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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

Indian Renewable Energy Development Agency Limited, Delhi vs. Deputy Commissioner of Income Tax, Circle - 10(1), Delhi

ITA 2569/DEL/2024[2013-14]Status: DisposedITAT Delhi31 Dec 2025AY 2013-14

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

schedule K aggregating to Rs.24,25,06,519/-to the extent of income aggregating to Rs.23,22,36,762/-was held to be income from other sources as against the same being shown as business income by the assessee; (b) AO held that the assessee is not at all eligible ... partly allowed the appeal of the assessee and held certain incomes to be business income and certain other incomes to be income from other sources, resulting in cross appeal being filed by the assessee and the Revenue.Accordingly, following issue relevant to Assessment Years involved are framed for adjudication

Indian Renewable Energy Development Agency Limited, Delhi vs. Deputy Commissioner of Income Tax, Circle-10(1), Delhi

ITA 2568/DEL/2024[2012-13]Status: DisposedITAT Delhi31 Dec 2025AY 2012-13

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

schedule K aggregating to Rs.24,25,06,519/-to the extent of income aggregating to Rs.23,22,36,762/-was held to be income from other sources as against the same being shown as business income by the assessee; (b) AO held that the assessee is not at all eligible ... partly allowed the appeal of the assessee and held certain incomes to be business income and certain other incomes to be income from other sources, resulting in cross appeal being filed by the assessee and the Revenue.Accordingly, following issue relevant to Assessment Years involved are framed for adjudication

Indian Renewable Energy Development Agency Limited, Delhi vs. Deputy Commissioner of Income Tax, Circle - 10(1), Delhi

ITA 2567/DEL/2024[2011-12]Status: DisposedITAT Delhi31 Dec 2025AY 2011-12

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

schedule K aggregating to Rs.24,25,06,519/-to the extent of income aggregating to Rs.23,22,36,762/-was held to be income from other sources as against the same being shown as business income by the assessee; (b) AO held that the assessee is not at all eligible ... partly allowed the appeal of the assessee and held certain incomes to be business income and certain other incomes to be income from other sources, resulting in cross appeal being filed by the assessee and the Revenue.Accordingly, following issue relevant to Assessment Years involved are framed for adjudication

Indian Renewable Energy Development Agency Limited, Delhi vs. Deputy Commissioner of Income Tax, Circle-10(1), Delhi

ITA 2566/DEL/2024[2010-11]Status: DisposedITAT Delhi31 Dec 2025AY 2010-11

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

schedule K aggregating to Rs.24,25,06,519/-to the extent of income aggregating to Rs.23,22,36,762/-was held to be income from other sources as against the same being shown as business income by the assessee; (b) AO held that the assessee is not at all eligible ... partly allowed the appeal of the assessee and held certain incomes to be business income and certain other incomes to be income from other sources, resulting in cross appeal being filed by the assessee and the Revenue.Accordingly, following issue relevant to Assessment Years involved are framed for adjudication

Lifestyle and Media Holding Ltd, New Delhi vs. ACIT, Circle-18(1), New Delhi

In the result, this appeal of the assessee is allowed

ITA 255/DEL/2020[2016-17]Status: DisposedITAT Delhi31 Dec 2025AY 2016-17

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.3714/Del/2024 (Assessment Year 2015-16) Dy. Commissioner Of Lifestyle & Media Holding Income Tax, Limited (Formerly Known As Ndtv Vs. C.R. Building, Lifestyle Holdings Limited) New Delhi. Plot No.09, Unit No. 055, Ground Floor Capia, Corporate Suites, Jasola, New Delhi-110025. Pan-Aadcn3076F (Appellant) (Respondent) Shri R.P. Mall, Adv. Assessee By Department By Ms. Ankush Kalra, Sr. Dr Date Of Hearing 29/10/2025 Date Of Pronouncement 31/12/2025 O R D E R [ Per Bench: All The Captioned Appeals Filed By The Assessee Against The Separate Orders Passed By Learned Commissioner Of Income Tax (Appeals)-6, Delhi [Ld. Cit(A)] For Ay 2014-15 To 1016017 & Having Common Issues, Therefore, They Are Dispose- Off By A Common Order. First, We Taken Assessee Appeal For Ay 2014-15 In Ita No. 64/Del/2019. Ita No.3714/Del/2024 & Lifestyle & Media Holdings Limited Vs. Dci

