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“income from other sources”

Income HeadsSection 56Section 568,248 judgments

The decision most relied on for income from other sources is Jute Corporation of India Ltd. v. CIT (187 ITR 688), cited in 1,372 judgments on BharatTax.

Leading authorities on income from other sources

Jute Corporation of India Ltd. v. CIT
187 ITR 688 · 1991 · Supreme Court
1,372
citing judgments

The Commissioner of Income Tax (Appeals) possesses co-terminus powers with the Assessing Officer and can direct the Assessing Officer to perform actions he failed to do, but cannot introduce a new source of income in the assessment. The appellate assessment must be confined to the items of income that were the subject matter of the original assessment.

Totgars Co-operative Sale Society Ltd. v. ITO
322 ITR 283 · 2010 · Supreme Court
1,283
citing judgments

The interest income earned by a cooperative society from investing its surplus funds in fixed deposits with banks is not "derived from" its eligible business activities and is taxable as "income from other sources" under Section 56, thus not qualifying for deduction under Section 80P.

K.P. Varghese v. ITO
131 ITR 597 · 1981 · Supreme Court
989
citing judgments

An addition to income cannot be made merely on the basis of a difference in valuation of assets or a Valuation Officer's report without establishing actual understatement of consideration or the source of unexplained funds through proper enquiry. The Assessing Officer must conduct proper enquiry and satisfy the conditions for making such additions.

GE India Technology Centre Pvt. Ltd. v. CIT
327 ITR 456 · 2010 · Supreme Court
663
citing judgments

Tax must be deducted at source from payments made to a non-resident under Section 195 only if such payment is chargeable to tax in India. The Assessing Officer bears the onus to establish that the payments made are indeed chargeable to tax under the Income Tax Act.

Commissioner of Income Tax v. Nova Promoters and Finlease (P) Ltd.
342 ITR 169 · 2012 · High Court
658
citing judgments

To make an addition under Section 68 for unexplained cash credits, the Assessing Officer must conduct proper inquiry into the identity, genuineness, and creditworthiness of the creditor, especially concerning share application money. The assessee's initial discharge of burden by providing necessary details shifts the onus back to the AO for further investigation, including the source of source.

Tuticorin Alkali Chemicals & Fertilizers Ltd. v. CIT
227 ITR 172 · 1997 · Supreme Court
621
citing judgments

Interest income earned on deposits, particularly before the commencement of business operations or as a requirement for business licensing, is taxable as "income from other sources" under Section 56, and cannot be treated as business income or set off against interest on borrowed funds.

Kale Khan Mohammad Hanif v. CIT
50 ITR 1 · 1963 · Supreme Court
581
citing judgments

The assessee bears the onus of proving the source and nature of any sum of money or receipt found to have been received by them. If the assessee fails to satisfactorily explain the receipt, the Income-tax Officer is entitled to treat it as taxable income.

Liberty India v. CIT
317 ITR 218 · 2009 · Supreme Court
571
citing judgments

The Supreme Court clarified that for profits and gains to be eligible for deductions under sections like 10B, 80IA, or 80IB, the income must be "derived from" or have a direct nexus to the eligible business activity. Income from incidental sources like the sale of scrips/licenses or interest on employee loans is generally not considered as derived from the eligible business for such deductions.

Judgments citing income from other sources

Jayshree Ravi Sancheti, Mumbai vs. PCIT-20, Mumbai

In the result, the appeal of the assessee is allowed

ITA 2269/MUM/2024[2013-14]Status: DisposedITAT Mumbai27 Sept 2024AY 2013-14

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

For Appellant: Shri Prakash Jhunjhunwala, ARFor Respondent: Ms. Rajeshwari Menon, Sr. DR
Section 10(38)Section 147Section 148Section 263Section 68Section 69C

