← All Phrases

“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

Addl. CIT, Special Range-2, New Delhi vs. Bokaro Power Supply Company Pvt. Ltd., New Delhi

ITA 4455/DEL/2017[2011-12]Status: DisposedITAT Delhi12 Jan 2024AY 2011-12
For Appellant: Shri M. P. Rastogi, AdvFor Respondent: Shri PN Shastri, Adv Shri Kanv Bali, Sr. DR
Section 143(3)

joint venture partners are inextricably linked with the setting up of the plant and the interest earned cannot be treated as income from other sources. “Indian Oil Panipat Power Consortium Ltd.” (supra) is squarely applicable to the present case, as discussed. This is in consonance with "Bokaro Steel Ltd.” (supra

DCIT, Circle-2(1), Hyderabad vs. Kmc Constructions Limited, Hyderabad

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

ITA 32/HYD/2017[2011-12]Status: DisposedITAT Hyderabad11 Jan 2024AY 2011-12

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Shri K. Madhusudan, CIT-DR
Section 145(3)

learned Assessing Officer to adopt the profit rate of 12.5% on contract receipts and to tax the interest income as ‘income from other sources’. 28. On the aspect of profit rate, as stated above, brief facts of the case are that during the course of assessment proceedings, despite several opportunities ... Tribunal in ITA Nos. 1247/Hyd/2012 and batch for the assessment year 2008-09 and 2009-10 and held that the interest income is income from other sources and accordingly brough it to tax. 22. Learned CIT(A) examined the details of the finance charges wherein

Kmc Contructions Limited, Hyderabad vs. Addl. CIT, Range-2, Hyderabad

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

ITA 1734/HYD/2016[2011-12]Status: DisposedITAT Hyderabad11 Jan 2024AY 2011-12

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Shri K. Madhusudan, CIT-DR
Section 145(3)

learned Assessing Officer to adopt the profit rate of 12.5% on contract receipts and to tax the interest income as ‘income from other sources’. 28. On the aspect of profit rate, as stated above, brief facts of the case are that during the course of assessment proceedings, despite several opportunities ... Tribunal in ITA Nos. 1247/Hyd/2012 and batch for the assessment year 2008-09 and 2009-10 and held that the interest income is income from other sources and accordingly brough it to tax. 22. Learned CIT(A) examined the details of the finance charges wherein

M/S. Moodbidri Co-Operative Service Bank Limited, Moodbidri vs. Pr. Commissioner of Income Tax, Panaji-Goa Income-Tax Officer, Ward-2(1), Mangaluru

ITA 930/BANG/2023[2018-19]Status: DisposedITAT Bangalore11 Jan 2024AY 2018-19

Bench: Shri George George K & Shri Chandra Poojariassessment Year : 2018-19 M/S. Moodbidri Co-Operative Service Vs. Ito, Bank Ltd., Ward –2(1), Door No.192, Main Road, Mangaluru. Moodbidri – 574 227. Pan : Aabam 7065 K Appellant Respondent Assessee By : Shri. V. Srinivasan, Advocate Revenue By : Shri. D. K. Mishra, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 09.01.2024 Date Of Pronouncement : 11.01.2024

For Appellant: Shri. V. Srinivasan, AdvocateFor Respondent: Shri. D. K. Mishra, CIT(DR)(ITAT), Bengaluru
Section 143Section 143(2)Section 143(3)Section 263Section 57Section 80P

case of Totgar's Society (188 taxmann 282) has held that the interest earned on deposits with banks fall under the category of "Income from Other Sources", which are not eligible for deduction U/s 80P of the 1 T Act, 1961. The AO in his assessment order has applied ... ought to have considered the interest received from SCDCC Bank of Rs. 3,53,68,999/- as income from other sources and disallowed the deduction U/s 80P in respect of income arising from this receipt also.” 6. On receipt of the aforesaid notice, assessee filed objections vide its letter dated

Addl CIT RG 7(1), Mumbai vs. Piramal Enterprises Ltd (Formerly Knwon As Piramal Healthcare Ltd) (As Ultimate Successor to Nicholas Piramal India Ltd), Mumbai

