ in AYs 2014-15 to 2017-18. Also, the entries titled ‘Power M’ found in the ledger seized from the premises

R.Viswanathan, Chennai vs. The Deputy Commissioner of Income Tax, Central Circle-1(4), Chennai

ITA 1323/CHNY/2025[2016-17]Status: DisposedITAT Chennai22 Jan 2026AY 2016-17

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1321 To 1324/Chny/2025 िनधारण वष/Assessment Years: 2014-15 To 2017-18 R. Viswanathan, Flat No.A-4, Rams Anjali Atrium No.8, Sundaram Salai, R.A. Puram, Chennai-600 028. [Pan: Adlpv 6760 G] V. The Dcit, Central Circle-1(4), Chennai. (अपीलाथ/Appellant) (यथ/Respondent) आयकर अपील सं./Ita Nos.1556 & 1597/Chny/2025 िनधारण वष/Assessment Years: 2016-17 & 2015-16 The Dcit, Central Circle-1(4), Chennai. V. R. Viswanathan, Flat No.A-4, Rams Anjali Atrium No.8, Sundaram Salai, R.A. Puram, Chennai-600 028. [Pan: Adlpv 6760 G] (अपीलाथ/Appellant) : (यथ/Respondent) अपीलाथ की ओर से/ Assessee By : Shri. V. Naga Prasad, Advocate/Ar थ की ओर से /Department By : Smt. E. Pavuna Sundari, Cit/Dr सुनवाईकतारीख/Date Of Hearing : 29.10.2025 / 17.11.2025 घोषणाकतारीख /Date Of Pronouncement : 22.01.2026 :: 2 ::

For Appellant: Shri. V. Naga PrasadFor Respondent: Smt. E. Pavuna Sundari

Section 132Section 139Section 142(1)Section 153ASection 153CSection 250

153C of the :: 4 :: ITA No.1321/Chny/2025 & Others R. Viswanathan Act on 31.12.2018 after making addition on account of coal-commission by way of ‘Income from Other Sources’ across all the years. 4. Aggrieved by the order(s) of the AO, the assessee preferred appeal(s) before ... represented coal commission earned by the assessee and added aggregate sum of Rs.550.40 crores in the hands of the assessee by way of ‘Income from Other Sources’ in AYs 2014-15 to 2017-18. Also, the entries titled ‘Power M’ found in the ledger seized from the premises

R.Viswanathan, Chennai vs. The Deputy Commissioner of Income Tax, Central Circle-1(4), Chennai

ITA 1322/CHNY/2025[2015-16]Status: DisposedITAT Chennai22 Jan 2026AY 2015-16

For Appellant: Shri. V. Naga PrasadFor Respondent: Smt. E. Pavuna Sundari

Section 132Section 139Section 142(1)Section 153ASection 153CSection 250

R.Viswanathan, Chennai vs. The Deputy Commissioner of Income Tax, Central Circle-1(4), Chennai

ITA 1321/CHNY/2025[2014-15]Status: DisposedITAT Chennai22 Jan 2026AY 2014-15

For Appellant: Shri. V. Naga PrasadFor Respondent: Smt. E. Pavuna Sundari

Section 132Section 139Section 142(1)Section 153ASection 153CSection 250

ITO-22(1)(6), Mumbai vs. Arcil Retail Loan Portfolio- 001- A- Trust, Mumbai

ITA 4252/MUM/2025[2016-17]Status: DisposedITAT Mumbai22 Jan 2026AY 2016-17

Bench: Shri Amit Shukla& Shri Makarand Vasant Mahadeokar

Section 143(1)Section 143(3)Section 164Section 2(31)Section 250Section 61Section 63

4252/Mum/2025 ARCIL RETAIL LOAN PORTFOLIO- 001- A TRUST expenses of Rs. 2,69,70,724/- and treated interest income as income from other sources. Accordingly, the AO assessed the total income of the assessee at Rs. 30,33,45,950/- and initiated penalty proceedings under sections ... justified in deleting the entire addition of Rs.30,33,45,947/- made on account of business income, income from other sources, disallowances of Protection preservation, Insurance Expenses and Management Charge and interest income. 2. The CIT(A) has not appreciated the fact that the assessee is not arevocable trust since