Rs.44,19,280/- (Rs.35.31.934/- Rs.8.87.346/-), and is required to be disallowed. The escaped amount of accommodation entry is required to be taxed as income from other sources. 9. In view of the above discussion the assessment order u/s 147 r.wis 144 read with section 144B of the Income ... therefore the exemption claimed u/s. 10(38) of Rs.2,60,46,279/- is rejected and the said amount is assessed to tax as income from other source as cash credit u/s 68 and brought to tax. This addition is liable for tax u/s 115BBE. Penalty proceedings u/s.271

Om Sri Maa Shakti Namah, Mumbai vs. Asstt. Commissioner of Income Tax, Cir-32(2), Mumbai

ITA 1989/MUM/2024[2014-2015]Status: DisposedITAT Mumbai27 Sept 2024AY 2014-2015

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

Section 36(1)(iii)Section 57

Investment Co. Pvt. Ltd. [2001] 249 ITR 776 (Del.) held that "where funds borrowed for business purposes yield Business Income as well as Income from Other Sources, the entire interest paid is to be allowable u/s 36(1)(iii). The H'ble Calcutta HC has gone a step forward ... Chemicals (1997) 93 Тахтапп 502 (SC) by the H' ble Supreme Court to justify the interest income for its taxability under the head "Income from Other Sources". vide para 4.3 of his order. viii. However in the same judgment the H'ble Supreme Court has further stated that "The question

DCIT, Central Circle - 7(1), Mumbai vs. Rare Enterprises, Mumbai

In the result, appeal of the Revenue is partly allowed

ITA 1442/MUM/2024[2018-19]Status: HeardITAT Mumbai27 Sept 2024AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Girish Agrawal

Section 143(3)

year under consideration in respect of TDS done by Dharti is to be treated as an item of income under the head "income from other sources" and provisions of section 198 be applied accordingly. It is important to note that once TDS is deducted, assessee cannot be permitted

Deepak Ramlal Wadhawan, Mumbai vs. Assistant Commissioner of Income Tax-27(1), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 1251/MUM/2024[2014-15]Status: DisposedITAT Mumbai27 Sept 2024AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Girish Agrawalassessment Year: 2014-15

For Appellant: NoneFor Respondent: Smt. Mahita Nair, Sr. DR
Section 143(3)Section 57

return of account of non receipt of the interest, assessee devised a methodology of reporting the same in his return under the head “income from other sources” and correspondingly claiming for deduction u/s. 57 of the Act. For this, he submitted explanations by justifying the differences arising ... consideration in respect of TDS done by PBA Infrastructure Pvt. Ltd. is to be treated as an item of income under the head “income from other sources” and provisions of section 198 be applied accordingly. It is important to note that once TDS is deducted, assessee cannot be 7 Deepak

Maharashtra Airport Development Company Ltd., Mumbai vs. ACIT-3(2)(1), Mumbai

In the result, appeal of the assessee is allowed and that of the Revenue is dismissed

ITA 520/MUM/2019[2007-08]Status: DisposedITAT Mumbai27 Sept 2024AY 2007-08

Bench: Shri Satbeer Singh Godara & Shri Girish Agrawalassessment Year: 2007-08 Assistant Commissioner Of Income Maharashtra Airport Tax- 3(2)(1), Development Co. Ltd., Mumbai 12Th Floor,World Trade Centre, Vs. Tower No.1, Cuffe Parade, Mumbai – 400 005

For Appellant: Shri Rushabh Mehta, CAFor Respondent: Smt. Sanyogita Nagpal, CIT, DR
Section 143(3)Section 220(2)Section 234BSection 57

erred in law and in fact in not allowing deduction of interest paid, in case the interest on FDRs is being treated as Income from Other Sources. 6) That the AO/CIT (A) has erred in facts and in law in holding that the Assessee failed to prove nexus between ... Progress" to the extent of additional interest income of Rs. 10,56,49,189/-made by the id. Assessing Officer under the heat Income From Other Sources' which was reduced by the assessee from Capital Work in Progress in its Balance Sheet General 3) The above grounds of appeal

