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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

Amardeep Chaudhary, Panchkula, Haryana vs. Income Tax Officer, Ward 1 Panchkula, Panchkula Haryana

In the result, Assessee’s appeal is partly allowed

ITA 750/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh06 Jan 2026AY 2017-18

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Krinwant Sahay, Am आयकरअपीलसं./ Ita No.750/Chd/2025 (िनधा"रणवष" / Assessment Year: 2017-18) Amardeep Chaudhary Ito Ward 1 Panchkula बनाम/ Vs. House No. 153, Sector-2, Ito Ward-1, Panchkula, Panchkula, Haryana - 134112 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aakpc-3432-A (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ : Sh. B.M. Monga & Sh. Rohit Kaura (Advocates) Appellant By ""थ"कीओरसे/Respondent By : Sh. Vivek Vardhan (Addl. Cit) Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 17-12-2025 घोषणाकीतारीख /Date Of Pronouncement : 06- 01-2026

For Respondent: Sh. Vivek Vardhan (Addl. CIT) Sr. DR
Section 143(1)Section 23Section 28Section 56(2)(viii)Section 57

made on account of amount received by the assessee as enhanced compensation alongwith the interest u/s 28 of the Land Acquisition Act, as income from other sources, whereas the enhanced compensation AMD interest received u/s 23(I-A), 23(2) AMD 28 is exempt as held ... made on account of amount received by the Assessee as enhanced compensation along with interest of the Land Acquisition Act under as ‘income from other sources’. 8. During proceedings before us, ld. Counsel for the Assessee made submissions that the Assessee is entitled for enhanced compensation alongwith interest

Income Tax Officer, Ward 5, Sangli. vs. Shree Ganesh Nagari Sahakari Pat Sanstha Maryadit, Ashta

In the result, the appeal filed by the Revenue is dismissed

ITA 2375/PUN/2025[2018-19]Status: DisposedITAT Pune06 Jan 2026AY 2018-19

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2375/Pun/2025 िनधा"रण वष" / Assessment Year : 2018-19 Ito, Ward-5, Sangli. Vs. Shree Ganesh Nagari Sahakari Pat Sanstha Maryadit, Ashta, Tal. Walwa, Dist. Sangli, Sangli- 416301. Pan : Aaaas8248R Appellant Respondent C. O. No.49/Pun/2025 (Arising Out Of Ita No.2375/Pun/2025) िनधा"रण वष" / Assessment Year : 2018-19 Shree Ganesh Nagari Vs. Ito, Ward-5, Sangli. Sahakari Pat Sanstha Maryadit, Ashta, Tal. Walwa, Dist. Sangli, Sangli- 416301. Pan : Aaaas8248R Appellant Respondent Revenue By : Shri Umesh Phade Assessee By : Shri Sarang Gudhate Date Of Hearing : 25.11.2025 Date Of Pronouncement : 06.01.2026 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Revenue Is Directed Against The Order Dated 05.08.2025 Passed By Ld. Cit(A)/Nfac For The Assessment

For Appellant: Shri Sarang GudhateFor Respondent: Shri Umesh Phade
Section 143(3)Section 28Section 36(1)(va)Section 80P(2)Section 80P(2)(d)

directed to calculate the deduction related to the interest income earned from nationalised banks and the same may be assessed as income from other sources. Therefore, the AO is directed to allow deduction u/s 80P(2)(d) in respect of interest income earned from cooperative banks

The Govt. Tele Communication Employees Co-Op. Society Ltd., Chennai vs. ITO, Ncw-11(1), Chennai

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

ITA 2527/CHNY/2024[2017-18]Status: DisposedITAT Chennai06 Jan 2026AY 2017-18

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 2527/Chny/2024 िनधा"रण वष"/Assessment Year: 2017-18 M/S. The Government Tele The Income Tax Officer, Communication Employees Vs. Non-Corporate Ward 11(1), Co-Operative Society Limited, Chennai. 37-A, Sembudoss Street, Broadway, Chennai - 600 001. Pan: Aabat 3072B (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri M.Karunakaran, Advocate ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 06.01.2026 घोषणा क" तारीख/Date Of Pronouncement : 06.01.2026