Subhash Suryakant Phadkar, Mumbai vs. Income Tax Officer 35(3)(4), Mumbai

In the result, the appeal filed by the assessee is hereby allowed in above terms

ITA 3490/MUM/2025[2011-12]Status: DisposedITAT Mumbai22 Jan 2026AY 2011-12

Bench: Ms. Kavitha Rajagopal, Jm & Shri Omkareshwar Chidara, Am Mr. Subhash Suryakant Phadkar, Income Tax Officer, B-184, Kalpataru Sparkle, Bandra East, Ward 35(3)(4), Vs. Mumbai- 400051 Kautilya Bhavan, Bkc, Mumbai- 400051 Pan No.Aaapp3456H (Appellant) (Respondent) :

For Appellant: Shri Mayur Makadia, ARFor Respondent: Ms. Kavitha P. Kaushik, Sr. DR

Section 143(2)Section 143(3)Section 147Section 148Section 250Section 54Section 54E

appreciate that the AO had erred in characterizing the compensation of Rs.53,50,500 received by the Appellant from the builder as income from other sources rather than as Long-Term Capital Gains. Ground 4. On the facts and circumstances of the case ... income is considered as taxable.” 3. Brief facts of the case are that the assessee is an individual deriving income from pension and income from other sources as interest from bank and postal authority. The assessee filed his return of income declaring total income at Rs.3,33,247/-. The assessee

Milan Theatres P Limited, Mumbai vs. DCIT Circle 12(3)(2), Mumbai

ITA 5072/MUM/2024[2017-18]Status: DisposedITAT Mumbai22 Jan 2026AY 2017-18

Section 143(3)Section 342Section 45(2)

IN THE INCOME TAX APPELLATE TRIBUNAL, ‘D’ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & SHRI ARUN KHODPIA, ACCOUNTANT MEMBER

Dy. Commissioner of Income Tax, Central Circle-I Noida, Noida vs. M/S Advant It Park Private Limited, Delhi

Appeal is allowed and order of the High Court is set aside

ITA 5334/DEL/2025[2018-19]Status: DisposedITAT Delhi22 Jan 2026AY 2018-19

Bench: Shri Mahavir Singh & Shri Manish Agarwal

Section 143(3)

treated the same as a rental income and taken the lease rent as "Income from house property" and hire charges and maintenance as “Income from other sources", on the ground that the assessee was not notified as an Industrial Park/SEZ by the CBDT. The Ld. CIT(A) after detailed analysis ... made by the Assessing Officer under the heads "Income from House Property" and "Income from Other Sources", respectively, by reclassifying the same as "Business Income", ignoring the nature of receipts and the fact that the assessee was primarily engaged in passive leasing activities. 2. Whether on the facts and circumstances

Dy. Commissioner of Income Tax, Cetral Circle-I, Noida vs. Advant It Park Private Limited, Delhi

In the result appeal of the revenue is dismissed

ITA 5333/DEL/2025[2017-18]Status: DisposedITAT Delhi22 Jan 2026AY 2017-18

Bench: Shri Mahavir Singh & Shri Manish Agarwal

Section 1Section 143(3)

treated the same as a rental income and taken the lease rent as “Income from house property” and hire charges and maintenance as “Income from other sources”, on the ground that the assessee was not notified as an Industrial Park/SEZ by the CBDT. The Ld. CIT(A) after detailed analysis ... made by the Assessing Officer under the heads "Income from House Property" and "Income from Other Sources", respectively, by reclassifying the same as "Business Income", ignoring the nature of receipts 4 ITA Nos.5332 to 5334 /Del/2025 C.O. Nos.221 to 223/Del/2025 DCIT vs. M/s Advant It Park

Dy. Commissioner of Income Tax, Central Circle-I, Noida vs. M/S Advant It Park Private Limited, Delhi

ITA 5332/DEL/2025[2016-17]Status: DisposedITAT Delhi22 Jan 2026AY 2016-17

Bench: Shri Mahavir Singh & Shri Manish Agarwal

Section 143(3)

Misrilall Jain & Sons, Singhbhum West vs. ACIT, Central Circle-1, Ranchi

In the result the appeal filed by the assessee is allowed

ITA 468/RAN/2024[2017-18]Status: DisposedITAT Ranchi21 Jan 2026AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.468/Ran/2024 Assessment Year: 2017-18 Misrilall Jain & Sons….…………….…….…............................……….……Appellant M. D. House, Chaibasa Singhbhum West, Jharkhand – 833201. [Pan: Aabfm2851Q] Vs. Acit, Cc-1, Ranchi.................……….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Adv., Appeared On Behalf Of The Appellant. Shri Kanhaiya Lal Kanak, Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 21, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Cit(A)-3, Patna (Hereinafter Referred To As “Cit(A)”) Dated 30.07.2025 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”).