ACIT 3(2)(1), Mumbai vs. Maharashtra Airport Development Company Ltd, Mumbai

In the result, appeal of the assessee is allowed and that of the Revenue is dismissed

ITA 7497/MUM/2018[2007-08]Status: DisposedITAT Mumbai27 Sept 2024AY 2007-08

Bench: Shri Satbeer Singh Godara & Shri Girish Agrawalassessment Year: 2007-08 Assistant Commissioner Of Income Maharashtra Airport Tax- 3(2)(1), Development Co. Ltd., Mumbai 12Th Floor,World Trade Centre, Vs. Tower No.1, Cuffe Parade, Mumbai – 400 005

For Appellant: Shri Rushabh Mehta, CAFor Respondent: Smt. Sanyogita Nagpal, CIT, DR
Section 143(3)Section 220(2)Section 234BSection 57

erred in law and in fact in not allowing deduction of interest paid, in case the interest on FDRs is being treated as Income from Other Sources. 6) That the AO/CIT (A) has erred in facts and in law in holding that the Assessee failed to prove nexus between ... Progress" to the extent of additional interest income of Rs. 10,56,49,189/-made by the id. Assessing Officer under the heat Income From Other Sources' which was reduced by the assessee from Capital Work in Progress in its Balance Sheet General 3) The above grounds of appeal

N.D.A. Employees Co. Op. Credit Society Limiteds, N.D.A. Campus Khadakwasala vs. Income Tax Officer, Pmt Building Pune

Appeal is allowed in above terms

ITA 1689/PUN/2024[2018-19]Status: DisposedITAT Pune26 Sept 2024AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Inturi Rama Rao

For Appellant: Shri Satish NadeFor Respondent: Shri B.S. Rajpurohit, Addl. CIT
Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(2)(i)

eligible for deduction u/s 80P(a)(2)(1) of the Income Tax Act as the said income was not business income but was income from other sources. 2. In the facts and circumstances of the case and in law, the learned Commissioner of Income Tax (Appeals), NFAC has grossly erred ... society) was eligible for deduction u/s 80P(2)(d) of the Income Tax Act, 1961, even though the said income is taxed as income from other sources, as held by Hon'ble Apex Court of India in the case of Totagars Co-operative Sale Society vs. ITO in 188 taxmann.com

Udai Parnami, Jaipur vs. ITO Ward - 5(2), Jaipur

In the result, the appeal of the assessee is dismissed

ITA 1078/JPR/2024[2019-20]Status: DisposedITAT Jaipur26 Sept 2024AY 2019-20

Bench: Or At Lthe Time Of Hearing.

For Appellant: NoneFor Respondent: Shri Gautam Singh Chaudhary, JCIT D/R
Section 142(1)Section 143(2)Section 234ASection 250Section 270ASection 56Section 57

income declared comprises of income from Salary of Rs. 38,60,000/-, income from partnership business of Rs. 48,94,609/- and income from Other sources of (-) Rs. 28,98,271/-. The loss arrived at by the assessee under the head “Income from other sources” was set off against income ... issues in hand to be verified. The assessee submitted relevant details through e-proceedings. On verification of the income declared under the head “Income from other sources”, it was noticed by the AO that the assessee had declared interest income earned from others at Rs. 7,66,842/-. The said

Bhagwati Education Society, Sirsa vs. Income Tax Officer, Sirsa

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

ITA 429/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh25 Sept 2024AY 2017-18

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Kartik Garg, AdvocateFor Respondent: Shri Vivek Vardhan, JCIT, Sr. DR
Section 10Section 10(23)(iiiad)Section 10(23)(iiid)Section 143(2)Section 144

background of the case is that the appellant has inadvertently declared their net surplus amounting INR 3,47,180/- under the head of income from other sources wherein the whole income is exempt under section 10(23)(iiid). This is the case of the clerical mistake as the appellant neither ... asked to justify that the institute is eligible for claim of exemption under section 10(23c)(iiiad) and income shown under the head “income from other sources” amounting to Rs. 3,47,180/- have been utilized for education purposes and in absence of any explanation submitted by the assessee, assessment

