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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

Prem Singh, Chamba vs. ACIT Circle Palampur, Palampur

In the result, the appeal for AY 2017-18 stands partly allowed

ITA 947/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh15 Jan 2026AY 2017-18

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No. 946/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2015-16) & 2. आयकर अपील सं. / Ita No. 947/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) Shri Prem Singh Dcit Circle, Palampur बनाम/ The Palace. Chamba Himachal Pradesh - 176061 Vs. Himachal Pradesh – 176310 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aampr-8876-P (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Shri Ajay Jain (Ca) – Ld. Ar Revenue By : Shri Bharat Bhushan Garg (Cit) (Virtual) - Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 13-11-2025 घोषणाकीतारीख /Date Of Pronouncement : 13-01-2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1. The Assessee Is In Further Appeals Before Us For Assessment Years (Ay) 2015-16 & 2017-18 Which Arises Out Of Separate Orders Of Learned First Appellate Authority. First, We Take Up Appeal For Assessment Year (Ay) 2015-16 Which Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), Nfac [Cit(A)] Dated 22-07-2025 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S 143(3) Of The Act On 29-12-2017. The Assessee Is Aggrieved By Computation Of Capital

For Appellant: Shri Ajay Jain (CA) – Ld. ARFor Respondent: Shri Bharat Bhushan Garg (CIT) (Virtual) - Ld. DR
Section 143(3)Section 48Section 54Section 54F

Rs.1,54,301/-. The assessee did not reflect the same in his return of income and therefore, the same was added as income from other sources. During first appeal, the assessee stated that the refund relates to AY 2016-17 for which return of income was filed

Mange Ram, Gurugram vs. Pr. Commissioner of Income Tax, Faridabad

In the result, appeal of the assessee is allowed

ITA 710/DEL/2024[2017-18]Status: DisposedITAT Delhi15 Jan 2026AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Amitabh Shuklaassessment Year: 2017-18 Sh. Mange Ram, Vs. Pr. Commissioner Of Income H. No. 261, Main Pataudi Tax, Faridabad, Road, Near Hanuman Temple, Village Garoli Khurd, P.O.- Basai, Gurugram, Haryana Pan: Amwpr7462B (Appellant) (Respondent) Assessee By Sh. Suraj Bhan Nian, Adv., Sh. Mahfuzur Rahman, Ca Department By Ms. Amish S. Gupt, Cit(Dr) Date Of Hearing 15.01.2026 Date Of Pronouncement 15.01.2026 Order Per Satbeer Singh Godara, Jm This Assessee’S Appeal For Assessment Year 2017-18, Arises Against The Principal Commissioner Of Income Tax [In Short, The “Pcit”], Faridabad’S Order Dated 04.12.2023 Having Din & Order No. Itba/Rev/F/Rev5/2023-24/1058449758(1), Involving Proceedings Under Section 147 R.W.S. 144 Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’). Herd Both The Parties. Case File Perused. 2. It Emerges During The Course Of Hearing That The Sole Substantive Issue Between The Parties Is That Of Correctness Of The Learned Lower Authorities’ Action Assessing The Assessee’S Interest Component Of Land Acquisition Compensation U/S 28 Of The Land Acquisition Act, 1894, While Invoking Section 57(Iv) R.W.S. 56(1)(A) R.W.S. 145A(B) Of The Act. 3. Learned Sr. Dr Representing The Department Vehemently Argued That The Instant Issue Is No More Res Integra In Light Of Mahender Pal Narang Vs. Cbdt (2020) 423 Itr 13 (P&H) As Well As Pcit Vs. Inderjit Singh Sodhi Huf (2024) 161 Taxmann.Com 301 (Del.) Wherein The Department Has Succeeded Before Their Lordships That The Impugned Interest Component Ought To Be Assessed As Income From “Other” Sources Only. 4. We Have Given Our Thoughtful Consideration To The Assessee’S Pleadings & Revenue’S Foregoing Vehement Contention. It Emerges That This Tribunal’S Recent Decision

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 263Section 28Section 56(2)(viii)

taxmann.com 301 (Del.) wherein the department has succeeded before their lordships that the impugned interest component ought to be assessed as income from “other” sources only. 4. We have given our thoughtful consideration to the assessee’s pleadings and Revenue’s foregoing vehement contention. It emerges that this tribunal ... forming part of enhanced compensation as envisaged in section 45(5) of the Act to 'revenue receipt' chargeable to tax as income from other sources. The view taken by the Ld. AO that interest under section 28 of Land Acquisition Act received by the assessee is exempt under section