For Appellant: Shri M.Karunakaran, AdvocateFor Respondent: Ms. Gouthami Manivasagam
Section 250Section 80L

appellant submits that even if interest on fixed deposits and savings bank interest are not entitled to exemption u/s 80L the correct income under these sources should be computed after allowing interest paid against interest receipts as there is direct :- 4 -: nexus between the interest payment and interest receipts ... interest income. The case of the Assessee is that the Assessing Officer has treated the interest income earned by the Assessee has income from other sources and estimated the expenditure only. In the Assessment Order, the Assessing Officer has not properly considered the expenditure incurred by the Assessee to earn

Nayana Digant Kapadia, Mumbai vs. Income Tax Officer, 20(2)(1), Mumbai, Piramal Chambers

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

ITA 3173/MUM/2025[2017-2018]Status: DisposedITAT Mumbai06 Jan 2026AY 2017-2018

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2017-18 Nayana Digant Kapadia Income Tax Officer, 152, Ramanuj, 20(2)(1), Mumbai Road No.9, Wadala, Vs. Mumbai – 400 031 (Pan : Aabpk8446R) (Appellant) (Respondent) Present For: Assessee : Shri Satish Mody, Ca Revenue : Shri Pravin Salunkhe, Sr. Dr Date Of Hearing : 15.10.2025 Date Of Pronouncement : 06.01.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of Addl /Jcit (A)-3 Delhi Vide Itba/Apl/S/250/2024-25/1074687488(1), Dated 19.03.2025 Passed Against The Intimation Issued By Centralized Processing Center (Cpc), Bengaluru, U/S. 143(1) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 30.11.2019 For Assessment Year 2017-18. 2. Grounds Taken By The Assessee Are Reproduced As Under: “1. The Learned Commissioner Of Income Tax (Appeals)-32 Erred In Confirming The Order Made U/S 143(1) Dt 30/11/2019 Wherein The Interest Income Of Rs 26,49,581/- From Dlk Commercial Pvt Ltd Was Added As Income Of The Appellant On Accrual Basis Inspite Of The Fact That The Appellant U/S 145 Of The Income Tax

For Appellant: Shri Satish Mody, CAFor Respondent: Shri Pravin Salunkhe, Sr. DR
Section 143(1)Section 143(1)(a)Section 145

which was revised on 25.03.2019, reporting total income at Rs.4,35,340/-. Income reported by the assessee included income from salary and income from other sources. Under the head ‘income from other sources’, interest of Rs.93,391/- was reported from bank and Rs.21,950/- from fixed deposits with bank. Assessee ... perusal of material on record, we are satisfied that the Appellant has been consistently offering to tax interest income under the head 'Income from Other Sources' on receipt basis in line with the provisions of Section 145 of the Act. Interest income of INR.30,06,671/- reflected in Form 26AS

Lakhi Ram, Gurugram vs. ITO Ward 1(4) Gurgaon, Gurugram

In the result, appeal of the assessee is allowed

ITA 2028/DEL/2024[2019-20]Status: DisposedITAT Delhi05 Jan 2026AY 2019-20

Bench: Sh. Satbeer Singh Godara & Sh. Amitabh Shuklaita No. 2028/Del/2024 : Asstt. Year: 2019-20 Lakhi Ram, Vs Income Tax Officer, House No. 70, Village- Dhanwapur, Ward-1(4), Daultabad, Gurugram, Gurugram, Haryana-122001 Haryana-122001 (Appellant) (Respondent) Pan No. Awzpr6814L Assessee By : None Revenue By : Ms. Ankush Kalra, Sr. Dr Date Of Hearing: 05.01.2026 Date Of Pronouncement: 05.01.2026 Order Per Satbeer Singh Godara: This Assessee’S Appeal For Assessment Year 2019-20 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2023-24/1061566876(1) Dated 27.02.2024, In Proceedings U/S 144 R.W.S. 142(1) Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: NoneFor Respondent: Ms. Ankush Kalra, Sr. DR
Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 144Section 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. 5. We have given my thoughtful consideration to the assessee’s pleadings and Revenue’s foregoing vehement contention. It emerges that this tribunal ... capital receipt' 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