Uttar Gujarat Vij Company Limited, Mehsana vs. The Dy.CIT, Circle-2(1)(1), Vadodara

In the result, Ground No

ITA 294/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad25 Sept 2024AY 2018-19

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Mehul K. Patel, A.RFor Respondent: Shri R.N. Dsouza, CIT DR
Section 234BSection 271(1)(c)Section 32(1)(iia)

interest income amounting to Rs.1,47,55,000/- and Miscellaneous Receipts amounting to Rs.6,42,67,000/- treating the same as income from other sources as against Business Income. 3.0 The learned Commissioner of Income Tax (Appeals) has erred in law and on facts in confirming that the appellant, being ... with regards to this ground of appeal is relating to treating interest income from staff loans and advances and other miscellaneous receipts as “income from other sources” and not as “business income”. Before us, the Counsel for the assessee submitted that similar ground has been decided by the Tribunal

Uttar Gujarat Vij Company Limited, Mehsana vs. The Dy.CIT, Circle-2(1)(1), Vadodara

In the result, Ground No

ITA 293/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad25 Sept 2024AY 2017-18

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Mehul K. Patel, A.RFor Respondent: Shri R.N. Dsouza, CIT DR
Section 234BSection 271(1)(c)Section 32(1)(iia)

interest income amounting to Rs.1,47,55,000/- and Miscellaneous Receipts amounting to Rs.6,42,67,000/- treating the same as income from other sources as against Business Income. 3.0 The learned Commissioner of Income Tax (Appeals) has erred in law and on facts in confirming that the appellant, being ... with regards to this ground of appeal is relating to treating interest income from staff loans and advances and other miscellaneous receipts as “income from other sources” and not as “business income”. Before us, the Counsel for the assessee submitted that similar ground has been decided by the Tribunal

Uttar Gujarat Vij Company Limited, Mehsana vs. The Dy.CIT, Circle-2(1)(1), Vadodara

In the result, Ground No

ITA 292/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad25 Sept 2024AY 2016-17

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Mehul K. Patel, A.RFor Respondent: Shri R.N. Dsouza, CIT DR
Section 234BSection 271(1)(c)Section 32(1)(iia)

interest income amounting to Rs.1,47,55,000/- and Miscellaneous Receipts amounting to Rs.6,42,67,000/- treating the same as income from other sources as against Business Income. 3.0 The learned Commissioner of Income Tax (Appeals) has erred in law and on facts in confirming that the appellant, being ... with regards to this ground of appeal is relating to treating interest income from staff loans and advances and other miscellaneous receipts as “income from other sources” and not as “business income”. Before us, the Counsel for the assessee submitted that similar ground has been decided by the Tribunal

The ACIT, Circle-2(1)(1), Vadodara vs. Uttar Gujarat Vij Company Limited, Mehsana

In the result, Ground No

ITA 271/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad25 Sept 2024AY 2018-19

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Mehul K. Patel, A.RFor Respondent: Shri R.N. Dsouza, CIT DR
Section 234BSection 271(1)(c)Section 32(1)(iia)

interest income amounting to Rs.1,47,55,000/- and Miscellaneous Receipts amounting to Rs.6,42,67,000/- treating the same as income from other sources as against Business Income. 3.0 The learned Commissioner of Income Tax (Appeals) has erred in law and on facts in confirming that the appellant, being ... with regards to this ground of appeal is relating to treating interest income from staff loans and advances and other miscellaneous receipts as “income from other sources” and not as “business income”. Before us, the Counsel for the assessee submitted that similar ground has been decided by the Tribunal

The ACIT, Circle-2(1)(1), Vadodara vs. Uttar Gujarat Vij Company Limited, Mehsana

