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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

Caddie Hotels Pvt. Ltd., Delhi vs. Pr. CIT Central Circle 17, Delhi

In the result the appeal of the assessee in ITA No

ITA 2014/DEL/2021[2014-15]Status: DisposedITAT Delhi21 Jul 2023AY 2014-15

Bench: Shri N.K. Billaiya & Shri Anubhav Sharma

For Appellant: Shri Ajay Vohra, AdvFor Respondent: Shri T. James Singson, CIT- DR
Section 143(3)Section 263Section 56(2)Section 56(2)(viib)

prejudice to the generality of the provisions of sub-section (1), the following incomes, shall be chargeable to income-tax under the head "Income from other sources", namely:- (viib) where a company, not being a company in which the public are substantially interested, receives, in any previous year, from

Kishan Mundra, Indore vs. The ITO 3(2), Indore

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

ITA 345/IND/2022[2017-18]Status: DisposedITAT Indore21 Jul 2023AY 2017-18

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanikishan Mundra Ito-3(2) 108, Shalimar Corporate Indore Centre Vs. 8-B, South Tukoganj Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Abzpm 1576 H Assessee By Shri Ashish Porwal & N.D. Patwa, Ars Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 19.07.2023 Date Of Pronouncement 21 .07.2023

Section 57

expenditure u/s 57 of the Act. He has further submitted that the AO has disallowed the claim of interest expenditure against the income from other sources for want of supporting evidence and therefore, the assesse wanted to produce evidence in support of the said claim before ... relevant material on record we note that the only issue arises in this appeal is regarding disallowance of interest expenditure against the income from other sources which was disallowed by the AO for want of supporting evidence. The appeal filed by the assesse was also dismissed

Bhavana Baban Vaity, Mumbai vs. Income Tax Officer Ward 27(1)(1), Mumbai

The appeal of the appellant is dismissed

ITA 1391/MUM/2023[2009-2010]Status: DisposedITAT Mumbai20 Jul 2023AY 2009-2010

Bench: Shri Kuldip Singhassessment Year: 2009-10

For Appellant: Shri S.M. Kapoor, A.RFor Respondent: Shri B. Laxmi Kanth, D.R
Section 142(1)Section 143(2)Section 144Section 147Section 2(47)(v)Section 53ASection 54

gone through the Assessment Order and submissions of the appellant. The learned AO carried out addition of Rs.33,63,333/- on account of income from other sources. 5.2 The appellant along with five other joint owners has sold property worth Rs.2,01,80,000/- and accordingly her share of sale

Seaview Developers Pvt. Ltd., New Delhi vs. DCIT, Circle- 23(2), New Delhi

In the result the appeal of the assessee in ITA No

ITA 3213/DEL/2018[2013-14]Status: DisposedITAT Delhi20 Jul 2023AY 2013-14

Bench: Shri N.K. Billaiya & Shri Anubhav Sharma

For Appellant: Shri Rishab Malhotra, ARFor Respondent: Shri Vivek Kumar Upadhyay, Sr. DR
Section 68Section 80I

interest expense is concerned, we find that while computing the income, the assessee has added back interest expense considered under the head “Income from other sources Rs. 57,19,934” and under the head income from other sources, the assessee has deducted interest expense of Rs. 88,767/- only, which

Vimal Kishor Shah, Mumbai vs. ITO Ward-27(3)(1), Mumbai

In the result, both the appeals of the assessee are allowed

ITA 1499/MUM/2023[2014-2015]Status: DisposedITAT Mumbai19 Jul 2023AY 2014-2015

Bench: Shri B.R. Baskaran (Am) & Shri Narender Kumar Choudhry (Jm)

Section 10(38)Section 147Section 68Section 69

parties on this issue and perused the record. The assessee is an individual and deriving income by way of salary, capital gains and income from other sources. The Investigation Wing of the Income Tax Department found out that certain concerns floated by Rajendra Jain Group are providing accommodation entries

Vimal Kishor Shah, Mumbai vs. ITO Ward-27(3)(1), Mumbai

In the result, both the appeals of the assessee are allowed

ITA 1498/MUM/2023[2011-2012]Status: DisposedITAT Mumbai19 Jul 2023AY 2011-2012

Bench: Shri B.R. Baskaran (Am) & Shri Narender Kumar Choudhry (Jm)

Section 10(38)Section 147Section 68Section 69

parties on this issue and perused the record. The assessee is an individual and deriving income by way of salary, capital gains and income from other sources. The Investigation Wing of the Income Tax Department found out that certain concerns floated by Rajendra Jain Group are providing accommodation entries

