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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

Sh. Pawan Kumar, Chandigarh vs. DCIT, Circle 1(1), Chandigarh

In the result, the appeal of the assessee is allowed

ITA 750/CHANDI/2022[2019-20]Status: DisposedITAT Chandigarh04 Mar 2024AY 2019-20

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Rajiv Ahuja, Advocate and Shri Pawan Kumar, AssesseFor Respondent: Shri Dharam Vir, JCIT, Sr. DR
Section 139(1)Section 143(1)Section 90

income, the assessee has shown his foreign sourced income in form of capital gains amounting to Rs 6,05,94,361/- and income from other sources amounting to Rs 43,94,317/- and has claimed tax relief under section 90 / 90A amounting to Rs. 86,35,117/-. Separately, Form

Trimbak Konher Patil, Hubblli vs. Income-Tax Officer, Ward-2(1), Hubli

ITA 6/BANG/2024[2019-20]Status: DisposedITAT Bangalore04 Mar 2024AY 2019-20

Bench: Shri George George K & Shri Laxmi Prasad Sahu

Section 139(1)Section 143(1)(a)Section 154Section 2(24)(x)Section 250Section 36(1)(va)Section 43B

IN THE INCOME TAX APPELLATE TRIBUNAL "A" BENCH : BANGALORE BEFORE SHRI GEORGE GEORGE K, VICE PRESIDENT AND SHRI LAXMI PRASAD

Trimbak Konher Patil, Hubballi vs. Income-Tax Officer, Ward-2(1), Hubli

ITA 5/BANG/2024[2018-19]Status: DisposedITAT Bangalore04 Mar 2024AY 2018-19

Bench: Shri George George K & Shri Laxmi Prasad Sahu

For Appellant: Shri. Vinay Kulkarni, CA
Section 139(1)Section 143(1)(a)Section 154Section 2(24)(x)Section 250Section 36(1)(va)Section 43B

IN THE INCOME TAX APPELLATE TRIBUNAL "A" BENCH : BANGALORE BEFORE SHRI GEORGE GEORGE K, VICE PRESIDENT AND SHRI LAXMI PRASAD

Kohinoor Industrial Premises Co-Op Society Ltd., Mumbai vs. ITO Ward-31(2)(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 3697/MUM/2023[2018-19]Status: DisposedITAT Mumbai04 Mar 2024AY 2018-19

Bench: Shri Kuldip Singh & Shri Amarjit Singhkohinoor Industrial Vs. Ito, Ward 31(2)(2), Premises Co-Op Society Kautilya Bhavan, Limited, Plot No.10, Cts Bandra, No. 67, Dindoshi Village, Mumbai – 400 051 Western Express Highway Goregaon East Maharashtra – 400063 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaaak4970G Appellant .. Respondent Appellant By : Kirit S. Sanghvi Respondent By : S. Arunkumar Date Of Hearing 27.02.2024 Date Of Pronouncement 04.03.2024 आदेश / O R D E R Per Amarjit Singh (Am): This Appeal Filed By The Assessee Is Directed Against The Order Passed By The Ld. Cit(A) Nfac, Dated 11.07.2023 For A.Y. 2018-19. The Assessee Has Raised The Following Grounds Before Us: “1. The Learned Ctt(A) [Nfac, Delhi] Erred On Facts & In Law In Disallowing Rs.22,92,110/-Claimed As Deduction Under S 80P(2)(D) Of The Act 2. The Learned Cit(A) [Nfac, Delhi] Erred On Facts & In Law In Confirming The Order Passed Under S 154 Of The Act By Holding That There Was No Mistake Apparent From The Records 3. The Learned Cit(A) (Nfac, Delhi) Erred On Facts & In Law In Confirming The View Of The Cpc That The Appellant Did Not Correctly Fill In Sch-Via For Claiming Deduction Under S 80P. Relief Claimed: The Appellant Be Allowed Deduction Of Rs.22,92,110/- Under S 80P(2)(D) Of The Act.