Section 143(3)Section 148Section 148ASection 250

returned income. However, while completing the reassessment, the Assessing Officer proceeded to make further additions and assessed ₹4,75,23,253 as interest income from other sources, and ₹3,42,60,244 by disallowing business expenses, over and above the returned income. 3. Aggrieved by the order ... appeal before the Ld. CIT(A) where Ld. CIT(A) upheld the addition of ₹4,75,23,253 treating interest income as income from other sources, and the disallowance of expenses of ₹3,42,60,244, granting only an ad hoc relief of ₹10,00,000. 4. Aggrieved, the assessee

Nashik District Police Co Operative Credit Society Ltd Nashik, Nashik vs. Income Tax Officer, National E Assessment Canter, Delhi

In the result, appeal of the assessee is allowed

ITA 727/PUN/2025[AY 2018-19]Status: DisposedITAT Pune21 Jan 2026

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.727/Pun/2025 निर्धारण वषा / Assessment Years: 2018-19 Nashik District Police Co- V The Income Tax Officer, Operative Credit Society Ltd., S National E Assessment Sagar Plaza, Third Floor, Above Centre, Delhi. Axis Bank, Audumbar Nagar, Mumbai Agra Road, Nashik – 422003. Pan: Aacan6075F Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod Shingte Revenue By Smt Neha Thakur – (Virtual) Date Of Hearing 20/01/2026 Date Of Pronouncement 21/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2018-19 Dated 23.02.2024 Emanating From Assessment Order U/S.143(3) Read With Section 143(3A) & 143(3B) Of The I.T.Act, Dated 31.03.2021. The Assessee Has Raised The Following Grounds Of Appeal :

Section 143Section 143(3)Section 250Section 66Section 80Section 80P(2)(a)Section 80P(2)(d)

Rs.1,48,78,730/- 4. The Assessing Officer(AO) held that the interest income earned by Assessee needs to be assessed as income from other sources. 4.1 In this case, Assessing Officer has disallowed assessee’s claim for deduction u/s.80P(2)(d) of the Act, of Rs.1 ... interest income from cooperative bank. It is not allowable as deduction u/s 80P. So disallowed as deduction u/s 80P & added as income from other sources (IFOS). (Disallowance as 80P & addition as IFOS :-Rs.1,14,84,355/-).” 5. Aggrieved by the addition, Assessee filed appeal before the ld.CIT

Income Tax Officer Ward-2, Ahmednagar, Ahamednagar vs. Kanifnath Grmain Bigar Sheti Sahakaripatsanstha Maryadit, Maldad

In the result, Revenue’s Appeal is dismissed

ITA 2271/PUN/2025[2018-19]Status: DisposedITAT Pune21 Jan 2026AY 2018-19

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2270 & 2271/Pun/2025 निर्धारण वषा / Assessment Year: 2018-19 The Income Tax Officer, V Kanifnath Gramin Bigar Sheti Ward-2, Ahmednagar. S Sahakaripatsanstha Maryadit, At Post Malad, Taluka Sangamner, Ahmednagar – 422608. Pan: Aabak1395E Appellant/ Revenue Respondent /Assessee Assessee By Shri Pramod S Shingte – Ar Revenue By Smt Neha Thakkar (Virtual) Date Of Hearing 19/01/2026 Date Of Pronouncement 21/01/2026 आदेश/ Order Per Bench : These Two Appeals Filed By The Revenue Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac],Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2018- 19Dated 01.07.2025 Emanating From The Assessment Order Dated 30.03.2021 Under Section 143(3) R.W.S. 143(3A) & 143(3B) Of The Income Tax Act, 1961 & Order Under Section 250 Of The Income

Section 143(3)Section 250Section 270ASection 56Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

Assessment Order. 3. The Assessing Officer(AO) held that Interest Income arising from Deposits/Investments of funds in Banks is in the nature of Income from Other Sources taxable u/s.56 of the Act. The AO held that such Interest is not attributable to the business of providing credit facilities

Income Tax Officer Ward-2, Ahmednagar vs. Kanifnath Grmain Bigar Sheti Sahakari, Maldad Sangamner

In the result, Revenue’s Appeal is dismissed

ITA 2270/PUN/2025[2018-19]Status: DisposedITAT Pune21 Jan 2026AY 2018-19

Section 143(3)Section 250Section 270ASection 56Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)