Ballaleshwar Sahakari Patpedhi Maryadit, Mumbai vs. ITO Ward-17(2)(1), Mumbai

In the result, the solitary ground of appeal filed by the assessee is partly allowed with above directions

ITA 1237/MUM/2023[2018-19]Status: DisposedITAT Mumbai19 Jul 2023AY 2018-19

Bench: Shri Prashant Maharishi, Am & Shri Narender Kumar Choudhry, Jm Ballaleshwar Sahakari Patpetdhi Income Tax Officer, Maryadit 11/11A, Amnir, Bldg, Ward 17(2)(1), Vs. Navroji Hill Road No.9, Mumbai-400 020 Dongiri, Mumbai-400 009 (Appellant) (Respondent) Pan No. Aaatb6933F Assessee By : Shri P.S. Shingte, Authorised Representative Revenue By : Shri Ashok Kumar Ambastha, Sr Dr Date Of Hearing: 13.07.2023 Date Of Pronouncement : 19.07.2023

For Appellant: Shri P.S. Shingte, AuthorisedFor Respondent: Shri Ashok Kumar Ambastha, SR
Section 143(3)Section 144BSection 56Section 80Section 80(2)(p)Section 80PSection 80P(2)Section 80P(2)(a)

income with respect to 10 items which are not income earned by the assessee from the business of the Co-operative Society-but ‘income from other sources’ taxable under Section 56 of the Act. The sum total of such ten items were determined at ₹1,46,37,054/-. The learned ... assessee at ₹1,46,37,054/-. 04. The learned Assessing Officer has considered below mentioned income as tabulated here in as income from other source :- Sl No. Description Income Earned (Rs) 1. Bank deposit interest 10845120/- 2. Bank share dividend 61/- 3. Apna Bank saving interest 168/- 4. Loan from

ACIT, Central Circle-2(1), Mumbai vs. Fancy Devi., Mumbai

In the result, the appeal filed by Revenue is dismissed

ITA 3245/MUM/2022[2017-18]Status: DisposedITAT Mumbai19 Jul 2023AY 2017-18

Bench: Shri Pavan Kumar Gadale & Ms. Padmavathy Sacit, C. Circle-2(1), Fancy Devi, Room No.804,8Thfloor, B-502, Oberoi Sky बनाम/ Oldcgoannexbuilding, Heights, Cross Road, Vs. M.K.Road, Lokhandwala, Mumbai-400020. Andheri (W), Mumbai-400053. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aegpj5895J (""थ" / Respondent) (अपीलाथ" /Appellant)

For Appellant: Shri.Ankush Kapoor.DRFor Respondent: Shri.Mahaveer Jain.AR
Section 131Section 143(2)Section 143(3)Section 153ASection 68

cited supra. We therefore respectfully following the same hold that the AO has not jurisdictional to assess the long term capital gain as income from other sources as the same is not based upon the seized or incriminating materials found during the search proceedings qua the long term capital gain

Bhandari Gold and Jewellers Private Limited, Mumbai vs. CIT (Appeal), NFAC - Delhi

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

ITA 1619/MUM/2022[2017-2018]Status: DisposedITAT Mumbai19 Jul 2023AY 2017-2018

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Bledcit – 6(1)(2) V. M/S. Bandari Gold & Jewellers Pvt. Ltd., 407, Bussaudyog Bhavan Room No. 538B, 5Th Floor Tokersi, Jivraj Road, Sewree Aayakar Bhavan, M.K. Road Mumbai - 400015 Mumbai - 400020 Pan: Aadcb1291J (Appellant) (Respondent)

Section 143(3)Section 68

IncomeTax Act, 1961 Section 145: Method of accounting. (1) Income chargeable under the head "Profits and gains of business or profession" or "Income from other sources" shall, subject to the provisions of sub-section (2), be computed in accordance with either cash or mercantile system of accounting regularly employed ... Vishwnath Prasad (1969) 721TR194 (SC) that "It is for the assessee to prove that even if the cash credit represents income, it is income from a source, which has already been taxed". The assessee has already offered the sales for taxation hence the onus Page

Cy. CIT 6(1) (2), Mumbai vs. M/S. Bhandari Gold & Jewellers Pvt. Ltd, Mumbai

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

ITA 1564/MUM/2022[2017-18]Status: DisposedITAT Mumbai19 Jul 2023AY 2017-18

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Bledcit – 6(1)(2) V. M/S. Bandari Gold & Jewellers Pvt. Ltd., 407, Bussaudyog Bhavan Room No. 538B, 5Th Floor Tokersi, Jivraj Road, Sewree Aayakar Bhavan, M.K. Road Mumbai - 400015 Mumbai - 400020 Pan: Aadcb1291J (Appellant) (Respondent)