ITA 5091/MUM/2010[2005-06]Status: DisposedITAT Mumbai11 Jan 2024AY 2005-06

Bench: Shri Kuldip Singh & Shri S Rifaur Rahmanassessment Year: 2005-06 M/S. Piramal Enterprises Dy. Commissioner Of Limited (Formerly Known Income Tax, As Piramal Healthcare Range-8(2)(1), Limited) (Earlier Known As Mumbai. Nicholas Piramal India Ltd.), Vs. Piramal Tower, Agastya Corporate Park, Lbs Marg, Kamani Junction, Kurla (West), Mumbai – 400 070 Pan: Aaacn4538P (Appellant) (Respondent) Assessment Year: 2005-06 Dy. Commissioner Of M/S. Piramal Enterprises Income Tax, Limited (Formerly Known Circle-8(2)(1), As Piramal Healthcare [Erstwhile Dcit Circle- Ltd.) (As Ultimate 7(1)], Successor To Nicholas Vs. Mumbai. Piramal India Ltd.), Piramal Tower, Ganpatrao Kadam Marg, Lower Parel, Mumbai – 400 013 Pan: Aaacn4538P (Appellant) (Respondent)

For Appellant: Shri Priyank Gala, A.RFor Respondent: Shri P.D. Chogule, (Addl. CIT) Sr. A.R
Section 28Section 40Section 45

Building by reducing only appropriate portion of sale proceeds from the said block. GROUND XIV: Treating Rental Income from RPIL House as "Income from other sources" 1. On the facts and circumstances of the case and in law, the CIT(A) erred in upholding the action ... treating the Rental Income from RP House as "Income from Other Sources" instead of "Income from House Property" as offered by the Appellant on the alleged ground that the Appellant is not the owner of the property. 2. He failed to appreciate and ought to have held that the Appellant

Piramal Healthcare Ltd ( Earlier Knownas Nicholas Piramal India Ltd), Mumbai vs. Addl CIT 7(1), Mumbai

ITA 3706/MUM/2010[2005-06]Status: DisposedITAT Mumbai11 Jan 2024AY 2005-06

Bench: Shri Kuldip Singh & Shri S Rifaur Rahmanassessment Year: 2005-06 M/S. Piramal Enterprises Dy. Commissioner Of Limited (Formerly Known Income Tax, As Piramal Healthcare Range-8(2)(1), Limited) (Earlier Known As Mumbai. Nicholas Piramal India Ltd.), Vs. Piramal Tower, Agastya Corporate Park, Lbs Marg, Kamani Junction, Kurla (West), Mumbai – 400 070 Pan: Aaacn4538P (Appellant) (Respondent) Assessment Year: 2005-06 Dy. Commissioner Of M/S. Piramal Enterprises Income Tax, Limited (Formerly Known Circle-8(2)(1), As Piramal Healthcare [Erstwhile Dcit Circle- Ltd.) (As Ultimate 7(1)], Successor To Nicholas Vs. Mumbai. Piramal India Ltd.), Piramal Tower, Ganpatrao Kadam Marg, Lower Parel, Mumbai – 400 013 Pan: Aaacn4538P (Appellant) (Respondent)

For Appellant: Shri Priyank Gala, A.RFor Respondent: Shri P.D. Chogule, (Addl. CIT) Sr. A.R
Section 28Section 40Section 45

Building by reducing only appropriate portion of sale proceeds from the said block. GROUND XIV: Treating Rental Income from RPIL House as "Income from other sources" 1. On the facts and circumstances of the case and in law, the CIT(A) erred in upholding the action ... treating the Rental Income from RP House as "Income from Other Sources" instead of "Income from House Property" as offered by the Appellant on the alleged ground that the Appellant is not the owner of the property. 2. He failed to appreciate and ought to have held that the Appellant

Indore Pragatishil Sahakari Sakh Sanstha Maryadit, Indore vs. NFAC, Delhi, Indore

Appeal stand allowed

ITA 317/IND/2023[2018-19]Status: DisposedITAT Indore10 Jan 2024AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manish Boradassessment Year: 2018-19 Indore Pragatishil Income Tax Department, Sahakari Sakh Sanstha Nfa, बनाम/ Maryadit, Delhi Vs. Indore. (Assessee / Appellant) (Revenue / Respondent) Pan: Aaaai3124L Assessee By Shri S.S.Deshpande, Ca Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 02.01.2024 Date Of Pronouncement 10.01.2024

Section 143(2)Section 143(3)Section 57Section 80P

NFAC has erred in upholding the addition of Rs. 10,38,997/- being interest received on fixed deposit on the bank as income from other sources. (2) It was proved before the Ld. CIT(A) NFAC and the ld. AO that the judgment of Totgars Co-operative Society ... assessment proceedings, the assessee stated that the interest income on FDR is part of business income and should not be treated as income from other sources. However, the ld. AO noticed that the assessee has itself declared the interest income on FDR at Rs. 10,77,910/- as income from