Ishares Core Msci Total International Stock Etf (As A Successor to Ishare Core Taotal International Stock Mauritius Company ), Mumbai vs. Dy CIT (Int. Tax)-2(2)(1), Mumbai

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

ITA 6774/MUM/2025[2023-24]Status: DisposedITAT Mumbai02 Jan 2026AY 2023-24

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailishares Core Msci Emerging Markets Etf (As A Successor To Ishares Core Emerging Markets Mauritius Company) C/O Ernst & Young Llp, 17Th Floor, The Ruby, 29, Senapati Bapat Marg, ............... Appellant Dadar (West), Mumbai - 400028 Pan : Aafci3337N V/S Deputy Commissioner Of Income Tax (International Tax) - 2(2)(2) Room No.606, 6Th Floor, Kautilya Bhavan, ……………… Respondent C-41 To C-43, G-Block, Bandra Kurla Complex, Bandra (East), Mumbai – 400051 Ishares Msci All Country Asia Ex Japan Etf C/O Ernst & Young Llp, 17Th Floor, The Ruby, 29, Senapati Bapat Marg, Dadar (West), Mumbai - 400028 Pan : Aabti7439L ............... Appellant

For Appellant: Shri Pranav GandhiFor Respondent: Shri Satya Pal Kumar, CIT-DR
Section 143(3)Section 144C(13)Section 144C(5)Section 70Section 70(2)

Provisions of section 70 of the income tax act provides for the set off of losses from one source against income from another source under the same head of income. According to section 70 (1) where assessee suffers loss in respect of any source under any head of income other ... income. Hon’ble Special Bench also observed that, what is taxed by the Act is not different source of income, independently and that income from different source is clubbed under respective heads that are finally aggregated into the total income. The relevant extract of the observations

Ishares Core Msci Emerging Markets Etf (As A Successor to Ishares Core Emerging Markets Mauritius Company, Mumbai vs. DCIT (Tp) 2(2)(2), Mumbai

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

ITA 6051/MUM/2025[2023-24]Status: DisposedITAT Mumbai02 Jan 2026AY 2023-24

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailishares Core Msci Emerging Markets Etf (As A Successor To Ishares Core Emerging Markets Mauritius Company) C/O Ernst & Young Llp, 17Th Floor, The Ruby, 29, Senapati Bapat Marg, ............... Appellant Dadar (West), Mumbai - 400028 Pan : Aafci3337N V/S Deputy Commissioner Of Income Tax (International Tax) - 2(2)(2) Room No.606, 6Th Floor, Kautilya Bhavan, ……………… Respondent C-41 To C-43, G-Block, Bandra Kurla Complex, Bandra (East), Mumbai – 400051 Ishares Msci All Country Asia Ex Japan Etf C/O Ernst & Young Llp, 17Th Floor, The Ruby, 29, Senapati Bapat Marg, Dadar (West), Mumbai - 400028 Pan : Aabti7439L ............... Appellant

For Appellant: Shri Pranav GandhiFor Respondent: Shri Satya Pal Kumar, CIT-DR
Section 143(3)Section 144C(13)Section 144C(5)Section 70Section 70(2)

Provisions of section 70 of the income tax act provides for the set off of losses from one source against income from another source under the same head of income. According to section 70 (1) where assessee suffers loss in respect of any source under any head of income other ... income. Hon’ble Special Bench also observed that, what is taxed by the Act is not different source of income, independently and that income from different source is clubbed under respective heads that are finally aggregated into the total income. The relevant extract of the observations