Section 143(3)Section 68

IncomeTax Act, 1961 Section 145: Method of accounting. (1) Income chargeable under the head "Profits and gains of business or profession" or "Income from other sources" shall, subject to the provisions of sub-section (2), be computed in accordance with either cash or mercantile system of accounting regularly employed ... Vishwnath Prasad (1969) 721TR194 (SC) that "It is for the assessee to prove that even if the cash credit represents income, it is income from a source, which has already been taxed". The assessee has already offered the sales for taxation hence the onus Page

ITO, Ward-20(2), New Delhi vs. Prem Power Construction Pvt. Ltd., New Delhi

In the result, the Appeal of the assessee

ITA 4965/DEL/2018[2013-14]Status: DisposedITAT Delhi19 Jul 2023AY 2013-14

Bench: Shri Shamim Yahya & Shri Yogesh Kumar U.S.I.T.A. No. 4965/Del/2018 (A.Y. 2013-14) Ito Prem Power Construction Pvt. Ltd. Vs. Ward-20(2) Khasra No. 261/1, Room No. 218, 2Nd Floor, C. Village Ghitorni, R. Building, New Delhi New Delhi Pan: Aabcp8750G ( Appellant ) ( Respondent )

For Appellant: Department by: Ms. Beenu, Sr. DRFor Respondent: Ms. Beenu, Sr. DR
Section 145(3)Section 44

accounting which reads as under:- Method of accounting. '145. (1) Income chargeable under the head "Profits and gains of business or profession" or "Income from other sources" shall, subject to the provisions of sub-section (2), be computed in accordance with either cash or mercantile system of accounting regularly employed

DCIT Central Circle Ajmer, Ajmer vs. Yashwant Kumar Sharma, Ajmer

In the result, the appeal of the revenue is dismissed and the cross

ITA 210/JPR/2023[2020-21]Status: DisposedITAT Jaipur19 Jul 2023AY 2020-21

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA No. 210/JP/2023 fu/kZkj.k o"kZ@Assessment Years : 2020-21 DCIT, Central Circle, Ajmer cuke Vs. Yashwant Kumar Sharma F-108, Industrial Area, Makhupura Parbatpura, Ajmer LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: ASWPS 3791 E vihykFkhZ@Appellant izR;FkhZ@Respondent vk;dj vihy la-@C.O. No. 04/JP/2023 (Arising out of ITA Nos. 210/JP/2023) fu/kZkj.k o"kZ@Assessment Years : 2020-21 Yashwant Kumar Sharma

For Appellant: Sh. C. M. Agarwal (CA)For Respondent: Sh. James Kurian (CIT) &
Section 139(1)Section 271ASection 274

210/JP/2023 & CO No. 04/JP/2023 DCIT, Ajmer vs. Yashwant Kumar Sharma the real estate itself would not reveal the nature of income and the source of income of the year under consideration. It is a pre-condition for invoking the provisions of section 271AAB that the assessee admitted the undisclosed income ... maintain regular books of accounts. In the computation of income, the assessee has shown income from Salary, income from house property and income from other sources. The returned income was accepted by the AO while framing the assessment under section 143(3) and hence assessee’s case does not fall

Allied Computers International (Asia) Ltd, Mumbai vs. DCIT CC-2(2), Mumbai

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

ITA 661/MUM/2023[2011-12]Status: DisposedITAT Mumbai18 Jul 2023AY 2011-12

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Shri Neeraj ManglaFor Respondent: Dr. Kishor Dhule
Section 143(3)Section 250Section 68

learned AR submitted that in the year under consideration, the amount of interest income was taken from Form 26AS and assessed as income from other sources. While in the assessment year 2012-13, the Assessing Officer (“AO”) took the amount of interest income from the profit and loss account ... loss account, the AO considered the business loss at Nil. Further, the AO taxed the interest income earned by the assessee as income from other sources. 9. The learned CIT(A), vide impugned order, dismissed the grounds raised by the assessee on this issue. Being aggrieved, the assessee