Section 143(3)Section 2(13)Section 71

case there was a profit or loss on sale of shares or it would yield dividend income which would fall under the head 'Income from other sources'. In the case of the assessee it was noted that merely terming the activity of holding of investment as "business ... Lifestyle and Media Holdings Limited vs. DCI various streams of income out of these investments, one of which was assessable under the head ‘Income from other sources’. Similar is the view of coordinate bench in assessee’s own case for AY 2009-10 as extracted by us in preceding para

Lifestyle and Media Holding Ltd, New Delhi vs. DCIT, Circle-18(1), New Delhi

In the result, this appeal of the assessee is allowed

ITA 64/DEL/2019[2014-15]Status: DisposedITAT Delhi31 Dec 2025AY 2014-15

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.3714/Del/2024 (Assessment Year 2015-16) Dy. Commissioner Of Lifestyle & Media Holding Income Tax, Limited (Formerly Known As Ndtv Vs. C.R. Building, Lifestyle Holdings Limited) New Delhi. Plot No.09, Unit No. 055, Ground Floor Capia, Corporate Suites, Jasola, New Delhi-110025. Pan-Aadcn3076F (Appellant) (Respondent) Shri R.P. Mall, Adv. Assessee By Department By Ms. Ankush Kalra, Sr. Dr Date Of Hearing 29/10/2025 Date Of Pronouncement 31/12/2025 O R D E R [ Per Bench: All The Captioned Appeals Filed By The Assessee Against The Separate Orders Passed By Learned Commissioner Of Income Tax (Appeals)-6, Delhi [Ld. Cit(A)] For Ay 2014-15 To 1016017 & Having Common Issues, Therefore, They Are Dispose- Off By A Common Order. First, We Taken Assessee Appeal For Ay 2014-15 In Ita No. 64/Del/2019. Ita No.3714/Del/2024 & Lifestyle & Media Holdings Limited Vs. Dci

Section 143(3)Section 2(13)Section 71

case there was a profit or loss on sale of shares or it would yield dividend income which would fall under the head 'Income from other sources'. In the case of the assessee it was noted that merely terming the activity of holding of investment as "business ... Lifestyle and Media Holdings Limited vs. DCI various streams of income out of these investments, one of which was assessable under the head ‘Income from other sources’. Similar is the view of coordinate bench in assessee’s own case for AY 2009-10 as extracted by us in preceding para

Shri Shah Afroze Hossain, Bhagalpur vs. Dy. CIT, Cent, Cir-2, Patna

In the result, the appeal of the assessee is partly allowed in terms indicated above

ITA 711/PAT/2024[2022-23]Status: DisposedITAT Patna30 Dec 2025AY 2022-23

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.711/Pat/2024 Assessment Year: 2022-23 Shri Shah Afroze Hossain.….…………………....…………………....Appellant 12, Shahganjhi, Habibpur, Bhagalpur, Bihar-812006. [Pan: Aapph1112D] Vs. Dcit, Central Circle-2, Patna..………....…..………………….…..... Respondent Appearances By: Shri Manish Rastogi, Adv., Appeared On Behalf Of The Appellant. Md. Shadab Ahmed, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 14, 2025 Date Of Pronouncing The Order : December 30, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Cit(A), Patna-3 (Hereinafter Referred To As “Ld. Cit(A)”) Dated 22.10.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Filed His Return Of Income For The Assessment Year 2022–23 Declaring A Total Income Of ₹75,56,770, Comprising The Income From Business Of ₹6,54,569, Long- Term Capital Gains: ₹49,60,293 & Income From Other Sources Of ₹19,35,912. A Search & Seizure Operation Under Section 132 Of The Act Was Carried Out On 29.12.2022 At The Residential & Business Premises Of The Assessee Pursuant To A Warrant Of Authorisation Issued By The Director Of Investigation, Patna. During The Course Of The Search