For Appellant: Kirit S. SanghviFor Respondent: S. Arunkumar
Section 143(1)Section 154Section 80PSection 80P(2)(d)

ground(s) of appeal.” 2. Fact in brief is that the assessee is a cooperative society derived income from house property and income from other sources during the year under consideration. The assessee has filed return of income on 07.09.2018 declaring total income of Rs.25,54,640/-. The assessee cooperative

Upinder Kaur Khalsa Rao, Mumbai vs. Income Tax Officer 35(3)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 3670/MUM/2023[2011-12]Status: DisposedITAT Mumbai04 Mar 2024AY 2011-12

Bench: Shri Vikas Awasthy, Jm & Ms Padmavathy S, Am

For Appellant: Shri Haridas Bhat, CAFor Respondent: 27.02.2024
Section 148Section 2(24)

will enhance the capital value of the property. Therefore, the AO held that the amount is liable to be taxable under the head Income from Other Sources and completed the assessment accordingly. Aggrieved the assessee filed appeal before the CIT(A) and made similar submissions ... assessee that the amount received towards hardship allowance is a capital receipt not subject to tax. The AO treated the said receipt as income from other sources by holding that – “7. From the above, it is clear, that the receipt by assessee of Rs 53,50,000/- (or right

Ratan Chand Goel, Bahraich vs. ITO-2, Bahraich

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

ITA 331/LKW/2023[2013-14]Status: DisposedITAT Lucknow29 Feb 2024AY 2013-14

Bench: Shri Sudhanshu Srivastava & Shri Anadee Nath Misshraassessment Year: 2013-14 Ratan Chand Goel, Vs. The Income Tax Officer-Ii, Mohalla – Indira Nagar, 423-A, Vaishnavpuram, Risia Bazar, Huzoorpur Road, Bahraich- 271875 Bahraich- 271801, U.P. Pan: Ailpg 1104C (Appellant) (Respondent) Appellant By Shri Shubham Rastogi, Ca Respondent By Shri Sanjeev Krishna Sharma, Addl. Cit (Dr) Date Of Hearing 17/01/2024 Date Of Pronouncement 29/02/2024

Section 250

that in this case the return of income was filed in the status of individual showing income under the heads ‘business’ and ‘income from other sources’ and declaring the total income at Rs.2,01,210/-. The assessee’s case was selected for I.T.A. No.331/Lkw/2023 2 scrutiny under CASS

Ms. Gunjan Agarwal, Barabanki vs. The Income Tax Officer-5(4), Barabanki

The appeal of the assessee stands allowed for statistical purposes

ITA 107/LKW/2023[2012-13]Status: DisposedITAT Lucknow29 Feb 2024AY 2012-13

Bench: Shri Sudhanshu Srivastavaa.Ys. 2012-13 Ms. Gunjan Agarwal, Vs. Income Tax Officer-5(4), Fatehpur, Barabanki. Barabanki- 225001 (U.P.). Pan Aaspa 4237D (Appellant) (Respondent) Appellant By Shri Shubham Rastogi, Ca Respondent By Shri Sanjeev Krishna Sharma, Addl. Cit( Dr) Date Of Hearing 11/01/2024 Date Of Pronouncement 29/02/2024 O R D E R

Section 10(38)Section 139Section 147Section 148Section 68

response thereto the assessee filed her Return of Income showing income from salary at Rs.65,000/-, business income at Rs.5,15,961/- and income from other sources at Rs.68,069/-. The assessee also showed income from Long Term 2 Capital Gain to the tune of Rs.8,60,714/- from speculative

Gujarat Urja Vikas Nigam Ltd, Vadodara vs. The ACIT, Cirecle-1(1)(1), Vadodara

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

ITA 318/AHD/2020[2016-17]Status: DisposedITAT Ahmedabad29 Feb 2024AY 2016-17

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

For Appellant: Shri M. J. Shah, A.R. & Shri Jimi Patel , A.RFor Respondent: Shri Sudhendu Das, CIT DR
Section 143(3)Section 14ASection 234ASection 271(1)(c)

paid. The next step is that the AO has to examine the sources of the funds which were invested for earning the dividend income. If the source of such investment is out of the interest bearing borrowings, then only the question of disallowance of interest would arise, otherwise ... directing the Assessing Officer to treat the interest income on loan/advances and miscellaneous receipts of Rs. 76.05 lacs as business income instead of income from other sources without appreciating that the nature of the income is of purely interest and not from any activities of business or profession