In the result, Ground No

ITA 270/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad25 Sept 2024AY 2017-18

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Mehul K. Patel, A.RFor Respondent: Shri R.N. Dsouza, CIT DR
Section 234BSection 271(1)(c)Section 32(1)(iia)

interest income amounting to Rs.1,47,55,000/- and Miscellaneous Receipts amounting to Rs.6,42,67,000/- treating the same as income from other sources as against Business Income. 3.0 The learned Commissioner of Income Tax (Appeals) has erred in law and on facts in confirming that the appellant, being ... with regards to this ground of appeal is relating to treating interest income from staff loans and advances and other miscellaneous receipts as “income from other sources” and not as “business income”. Before us, the Counsel for the assessee submitted that similar ground has been decided by the Tribunal

The ACIT, Circle-2(1)(1), Vadodara vs. Uttar Gujarat Vij Company Limited, Mehsana

In the result, Ground No

ITA 269/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad25 Sept 2024AY 2016-17

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Mehul K. Patel, A.RFor Respondent: Shri R.N. Dsouza, CIT DR
Section 234BSection 271(1)(c)Section 32(1)(iia)

interest income amounting to Rs.1,47,55,000/- and Miscellaneous Receipts amounting to Rs.6,42,67,000/- treating the same as income from other sources as against Business Income. 3.0 The learned Commissioner of Income Tax (Appeals) has erred in law and on facts in confirming that the appellant, being ... with regards to this ground of appeal is relating to treating interest income from staff loans and advances and other miscellaneous receipts as “income from other sources” and not as “business income”. Before us, the Counsel for the assessee submitted that similar ground has been decided by the Tribunal

Vishal Balvantrai Agarwal, Ahmedabad vs. The Pr. Commissioner of Income Tax, Ahmedabad -1, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 226/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad25 Sept 2024AY 2018-19

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.226/Ahd/2023 िनधा"रण वष" /Assessment Year : 2018-19 Vishal Balvantrai Agarwal The Pr.Cit बनाम/ 249 New Cloth Market Ahmedabad-1 V/S. O/S. Raipur Gate Ahmedabad – 380 002 (Gujarat) "थायी लेखा सं./Pan: Adbpa 4462 G (अपीलाथ%/ Appellant) (&' यथ%/ Respondent) Assessee By : Shri Divyakant Parikh, Ar Revenue By : Shri Prathvi Raj Meena, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 18/09/2024 घोषणा की तारीख /Date Of Pronouncement: 25/09/2024 आदेश/O R D E R Per Shri Makarand V. Mahadeokar, Am:

For Appellant: Shri Divyakant Parikh, ARFor Respondent: Shri Prathvi Raj Meena, CIT-DR
Section 10Section 142(1)Section 143(3)Section 14ASection 263Section 57

directly established. 2.2. The assessee's case was selected for limited scrutiny. The scrutiny was limited to the issue of "deduction from income from other sources." During the assessment proceedings, the AO issued notices under Section 142(1) dated Vishal Balvantrai Agarwal vs. The Pr.CIT Asst. Year ... claimed under Section 57. The PCIT concluded that the assessee had failed to substantiate that the interest expenses were incurred exclusively for earning income from other sources. As a result, the PCIT held that the interest expenses of Rs. 3,26,45,179/- should have been disallowed and added back

Income Tax Officer Ward-2, Ahmednagar. vs. Goreshwar Gramin Bigar Sheti Sahakari Pat Sanstha Maryadit, Parner, Goregaon, Ahmednagar

In the result, the appeal of the Revenue is dismissed

ITA 630/PUN/2024[2018-19]Status: DisposedITAT Pune25 Sept 2024AY 2018-19

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Smt. Payal RathiFor Respondent: Shri Ramnath P. Murkunde
Section 143(2)Section 80P(2)Section 80P(2)(a)Section 80P(2)(d)