Sharda Devi, Basti vs. Income Tax Officer, Basti

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

ITA 525/LKW/2025[2017-18]Status: DisposedITAT Lucknow13 Jan 2026AY 2017-18

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2017-18 Sharda Devi, Vs. The Income Tax Officer, W/O Shyam Singh, Near Zila Basti-New Chikitsalaya, Purani Basti, Basti-2721 Pan: Auspd8424B (Appellant) (Respondent) Assessee By: None Revenue By: Sh. Amit Kumar, Dr Date Of Hearing: 27.10.2025 Date Of Pronouncement: 13.01.2026 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit(A), Nfac Dated 16.01.2025 Wherein The Ld. Cit(A) Has Dismissed The Appeal Of The Assessee Against The Order Of Penalty Passed By The Ld. Ao Dated 17.01.2022 In Limine Without Going Into The Merits Of The Case. The Grounds Of Appeal Are As Under:- “01. Because The Cit(A) Has Erred On Facts & In Law In Upholding The Addition Of Rs.8,11,663/- Being Cash Deposited In Bank During Demonetization Period Under Section 69A R.W.S. 115Bbe Of The Act, Which Addition Is Contrary To Facts, Bad In Law Be Deleted. 02. Because The Cit(A) Has Failed To Appreciate That The Assessee Is Carrying On The Business Of Household Items, Such As, Business Of Achar, Kuchry (Grocery) Declaring Profit Under Section 44Ad @ 8% Wherein The Provisions Of Section 68 & Section 69 Are Not Applicable, The Addition Of Rs.8,11,663/- Made By The Ao & Upheld By The Cit(A) Is Contrary To The Provisions Of Law Be Deleted. 03. Because The Explanation Furnished By The Assessee Has Not Been Found False Of Untrue, The Addition Of Rs.8,11,663/- Made By The Ao & Upheld By The Cit(A) Be Deleted.”

For Appellant: NoneFor Respondent: Sh. Amit Kumar, DR
Section 115BSection 147Section 271ASection 44ASection 68Section 69Section 69A

same to tax @ 60% under section 115BBE. He also added back the interest received on these deposits of Rs. 15,797/- as income from other sources. Subsequently, the ld. AO also initiated penalty proceedings under section 271AAC(1) of the Act and issued a show cause notice. The assessee

Income Tax Officer, Ward-I, Mandi Gobindgarh vs. Rohit, Mandi Gobindgarh

The appeal stands dismissed

ITA 905/CHANDI/2025[2021-22]Status: DisposedITAT Chandigarh13 Jan 2026AY 2021-22

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकर अपील सं. / Ita No.905/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2021-22) Ito-Ward-1 Shri Rohit Mandi Gobindgarh Shop No.308, Sec-26A बनाम/ At Sirhind, New Libra Kothi Amloh Road, Gobindgarh Vs. Railway Road, Sirhind Fatehgarh Sahib - 147301 Fatehgarh Sahib – 147301 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Asopr-3001-Q (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Shri Ashok Goyal (Ca) – Ld. Ar Revenue By : Shri Bharat Bhushan Garg (Cit) – Ld. Dr (Virtual) सुनवाईकीतारीख/Date Of Hearing : 10-11-2025 घोषणाकीतारीख /Date Of Pronouncement : 13-01-2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Revenue For Assessment Year (Ay) 2021-22 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] Dated 12-06- 2025 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S. 143(3) R.W.S 144B Of The Act On 24-12-2022. The Sole Grievance Of The Revenue Is Deletion Of Addition Of Rs.1509.90 Lacs As Made By Ld. Ao On Account Of Alleged Bogus Purchases While Framing The Assessment. The Sole Ground Of Appeal Read As Under: - Whether On The Facts & In The Circumstances Of The Case, The Cit(A) / Nfac Was Right In Law In Deleting The Addition Of Rs.15,09,90,967/- As Shown Purchases Expenses Claimed By The Assessee & Nefac Has Added To The Total Income & Taxed As Income From Other Sources U/S 69C Of The Act?

For Appellant: Shri Ashok Goyal (CA) – Ld. ARFor Respondent: Shri Bharat Bhushan Garg (CIT) – Ld. DR (Virtual)
Section 133(6)Section 143(3)Section 145(3)Section 69C

Rs.15,09,90,967/- as shown purchases expenses claimed by the assessee and NeFAC has added to the total income and taxed as income from other sources u/s 69C of the Act? 2. The Ld. CIT-DR advanced arguments supporting the assessment order whereas Ld. AR drew attention to various

Parmod Kumar Negi, Kinnaur vs. Income Tax Officer, Rampur Bushahr

The appeal stands allowed for statistical purposes

ITA 1291/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh13 Jan 2026AY 2018-19

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.1291/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2018-19) Shri Parmod Kumar Negi Ito Rampur Bushahar Ward No. 3 Barang, Kalpa, Barang, बनाम/ Vs. Himachal Pradesh - 172001 Kinnaur, Himachal Pradesh – 172107 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Afepn-8712-K (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. M.R. Sharma (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Dr. Ranjit Kaur (Addl. Cit) - Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 12.01.2026 घोषणाकीतारीख /Date Of Pronouncement : 13.01.2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2018- 19 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), Nfac [Cit(A)] Dated 22-02-2024 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] On Best Judgment Basis U/S 144 Of The Act On 23-05-2021. In The Assessment Order, Ld. Ao Made Considered Agricultural Income Of Rs.33,24,120/- As Income From Other Sources For Non-Compliance By The Assessee. The Ld.

For Appellant: Sh. M.R. Sharma (Advocate) – Ld. ARFor Respondent: Dr. Ranjit Kaur (Addl. CIT) - Sr. DR
Section 144

assessment order, Ld. AO made considered agricultural income of Rs.33,24,120/- as income from other sources for non-compliance by the assessee. The Ld. 2 CIT(A) confirmed the assessment for the same very reasons. The only prayer of Ld. AR is another opportunity of hearing before lower authorities