Section 132Section 142(1)Section 143(2)Section 250Section 50CSection 50C(2)

total income of ₹75,56,770, comprising the income from business of ₹6,54,569, long- term capital gains: ₹49,60,293 and income from other sources of ₹19,35,912. A search and seizure operation under section 132 of the Act was carried out on 29.12.2022 at the residential

Ila Khimjibhai Dulla, Mumbai vs. Ward 41(4)(2), Kautilya Bhavan

In the result, the appeal of the assessee is allowed

ITA 6716/MUM/2025[2015-16]Status: DisposedITAT Mumbai30 Dec 2025AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 144Section 147Section 148Section 148ASection 149(1)(b)Section 54

brother and sister-in-law, and during the relevant assessment year, her total income was below the basic exemption limit. She derived income from other sources and long-term capital gains arising from the sale of an immovable property. The property was jointly owned, and pursuant to the agreement

Vaibhav Dwarkanath Warekar, Navi Mumbai vs. Income Tax Office, Navi Mumbai

In the result, the appeal by the assessee is partly allowed

ITA 5432/MUM/2025[2011-12]Status: DisposedITAT Mumbai30 Dec 2025AY 2011-12

Bench: Shri Sandeep Singh Karhailshri Makarand Vasant Mahadeokarvaibhav Dwarkanath Warekar 1 Midland Chs, Sector-9A Vashi, Navi Mumbai ............... Appellant Pan: Aalpw3682P

For Appellant: Shri Laxman SutarFor Respondent: Ms. Kavitha Kaushik, Sr.DR
Section 131Section 143(3)Section 147Section 148Section 250Section 69

individual and proprietor of M/s Kohinoor Enterprise. For the year under consideration, the assessee derived income from salary, capital gains and income from other sources. However, the assessee did not file his original return of income. Accordingly, notice under section 148 of the Act was issued to the assessee

DCIT, Circle 3 4, Mumbai vs. Tata Consultancy Services Limited, Mumbai

In the result, appeals of both, revenue and assessee are partly

ITA 2244/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Dec 2025AY 2017-18

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Porus Kaka, Sr. AdvocateFor Respondent: Shri Ajay Chandra, CIT DR
Section 92CSection 92C(3)

IN THE INCOME TAX APPELLATE TRIBUNAL “H” BENCH MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT

Tata Consultancy Services Limited, Mumbai vs. Deputy Commissioner of Incometax 3(4), Mumbai

In the result, appeals of both, revenue and assessee are partly

ITA 1517/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Dec 2025AY 2017-18

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Porus Kaka, Sr. AdvocateFor Respondent: Shri Ajay Chandra, CIT DR
Section 92CSection 92C(3)

IN THE INCOME TAX APPELLATE TRIBUNAL “H” BENCH MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT

Mahent Baba Ishwar Shah, Kalanaur, Rohtak vs. PCIT, Rohtak

In the result, the appeal of the assessee is allowed

ITA 2297/DEL/2025[2020-21]Status: DisposedITAT Delhi30 Dec 2025AY 2020-21

Bench: Shri M. Balaganesh & Shri Raj Kumar Chauhanassessment Year : 2020-21 Mahent Baba Ishwar Shah, Vs. Pcit, Dera Mahent Baba Ishwar Shah, Rohtak, Near Bus Stand, Income Tax Office, Near Pnb Bhiwani Road, Rohtak. Kalanaur, Distt. Rohtak, Rohtak. Pan: Abspi7267G