Mrs Sunita Shyam Malpani, Mumbai vs. Income Tax Officer, Ward 25(1)(3), Mumbai

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

ITA 344/MUM/2023[2010-2011]Status: DisposedITAT Mumbai18 Jul 2023AY 2010-2011

Bench: Shri Pavan Kumar Gadalesunita Shyam Malpani, Vs. Ito 25(1)(3), 701,Plot No.117, Room No.703, Karanapartment, Kautilyabhavan, Lokhandwalacomplex, Bandra Bkc, Andheri (W), Mumbai-400051. Mumbai-400053. "थायी लेखा सं./जीआइआर सं.Pan/Gir No.Acppm8552J (अपीलाथ"/Applicant) (""यथ"/Respondent)

Section 10Section 143Section 144ASection 148Section 250Section 68Section 69C

facts of the case that, the assessee is a individual and derives income from salary, income from business, income from capital gains and income from other sources. The assessee has filed the return of income for AY 2010-11 on 13th July, 2010 disclosing a total income of Rs.1 ... assessees who belong to H group, AO did not accept the capital gains and treated the entire sale proceeds of the shares as income from undisclosed sources under s. 68-Not justified-Fact that the assessees in the group have purchased and sold shares of the same companies through

Meenu Ajay Pathak, Mumbai vs. I.T.O.- 32(2)(3), Mumbai

In the result, the appeal by the assessee is dismissed

ITA 155/MUM/2023[2015-16]Status: DisposedITAT Mumbai18 Jul 2023AY 2015-16

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: Shri Jitendra SinghFor Respondent: Smt. Mahita Nair
Section 234ASection 250Section 68Section 69C

facts of the case as emanating from the record are: The assessee is an individual and during the year under consideration has shown income from other sources only in the form of interest. For the year under consideration, the assessee e-filed her return of income on 30/01/2016, declaring

Hubtown Ltd, Mum vs. DCIT, CC-2(4), Mum

In the result, appeal is partly allowed

ITA 3259/MUM/2022[2019-20]Status: DisposedITAT Mumbai18 Jul 2023AY 2019-20

Bench: Shri Vikas Awasthy () & Ms. Padmavathy S. ()

Section 132Section 153Section 153ASection 56(2)(x)Section 69C

therefore before proceeding further we will look at the relevant provisions of the said section – 7 ITA 3259/Mum/2022 Hubtown Limited Income from other sources. 56. (1) Income of every kind which is not to be excluded from the total income under this Act shall be chargeable to income-tax under ... head "Income from other sources", if it is not chargeable to income-tax under any of the heads specified in section 14, items A to E. (2) In particular, and without prejudice to the generality of the provisions of sub-section (1), the following incomes, shall be chargeable to income

DCIT, Central Circle -15, New Delhi vs. B.L.Kashyap & Sons Ltd, New Delhi

In the result, the appeal of the revenue and cross objection of assessee are allowed for statistical purposes

ITA 2622/DEL/2022[2019-20]Status: DisposedITAT Delhi18 Jul 2023AY 2019-20

Bench: Shri Chandra Mohan Garg & Dr. B.R.R. Kumarassessment Year: 2019-20 The Dcit, Centralcircle-15, New Delhi M/S. B.L. Kashyap & Sons Ltd., 409, 4Th Floor, Dlf Tower-A, Jasola, 110055 Vs. New Delhi 110025 Pan Aaacb 0205 F (Appellant) (Respondent) Co No. 174/Del/2022 In Ita No.2622/Del/2022 Assessment Year: 2019-20 M/S. B.L. Kashyap & Sons Ltd., The Dcit, Centralcircle-15, New Delhi 409, 4Th Floor, Dlf Tower-A, Jasola, 110055 New Delhi 110025 Vs. Pan Aaacb 0205 F (Appellant) (Respondent)

For Appellant: Shri Sourav Rohtagi, CA
Section 143(1)Section 2(24)(x)

instant case, has shown business income from the business of building construction and allied services and interest income under the head income from other sources. Therefore, in the backdrop of nature of work, the ld. AR contends that the salary in such business is often disbursed to the employees

Assistant Commissioner of Income Tax, (Central)-I, Raipur vs. Mesers Chhattisgarh Steel & Power Limited, Raipur

In the result, appeal of the revenue in ITA No

ITA 92/RPR/2020[2013-14]Status: DisposedITAT Raipur18 Jul 2023AY 2013-14

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं./Ita Nos.91 & 92/Rpr/2020 "नधा"रण वष" / Assessment Years : 2012-13 & 2013-14 The Assistant Commissioner Of Income Tax, Central Circle-1, Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Chhattisgarh Steel & Power Limited. 142, Sahid Smarak, G.E Road, Raipur (C.G.) Pan : Aaccc7479G ……""यथ" / Respondent