Dy. Commissioner of Income Tax, Central Circle-2(3), Hyderabad vs. Varsha Viswanath Properties Private Limited, Hyderabad

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 2050/HYD/2018[2016-17]Status: DisposedITAT Hyderabad09 Jan 2024AY 2016-17

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

return filed in response to notice issued under section 153A for AY 2017-18, the assessee had admitted the same as income from other sources in his individual return of income. Since the assessee did not file any Page 31 of 46 M/s. Varsha Viswanath Properties Private Limited batch information

Dy. Commissioner of Income Tax, Central Circle-2(3), Hyderabad vs. Varsha Viswanath Properties Private Limited, Hyderabad

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 2049/HYD/2018[2015-16]Status: DisposedITAT Hyderabad09 Jan 2024AY 2015-16

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

return filed in response to notice issued under section 153A for AY 2017-18, the assessee had admitted the same as income from other sources in his individual return of income. Since the assessee did not file any Page 31 of 46 M/s. Varsha Viswanath Properties Private Limited batch information

Dy. Commissioner of Income Tax, Central Circle-2(3), Hyderabad vs. Varsha Viswanath Properties Private Limited, Hyderabad

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 2048/HYD/2018[2014-15]Status: DisposedITAT Hyderabad09 Jan 2024AY 2014-15

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

return filed in response to notice issued under section 153A for AY 2017-18, the assessee had admitted the same as income from other sources in his individual return of income. Since the assessee did not file any Page 31 of 46 M/s. Varsha Viswanath Properties Private Limited batch information

Dy. Commissioner of Income Tax, Central Circle-2(3), Hyderabad vs. Varsha Viswanath Properties Private Limited, Hyderabad

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 2047/HYD/2018[2013-14]Status: DisposedITAT Hyderabad09 Jan 2024AY 2013-14

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

return filed in response to notice issued under section 153A for AY 2017-18, the assessee had admitted the same as income from other sources in his individual return of income. Since the assessee did not file any Page 31 of 46 M/s. Varsha Viswanath Properties Private Limited batch information

Dy. Commissioner of Income Tax, Central Circle-2(3), Hyderabad vs. Varsha Viswanath Properties Private Limited, Hyderabad

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 2046/HYD/2018[2012-13]Status: DisposedITAT Hyderabad09 Jan 2024AY 2012-13

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

return filed in response to notice issued under section 153A for AY 2017-18, the assessee had admitted the same as income from other sources in his individual return of income. Since the assessee did not file any Page 31 of 46 M/s. Varsha Viswanath Properties Private Limited batch information

Varsha Viswanath Properties Private Limited, Hyderabad vs. Asst. Commissioner of Income Tax, Central Circle-2(3), Hyderabad

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 1910/HYD/2018[2016-17]Status: DisposedITAT Hyderabad09 Jan 2024AY 2016-17

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

return filed in response to notice issued under section 153A for AY 2017-18, the assessee had admitted the same as income from other sources in his individual return of income. Since the assessee did not file any Page 31 of 46 M/s. Varsha Viswanath Properties Private Limited batch information

Varsha Viswanath Properties Private Limited, Hyderabad vs. Asst. Commissioner of Income Tax, Central Circle-2(3), Hyderabad

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 1909/HYD/2018[2015-16]Status: DisposedITAT Hyderabad09 Jan 2024AY 2015-16

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

return filed in response to notice issued under section 153A for AY 2017-18, the assessee had admitted the same as income from other sources in his individual return of income. Since the assessee did not file any Page 31 of 46 M/s. Varsha Viswanath Properties Private Limited batch information

Varsha Viswanath Properties Private Limited, Hyderabad vs. Asst. Commissioner of Income Tax, Central Circle-2(3), Hyderabad

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 1908/HYD/2018[2014-15]Status: DisposedITAT Hyderabad09 Jan 2024AY 2014-15

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

return filed in response to notice issued under section 153A for AY 2017-18, the assessee had admitted the same as income from other sources in his individual return of income. Since the assessee did not file any Page 31 of 46 M/s. Varsha Viswanath Properties Private Limited batch information

Varsha Viswanath Properties Private Limited, Hyderabad vs. Asst. Commissioner of Income Tax, Central Circle-2(3), Hyderabad

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 1907/HYD/2018[2013-14]Status: DisposedITAT Hyderabad09 Jan 2024AY 2013-14