The Farmers Service Co-Op Ltd., Ranasthalam vs. Income-Tax Officer Ward-1, Srikakulam

In the result, appeal of the Revenue is dismissed

ITA 310/VIZ/2023[2020-21]Status: DisposedITAT Visakhapatnam29 Feb 2024AY 2020-21

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./ I.T.A. No.310/Viz/2023 ("नधा"रण वष" / Assessment Year :2020-21) The Farmers Service Co-Op. Ltd., Vs. Income Tax Officer, Ranasthalam, Ward-1, Srikakulam-532407. Srikakulam. Pan: Aabtt 4377 L (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Appellant By : Sri I Kama Sastry, Ar ""याथ" क" ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar

For Appellant: Sri I Kama Sastry, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 80PSection 80P(2)(a)

Apex Court has held that interest earned from retaining the amount payable to its members shall not be considered as income from other sources. However, in the instant case the facts are distinguishable and hence in our view the ratio laid down in the case of M/s. Totgars Cooperative Sale

Sandhya Garg, Jabalpur vs. The ITO, W-2(4), Bhopal

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

ITA 178/IND/2022[2011-12]Status: DisposedITAT Indore29 Feb 2024AY 2011-12

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanisandhya Garg Ito War,2(4) 30, Subhash Grih Nirman Bhopal Society, Priydarshini Colony Vs. Jabalpur (Appellant / Assessee) (Respondent/ Revenue) Pan: Agtpg7994G Assessee By Shri Manoj Kumar Jain, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 29.02.2024 Date Of Pronouncement 29.02.2024

Section 54FSection 69

declared in the return, ld CIT (A) erred in confirming addition of Income of Rs.400000/- on sale of Furniture and Fixtures as income from other sources. Furniture used for personal purposes is not a capital asset, therefore, not liable for capital gain." 2. Ground no.1 is regarding addition made

Royal Indl Estate Co Op Soc Ltd, Mumbai vs. Deputy Commissioner of Income Tax - 20(1), Piramal Chamber, Lalbaug, Parel, Mumbai

In the result, appeal of the assessee is allowed

ITA 3792/MUM/2023[2018-19]Status: DisposedITAT Mumbai29 Feb 2024AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

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

deduction u/s. 80P(2)(d) of the Act. 2. The assessee is a co-operative society having income from house property and income from other sources. The Ld. AO noted that the assessee has an interest of Rs.28,08,568/- on bank fixed deposits and savings account, which was claimed

Mohd Shahid Mohd Yusuf Qureshi, Mumbai vs. Dy. Commissioner of Income Tax, Mumbai

In the result, appeal filed by the assessee stands allowed for statistical purpose

ITA 2788/MUM/2023[AY 2020-21]Status: DisposedITAT Mumbai29 Feb 2024

Bench: Shri.Narender Kumar Choudhry () & Miss. Padmavathy S. ()

Section 131Section 132Section 144Section 250

same as commission income of the assessee and by subtracting the amount of Rs.5,62,000/- as shown by the assessee as ’Income from other sources’ in its return of income for the year under consideration, added the differential amount of Rs.2,59,772/- (Rs. 8,21,772/- (-) Rs.5

Anand Urban Cooperative Credit Society Limited, Aurangabad vs. Income Tax Offier, Ward-1(5), Aurangabad

Appeal is allowed in above terms

ITA 136/PUN/2024[2018-19]Status: DisposedITAT Pune28 Feb 2024AY 2018-19

Bench: Shri Satbeer Singh Godara

For Appellant: Shri Santosh B GarudFor Respondent: Shri B.S. Rajpurohit
Section 143(3)Section 80Section 80P(2)(a)Section 80P(2)(d)