For Appellant: Ms. Puja Bajaj, CAFor Respondent: Shri Piyush Tripathi, Sr. DR
Section 143(2)Section 143(3)Section 14ASection 40

income is not chargeable to tax under the head “profits and gains of business or profession” it will be assessed under the head “income from other sources.” 27 M/s. Chhattisgarh Steel & Power Ltd.Vs. ACIT, Central Circle-1, Raipur ITA Nos. 91 & 92/RPR/2020 36. Significantly, the same Finance Act, 1987 also

Assistant Commissioner of Income Tax (Central)-I, Raipur vs. Mesers Chhattisgarh Steel & Power Limited, Raipur

In the result, appeal of the revenue in ITA No

ITA 91/RPR/2020[2012-13]Status: DisposedITAT Raipur18 Jul 2023AY 2012-13

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं./Ita Nos.91 & 92/Rpr/2020 "नधा"रण वष" / Assessment Years : 2012-13 & 2013-14 The Assistant Commissioner Of Income Tax, Central Circle-1, Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Chhattisgarh Steel & Power Limited. 142, Sahid Smarak, G.E Road, Raipur (C.G.) Pan : Aaccc7479G ……""यथ" / Respondent

For Appellant: Ms. Puja Bajaj, CAFor Respondent: Shri Piyush Tripathi, Sr. DR
Section 143(2)Section 143(3)Section 14ASection 40

income is not chargeable to tax under the head “profits and gains of business or profession” it will be assessed under the head “income from other sources.” 27 M/s. Chhattisgarh Steel & Power Ltd.Vs. ACIT, Central Circle-1, Raipur ITA Nos. 91 & 92/RPR/2020 36. Significantly, the same Finance Act, 1987 also

Shri Murlimanohar Ramkishan Mundhra, Surat vs. Income Tax Officer, Ward - 1(2)(1), Surat

In the result, ground No. 1 of the appeal is allowed

ITA 158/SRT/2023[2013-14]Status: DisposedITAT Surat18 Jul 2023AY 2013-14

Bench: Shri Pawan Singhआ.अ.सं./Ita No.158/Srt/2023 (Ay 2013-14) (Hearing In Physical Court) Murlimanohar Ramkishan Income Tax Officer, Ward-1(2)(1), (Old Ward- Mundhra, 301 To 308, Vs 1(2)(3) Surat, Aayakar Third Floor, Shree Krishna Market, Near Metro Tower, Bhavan, Majura Gate, Ring Road, Surat-395002 Surat-395001 Pan No: Aflpm 6057 P अपीलाथ"/Appellant ""यथ" /Respondent "नधा"रती क" ओर से /Assessee By Shri Sudhir Surana, Ca & Shri Om Prakash Soni, Ca राज"व क" ओर से /Revenue By Shri Vinod Kumar, Sr-Dr अपील पंजीकरण/Appeal Instituted On 03.03.2023 सुनवाई की तारीख/Date Of Hearing 03.05.2023 उ"घोषणा क" तार"ख/Date Of 18.07.2023 Pronouncement Order Under Section 254(1) Of Income Tax Act Per Pawan Singh: 1. This Appeal By Assessee Is Directed Against The Order Of National Faceless Appeal Centre, Delhi [For Short To As “Ld. Nfac/Ld.Cit(A)”] Dated 13.01.2023 For Assessment Year 2013-14, Which In Turn Arises From The Addition Made By The Assessing Officer In Assessment Order Passed Under Section 143(3) R.W.S 147 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Dated 30.11.2018. The Assessee Has Raised The Following Ground Of Appeal:- Murllimanohar R Mundhra “1. Ld. Cit(A) Erred In Law & On Facts Confirming The Reassessment Proceeding Initiated By The Ld. Ao, Without Properly Appreciating The Submission Of The Appellant.

Section 143(2)Section 143(3)Section 147Section 148Section 254(1)Section 57

Subsequently, the Assessing Officer on perusal of record found that assessee has shown interest received of Rs. 20,773/- under the head “income from other sources” against which, the amount of Rs.6,49,951/- was claimed as deduction on account of interest paid to other parties. The assessee has already ... Rs.15.42 lakhs in profit and loss account for loan borrowed for its business. Thus, interest amount of Rs.6,49,951/- claimed for “income from other sources” was not justified, hence, deduction was not 2 Murllimanohar R Mundhra justified. On the basis of such observation, the Assessing Officer