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

return filed in response to notice issued under section 153A for AY 2017-18, the assessee had admitted the same as income from other sources in his individual return of income. Since the assessee did not file any Page 31 of 46 M/s. Varsha Viswanath Properties Private Limited batch information

Varsha Viswanath Properties Private Limited, Hyderabad vs. Asst. Commissioner of Income Tax, Central Circle-2(3), Hyderabad

In the result, all the appeals filed by the assessee as well as the Revenue are treated as allowed for statistical purposes

ITA 1906/HYD/2018[2012-13]Status: DisposedITAT Hyderabad09 Jan 2024AY 2012-13

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri S. Rama Rao, ARFor Respondent: Ms. TH. Vijaya Lakshmi, CIT-DR
Section 132Section 133ASection 153A

return filed in response to notice issued under section 153A for AY 2017-18, the assessee had admitted the same as income from other sources in his individual return of income. Since the assessee did not file any Page 31 of 46 M/s. Varsha Viswanath Properties Private Limited batch information

Southern Petrochemical Industries Corporation Ltd., Chennai vs. ITO, Corporate Ward-3(1), Chennai

In the result, the appeal stands partly allowed in terms of our above order

ITA 170/CHNY/2023[2003-04]Status: DisposedITAT Chennai09 Jan 2024AY 2003-04

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.170/Chny/2023 (िनधा)रण वष) / Assessment Year: 2003-04) M/S. Southern Petrochemical Income Tax Officer बनाम Industries Corporation Limited Corporate Ward-3(1) 88, Spic House, Mount Road, Guindy, Chennai-600 034. / Vs. Chennai-600 032. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacs-4668-K (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri R. Vijayaraghavan & Shri Saroj Kumar Parida (Advocates)-Ld. Ars " थ"कीओरसे/Respondent By : Shri Nilay Baran Som (Cit) & Shri Ar V Sreenivasan (Addl. Cit)-Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 16-10-2023 घोषणाकीतारीख /Date Of Pronouncement : 09-01-2024 आदेश / O R D E R

For Appellant: Shri R. Vijayaraghavan & Shri Saroj KumarFor Respondent: Shri Nilay Baran Som (CIT) &
Section 143(3)

deduction in the computation of profit and gains of the business could not be set-off against interest received under the head ‘income from other source’. 5.3 It also transpired that the assessee advanced sum of Rs.16.78 Crores to its sister concern viz. M/s SPEL semiconductor Ltd. Pursuant to revisionary ... find that the assessee has claimed only net expenditure in the Profit & Loss Account., The interest income is not separately assessed as ‘Income from other sources’ which would mean that the interest income has business nexus. In such a case, the ratio of decision of Hon’ble Supreme Court

M/S. Pane Mangalore Rss Bank, Bantwal vs. Income Tax Office, Ward-2(1), Mangalore

In the result, appeal of the assessee is allowed

ITA 958/BANG/2023[2018-19]Status: DisposedITAT Bangalore09 Jan 2024AY 2018-19

Bench: Shri George George K. & Shri Chandra Poojariassessment Year: 2018-19

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Shri Subramanian S., D.R
Section 143Section 143(3)Section 263Section 80P(2)(d)Section 8O

earned from SCDCC Bank Ltd./Syndicate Bank and Co-operative Societies, Dividend from SCDCC Bank Ltd. and Dividend from Co-operative Bank as income from other sources as follows: Schedule 7 for computation of income placed at page no.5 of paper book: Income considered under other heads Interest received – FROM ... above income of Rs.1,54,05,706/-, which is shown as “income from other sources” by assessee in Schedule 7 to computation of income. Being so, in our opinion, the order passed by ld. AO vide order dated 19.4.2021 is not prejudicial so far as erroneous to the interest

Sri Kalika Parameswari Co-Operative Society Limited, Shivamogga vs. Income-Tax Officer, Ward-1 & Tps, Shivamogga

ITA 955/BANG/2023[2018-19]Status: DisposedITAT Bangalore09 Jan 2024AY 2018-19

Bench: Shri George George K & Shri Chandra Poojari

For Appellant: Shri. B. V. Raveendranath, CAFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bengaluru
Section 2Section 250Section 56Section 57Section 801Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 8o

learned Assessing Officer who has held that interest income from co-operative banks and other banks are to be considered under income from other sources under section 56 of the Income Tax Act, 1961.Further, the learned CIT(A) has not allowed the expenditure under section 57 Income ... held that interest income earned from investments with Central District Co- operative Bank is to be assessed as “Income from Other Sources” under section 56 of the Act, and the same is not entitled to deduction either under section 80P(2)(a)(i) or under section