136/PUN./2024 earned on Investment made in other Cooperative societies/Nationalized/Scheduled Bank by the appellant is liable to be taxed under the Head of Income from Other Sources and not Income from Profits and Gains from Business/Profession which is eligible for deduction u/s.80(P)(a)(i). 2. On the facts

Prathi Vijay Kumar, Srikakulam vs. Income Tax Officer, Ward-1, Srikakulam

In the result, appeal of the assessee is allowed

ITA 284/VIZ/2023[2021-22]Status: DisposedITAT Visakhapatnam28 Feb 2024AY 2021-22

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./ I.T.A. No.284/Viz/2023 ("नधा"रण वष" / Assessment Year : 2021-22) Prathi Vijay Kumar, Vs. Income Tax Officer, Srikakulam, Ward-1, Andhra Pradesh-532312. Srikakulam. Pan: Aizpp 5124 Q (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Appellant By : Sri Gvn Hari, Ar ""याथ" क" ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar

For Appellant: Sri GVN Hari, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 143(1)Section 234B

savings account for Rs. 511/- and from the sale of sites Rs. 21,76,370/- and is admitted under the respective heads ie., ‘income from other sources’ and ‘income from capital gains’. Thus, an addition of Rs.21,76,881/- was made by the CPC and 3 also charged the interest ... Addl./JCIT (Appeals) ought to have deleted the adjustment as the appellant already admitted this amount of Rs.21,76,681/- under the heads ‘income from other sources’ and ‘capital gains’. 4. Any other grounds may be urged at the time of hearing.” 3. At the outset, the main contention

Smt. Anjani Kumari Vardha, Vijayawada vs. The ITO, Vijayawada

ITA 207/VIZ/2017[2011-2012]Status: DisposedITAT Visakhapatnam28 Feb 2024AY 2011-2012

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble(Through Hybrid Hearing) आयकर अपील सं./ I.T.A. Nos. 215/Viz/2015 & 207/Viz/2017 ("नधा"रण वष" / Assessment Years: 2010-11 & 2011-12) Smt. Anjani Kumari Varada, Vs. Income Tax Officer, Vijayawada. Ward-1(4), Pan: Acvpv 2970 M Vijayawada. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Assessee By : Sri Bvs Chalapathi Rao ""याथ" क" ओर से / Revenue By : Dr. Aparna Villuri, Sr. Ar

For Appellant: Sri BVS Chalapathi RaoFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 131Section 143(1)Section 143(2)Section 143(3)

following paras on merits. 3. Brief facts pertaining to AY 2010-11 are that the assessee is an individual, deriving income from other sources filed her return of income for the AY 2010-11 on 25/01/2012 admitting total income of Rs. 4,14,580/- and the same was processed

Anjani Kumari Varada, Vijayawada vs. The ITO, Vijayawada

ITA 215/VIZ/2015[2010-11]Status: DisposedITAT Visakhapatnam28 Feb 2024AY 2010-11

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble(Through Hybrid Hearing) आयकर अपील सं./ I.T.A. Nos. 215/Viz/2015 & 207/Viz/2017 ("नधा"रण वष" / Assessment Years: 2010-11 & 2011-12) Smt. Anjani Kumari Varada, Vs. Income Tax Officer, Vijayawada. Ward-1(4), Pan: Acvpv 2970 M Vijayawada. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Assessee By : Sri Bvs Chalapathi Rao ""याथ" क" ओर से / Revenue By : Dr. Aparna Villuri, Sr. Ar

For Appellant: Sri BVS Chalapathi RaoFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 131Section 143(1)Section 143(2)Section 143(3)

following paras on merits. 3. Brief facts pertaining to AY 2010-11 are that the assessee is an individual, deriving income from other sources filed her return of income for the AY 2010-11 on 25/01/2012 admitting total income of Rs. 4,14,580/- and the same was processed

Mayank Bansal, Howrah vs. ITO, Ward 46(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1016/KOL/2023[2018-19]Status: DisposedITAT Kolkata28 Feb 2024AY 2018-19

Bench: Dr. Manish Borad & Shri Sonjoy Sarma]