For Appellant: Shri Navin Gupta, Advocate &For Respondent: Shri Jitendra Singh, CIT-DR
Section 142(1)Section 143(1)(a)Section 144Section 263Section 69A

through Faceless e-Assessment Scheme-2019. While concluding the assessment a consideration of Rs.98,23,352/- was proposed as variation under the head, ‘Income from other sources’ and total income was assessed at Rs.1,06,24,622/-. The assessee is stated to have challenged the said assessment order and appeal

Aggarwal Agro Industries, Karnal vs. ITO-Ward-1, Karnal

In the result, the appeal filed by the assessee is partly allowed

ITA 2544/DEL/2024[2013-14]Status: DisposedITAT Delhi30 Dec 2025AY 2013-14
For Appellant: Shri Manav Agarwal, ARFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 139(1)Section 142(1)Section 143(2)Section 147Section 148Section 292CSection 69C

facts in making addition of Rs.61,549/- on account of alleged commission paid by treating it as alleged income Under the head 'Income from Other Sources' and that too by recording incorrect facts and findings and without any basis, material or evidence available on record and the Ld. CIT(Appeals

Balasaheb Vitthal Shinde, Pune vs. Income Tax Officer, Ward 5(4), Pune, Aayakar Vibhag, Pmt Building, Swargate

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

ITA 674/PUN/2025[2011-12]Status: DisposedITAT Pune29 Dec 2025AY 2011-12

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2011-12 Balasaheb Vitthal Shinde Ito, Ward-5(4), Pune Chaledi, Nasarapur, Taluka Bhor, Vs. Pune – 412213 Pan: Anips1140A (Appellant) (Respondent) Assessee By : Shri Deepak S Sasar Department By : Shri Vidya Ratan Kishore Date Of Hearing : 17-12-2025 Date Of Pronouncement : 29-12-2025 O R D E R Per R.K. Panda, Vp:

For Appellant: Shri Deepak S SasarFor Respondent: Shri Vidya Ratan Kishore
Section 143(3)Section 148Section 2Section 63

wherein he made addition of Rs.49,44,572/- on account of short term capital gain and tower rent of Rs.1,57,138/- as income from other sources. 3. Before the Ld. CIT(A) / NFAC the assessee filed certain additional evidences which the Ld. CIT(A) / NFAC has accepted and forwarded

Vaibhav Das Mundhra, Kolkata vs. Assistant Director of Income Tax, CPC, Bangalore

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

ITA 35/KOL/2025[2021-2022]Status: DisposedITAT Kolkata29 Dec 2025AY 2021-2022

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 234BSection 234CSection 250Section 295(1)Section 90

entity based in Singapore. He also earned rental income from his house properties situated in India and Income from Capital gains and income from other sources. The appellant had earned the following income from outside India (Singapore) which was subject to tax in both India and Singapore: Salary income from

Pooja Prabhakar, Chennai vs. Income Tax Officer, Non Corporate Ward 15(1), Chennai

In the result, appeal filed by the assessee is allowed

ITA 3049/CHNY/2025[2018-19]Status: DisposedITAT Chennai29 Dec 2025AY 2018-19

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Mr. R. Venkataraman, FCA &For Respondent: Shri. ARV Sreenivasan, CIT
Section 144Section 147Section 148Section 148ASection 151ASection 69Section 69ASection 69C

Added interest income of Rs.1,39,030/- received from HDFC Bank and State Bank of India under the head “Income from Other Sources”; de: ITA. No:3049/Chny/2025 iv. Treated cash deposits of Rs.29,83,600/- made in the HDFC Bank account as unexplained money and made an addition u/s.69A r.w.s

Sivarajpandi Vasantha, Thirupalai, Madurai vs. Deputy Commissioner of Income Tax, Non Corp. Circle-1, Madurai, Income Tax Office