Assessing Officer (“AO”) found that while computing the total income the assessee adjusted the business loss of Rs.1,10,56,836/- against income from other sources amounting to Rs.1,71,09,178/- and arrived at gross total income of Rs.60,52,342/- being interest income earned from investments (Fixed Deposits

Vipinchandra M. Chokhawali, Navapur vs. The Income Tax Officer, Ward-1, Dhule

In the result, the appeal filed by the assessee is allowed and the Stay Application filed by the assessee is dismissed

ITA 1551/PUN/2024[2018-19]Status: DisposedITAT Pune25 Sept 2024AY 2018-19

Bench: Shri Inturi Rama Rao & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1551/Pun/2024 "नधा"रण वष" / Assessment Year : 2018-19 Along With Stay Application 06/Pun/2024 (Arising Out Of Ita No.1551/Pun/2024) Vipinchandra M. Chokhawala, Vs. Ito, Ward-1, Old Station Road, Dal Mill, Dhule Nandurbar, Navapur-425418 Maharashtra Pan : Adnpc8588M Appellant Respondent

For Appellant: Shri Amit Khatiwala and Shri Jitendra SanghaviFor Respondent: Shri Arvind Desai
Section 143(3)Section 250Section 56(2)(x)

that the appellant is an individual deriving income under the head “House Property, Income from S.A.No.06/PUN/2024 Partnership firms, Capital Gains and Income from Other sources. The Return of Income for the A.Y. 2018-19 was filed on 04.10.2018 declaring total income of Rs.78,24,250/-. Against the said return ... stamp duty of the said flat of Rs.4,18,62,535/- which comes to Rs.1,69,31,706/-, should be treated as ‘Income from Other Sources’ interms of provisions of section 56(2)(x)(b) of the Act. Accordingly, he brought to tax the said sum S.A.No.06/PUN/2024 rejecting

Vijay Agencies, Latur vs. ITO Ward 2, Latur

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

ITA 1277/PUN/2024[2013-2014]Status: DisposedITAT Pune25 Sept 2024AY 2013-2014

Bench: Shri Satbeer Singh Godara & Shri Inturi Rama Raoआयकर अपील सं. / Ita No.1277/Pun/2024 "नधा"रण वष" / Assessment Year : 2013-14

For Appellant: Shri Rajendra AgiwalFor Respondent: Shri B.S. Rajpurohit
Section 250Section 40Section 68

concerned. The AO also made addition of unsecured loans received from the following parties to the tune of Rs.1,29,81,441/- as Income from Other Sources u/s.68 of the Act : S.No. Name of the party in whose name Sum credited under the the sum is credited guise of unsecured

Anuradha Reddy, Gudivada vs. The Income Tax Officer, Ward-1, Gudivada

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

ITA 305/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam25 Sept 2024AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Ble(Through Hybrid Hearing) आयकर अपील सं./ I.T.A. No.305/Viz/2024 (िनधा"रण वष" / Assessment Year : 2017-18) Anuradha Reddy, Vs. The Income Tax Officer, Gudivada. Ward-1, Pan: Babpr5333M Gudivada. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Appellant By : Sri M.V. Prasad, Ar ""याथ" क" ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar सुनवाई क" तारीख / Date Of Hearing : 09/09/2024 घोषणा क" तारीख/Date Of : 25/09/2024 Pronouncement O R D E R

For Appellant: Sri M.V. Prasad, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 133(6)Section 142(1)Section 143(2)Section 144Section 271ASection 271FSection 69A

business income of the assessee was admitted at Rs. 5,50,000/- on gross receipts of Rs. 45 lakhs and also the income from other sources at Rs. 36,297/-. Further, the assessee also furnished the sale deeds and purchase deeds of his land property before the Ld. AO. However ... entire deposits are treated as unexplained income of the assessee U/s. 69A of the Act and brought to tax under the head ‘income from other sources’. Thus, the Ld. AO made addition of Rs. 34,00,000/- U/s. 69A r.w.s 115BBE of the Act and also initiated the penalty proceedings