Section 143(3)Section 80G

erred in confirming the action of AO in making addition of the sum of Rs. 26,12,500/- under the head income from other sources when the same was donation paid which was already disallowed without granting deductions under chapter VIA i.e., Sl. No. 13 while computing the total income ... assessee is in relation with confirming the action of the AO by sustaining the addition of Rs. 26,12,500/- under the head income from other sources as and when it was already disallowed by ld. AO without granting deduction under Chapter VIA i.e. Sl. No. 13 while computing

Roop Kumar Chopra, Jaipur vs. PCIT Jaipur 1, Jaipur

In the result, the appeal of the assessee is allowed

ITA 264/JPR/2023[2018-19]Status: DisposedITAT Jaipur28 Feb 2024AY 2018-19

Bench: Him By The Assessee In Compliance To The Notice Notices Issued To Him U/S 142(1) As Well As U/S 143(2) Of The Act By The Ao As Erroneous In So Far As It Is Prejudicial To The Interest Of The Revenue For The Purpose Of Section 263 Of The Act & Consequently Setting Aside The Assessment Order Passed Dated 01-01-2021 To Be Made Afresh Made Is Most Arbitrarily, Unjust, Untenable & Liable To Be Vacated.’’

For Appellant: Shri Dheeraj Borad, CAFor Respondent: Shri Ajay Malik, CIT
Section 142(1)Section 142(2)Section 143Section 143(2)Section 143(3)Section 263Section 57

case of assessee was selected for Limited Scrutiny under the E-assessment Scheme, 2019 on the following issues. S.N. Issues 1. Deductions from income and other sources. It is noted from the assessment order that the assessee derived income from Interest and Business income during the year under consideration ... well as the documents placed on record. Perusal of the assessment records showed that the AO had allowed set off of loss from "income from other sources against business Income which is not correct as per the Income Tax Act, 1961. As per section 57 (iii) of the Act, income

Udupi District Ex-Servicemen'S Multipurpose Co-Op. Society Ltd., Udupi vs. Income Tax Officer, Ward-1 & Tps, Udupi

Accordingly, this issue is allowed for statistical purposes

ITA 77/BANG/2024[2020-21]Status: DisposedITAT Bangalore28 Feb 2024AY 2020-21

Bench: Shri Narender Kumar Choudhry & Shri Laxmi Prasad Sahuassessment Year : 2020-21 M/S. Udupi District Ex-Servicemen’S The Income Tax Multipurpose Co-Op. Officer, Society Ltd., Ward – 1 & Tps, Adi-Udupi, Udupi. Udupi – 576 103. Vs. Pan: Aabau6021F Appellant Respondent

For Appellant: Shri Mahesh R. Uppin, Advocate
Section 56Section 80PSection 80P(2)(a)

operative society from its investment made with the co-operative banks or other nationalised banks or the treasury is assessable as income from other sources u/s. 56 of the Act and not eligible for deduction u/s. 80P(2)(a)(i) of the IT Act. Aggrieved from the above order ... judgment, the assessee is not eligible for claim of deduction u/s. 80P(2)(a)(i) and interest income shall be taxed as income from other sources u/s. 56. He also submitted that the Hon’ble Apex Court has decided in the case of Kerala State Co-operative Agricultural and Rural

M/S. Nti Housing Co-Operative Society, Bengaluru vs. Assistant Commissioner of Income-Tax, Circle-2(2)(1), Bengaluru

In the result, appeal preferred by the appellant is allowed

ITA 829/BANG/2023[2017-18]Status: DisposedITAT Bangalore28 Feb 2024AY 2017-18

Bench: Shri Chandra Poojari & Ms. Madhumita Roy

For Appellant: Shri Narendra Sharma, AdvocateFor Respondent: Shri V. Parithivel, JCIT
Section 147Section 148Section 154Section 80P(2)(d)

directed that the interest earned by the assessee from commercial banks may be considered under the head ‘income from other sources’ and relief may be granted as available to the assessee u/s 57 of the Act in accordance with law. Accordingly ground No.2 and 3 raised by the asseseee stands