In the result, appeal filed by the assessee is allowed

ITA 2878/CHNY/2025[2020-2021]Status: DisposedITAT Chennai29 Dec 2025AY 2020-2021

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

For Appellant: Mr. T. Vasudevan, AdvocateFor Respondent: Shri. K. Ilaiyaraja, Addl. CIT
Section 139(5)Section 144BSection 147Section 148Section 151ASection 57

Based on the information received by the department, the assessee has receive interest Rs.12,46,287/- under the head of income from other sources, out of which interest received at Rs.11,42,061/- on account of death compensation of her husband death, a notice u/s.148 of the Act was issued

The Karnataka State Regn and Stamps Department Officials Multi-Purpose Co-Op Society Limited, Bengaluru vs. ACIT, Circle-2(1)(1), Bengaluru

ITA 1518/BANG/2025[2017-18]Status: DisposedITAT Bangalore29 Dec 2025AY 2017-18

Bench: Shri Prashant Maharishi, Vice – & Shri Sandeep Singh Karhail

For Appellant: Shri Pranav Krishna, AdvocateFor Respondent: Shri Subramanian – JCIT DR
Section 57

deduction under section 80 P (2) (a) (i) of the act as it is chargeable to tax as income under the head income from other sources under section 56 of the act. The learned authorized representative vehemently supported the claim of the assessee in the return of income and stated ... business income of the assessee. He further submitted that there is no finding in the assessment order that such interest income is income from other sources. He submits that the case of the assessee squarely covered by the decision of the honourable Karnataka High Court by two decisions which have

Pujya Sharanabasaveshwara Pattina Souharda Sahakari Sangha Ni Maski, Maski vs. Income-Tax Office, Ward-1, Raichur

In the result appeal of the assessee is allowed

ITA 1180/BANG/2025[2020-21]Status: DisposedITAT Bangalore29 Dec 2025AY 2020-21

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhailassessment Year : 2020-21

For Appellant: Shri Anil Kumar, CAFor Respondent: Shri Muthu Shankar, CIT(DR)(ITAT), Bengaluru
Section 133Section 143Section 144BSection 263Section 56Section 80

notice on 23 March 2022 to the assessee that why the claim of deduction under section 80 P should not be taxed as income from other sources under section 56 of the Act and added back to the total income of the assessee. The assessee Page 3 of 14 responded ... commercial banks at ₹ 3,418,255/– which the assessing officer has failed to examine properly and consider the total income under the head income from other sources in view of the decision of the Hon’ble Karnataka High Court in case of PCIT v. Totgars Co-operative Sale Society

Srikanth Kakati, Kothagudem vs. Income Tax Officer, Ward - 1, Kothagudem

In the result, appeal of the Assessee is allowed

ITA 1341/HYD/2025[2018-19]Status: DisposedITAT Hyderabad24 Dec 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1341/Hyd/2025 Assessment Year 2018-2019 Srikanth Kakati, The Income Tax Officer, Kothagudem–507 Ward-1, Vs. 101. Khammam. Kothagudem. Telangana. Pin –507 101. Pan Csupk1347N Telangana. (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ms Ml Niharika, Advocate राज" व "ारा /Revenue By: Ms Kritika Jaiswal, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 18.12.2025 घोषणा की तारीख/Pronouncement: 24.12.2025 आदेश/Order

For Appellant: MS ML Niharika, AdvocateFor Respondent: MS Kritika Jaiswal, Sr. AR
Section 144BSection 148Section 69Section 69A

Rs.13,00,000 u/s 69 as unexplained investments and Rs. 14,15,000/-u/s 69A unexplained money and Rs 2,84,093 under income from other sources by the learned Assessing Officer (AO) is bad in law and in fact. 2. The CIT(A) has erred in confirming the addition ... investment under section 69 of the Act. 4. The CIT(A) has erred in confirming the addition of Rs. 2,84,093/- as "income from other sources", whereas the said sum constitutes business income of the appellant and ought to have been assessed under the head "Profits and Gains