“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

ITO, Ward- 9(3), New Delhi vs. Fortune Land and Housing Pvt. Ltd., New Delhi

In the result, the appeal of the revenue is dismissed

ITA 3503/DEL/2018[2015-16]Status: DisposedITAT Delhi16 Jun 2023AY 2015-16

For Appellant: Shri Sahil Sharma, AdvFor Respondent: Ms. Maimun Alam, Sr. DR

allowed to assessee by assessing officer, resulting in total addition of Rs. 6,92.25,7491 under the head "income from other sources" in the hands of appellants Since the entire land rights were transfered by appellant to Orris Inftastructure Prt. Ltd (OIPL) and the compensation thereon was offered

DCIT, New Delhi vs. M/S. Gardenia Aims Developers Pvt. Ltd., Noida

In the result, appeal of the assessee is dismissed and appeal of the revenue is partly allowed for ground no

ITA 2623/DEL/2014[2011-12]Status: DisposedITAT Delhi16 Jun 2023AY 2011-12

Bench: Shri C.M. Garg & Dr. B. R. R. Kumargardenia Aims Developers Pvt. Ltd, Vs. Dcit, Plot No. Gh-1, Sector-46, Noida, Central Circle-7, Up-201301 New Delhi (Appellant) (Respondent) Pan: Aadcg5568K Dcit, Vs. Gardenia Aims Developers Pvt. Ltd, Central Circle-7, Plot No. Gh-1, Sector-46, Noida, New Delhi Up-201301 (Appellant) (Respondent) Pan: Aadcg5568K Assessee By : None Revenue By: Shri Kanav Bali, Sr. Dr Date Of Hearing 19/05/2023 Date Of Pronouncement 16/06/2023

For Appellant: NoneFor Respondent: Shri Kanav Bali, Sr. DR

Section 143(3)Section 69Section 69A

facts and circumstances of case and in law, the Commissioner of Income Tax (Appeal) erred in confirming the addition of Rs.38,78.388/- as income from other sources. On the facts and circumstances of case and in law, the addition of Rs.38,78,388/- made by the assessing officer is erroneous ... Apropos remaining effective sole ground No. 1 of assessee is with regard to confirming the addition of Rs. 38,78,388/- as income from other sources. 7. From the assessment order we note that the AO has made addition of Rs. 38,78,388/- on account of cash seized during

M/S. Gardenia Aims Developers Pvt. Ltd., Noida vs. DCIT, New Delhi

In the result, appeal of the assessee is dismissed and appeal of the revenue is partly allowed for ground no

ITA 2592/DEL/2014[2011-12]Status: DisposedITAT Delhi16 Jun 2023AY 2011-12

For Appellant: NoneFor Respondent: Shri Kanav Bali, Sr. DR

Section 143(3)Section 69Section 69A

Pushpagiri Medical Society, Thiruvalla vs. ACIT, Exemption Circle, Thiruvananthapura

In the result, the assessee’s appeal is allowed

ITA 599/COCH/2022[2018-2019]Status: DisposedITAT Cochin16 Jun 2023AY 2018-2019

Bench: Shri Sanjay Arora & Shri Aby T.Varkeypushpagiri Medical Society Asst. Cit Thiruvalla 689101 (Exemptions) Vs. Pan – Aaatp2418H Cochin

For Appellant: Shri Abraham K Thomas, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R

Section 10Section 12ASection 143(3)Section 144BSection 154Section 272B

assessment dated 13/4/2021, seeking, apart from deletion of the disallowance of revenue expenditure (rs. 178.49 cr.) and addition under the head of income from other sources (rs. 80.64 lacs), aggregating to Rs.179.30 cr., inadvertently made in the computation-sheet afore- referred, credit for TDS and tax collected at source

Shree Mangrol Vanik Dasha Shrimali Gnati Shapur Darwaja, Mangroal-362225 vs. The ITO (Exmption) Ward-2, Rajkot

In the result, the order passed by Ld

ITA 56/RJT/2023[2011-12]Status: HeardITAT Rajkot16 Jun 2023AY 2011-12

Bench: Ms. Annapurna Gupta (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

For Appellant: Shri G.R. Sanghavi, A.RFor Respondent: Shri K.L. Solanki, Sr. D.R

Section 11Section 12ASection 143(1)Section 143(1)(a)Section 250

Polytechnic College 122 taxmann.com 287 (Indore - Trib.), the ITAT held that where income of assessee charitable educational institution was brought to tax as 'income from other sources' for reason that assessee was not registered as charitable trust under section 12AA, all incidental expenditures laid out by assessee wholly or exclusively

Asst. Commissioner of Income Tax, Circle-1(1)(1), Surat vs. Bhikhabhai Keshubhai Dhameliya, Surat

In the result, appeal filed by the Revenue is dismissed

ITA 196/SRT/2022[2016-17]Status: DisposedITAT Surat16 Jun 2023AY 2016-17

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.196/Srt/2022 "नधा"रण वष"/Assessment Year: (2016-17) (Physical Hearing) The Acit, Circle-1(1)(1), Vs. Bhikhabhai Keshubhai Dhameliya, Surat. Jay Gangeshwar Society, Varachha, Dist – Surat, 395010. (Appellant) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaupd7552N Appellant By Shri Vinod Kumar, Sr. Dr Respondent By Shri Sapnesh Sheth, Ca 31/05/2023 Date Of Hearing Date Of Pronouncement 16/06/2023

Section 142(1)Section 143Section 143(2)Section 143(3)Section 56(2)(vii)

During the year under consideration, the assessee was a partner in partnership firm “M/s Keshav Diamond & M/s Somnath Enterprise” and income from other source. During the course of assessment proceedings, the assessee was requested to submit the copy of purchase deed of the properties purchased during the year under consideration ... value of the property determined by Stamp Valuation Authority by Rs.2,21,82,025/-, the same is required to be treated as income from other sources. In view of the above, as per share of assessee i.e. 67% of total difference of Rs.2,21,82,025/- an addition of Rs.1

Manojj Ganeshlal Bhatia, Surat vs. ACIT, Cir 1(3), Surat

In the result, appeal filed by the Revenue is dismissed

ITA 494/SRT/2019[2015-16]Status: DisposedITAT Surat16 Jun 2023AY 2015-16

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.494/Srt/2019 ("नधा"रणवष" / Assessment Years: (2015-16) (Virtual Court Hearing) Assistant Commissioner Of Manojj Ganeshlal Bhatia Income-Tax, Circle-1[3], Room B-703, Opera House Building, Vs. 3Rd No.301, Floor, Anavil Nr. Agarsen Bhavan, City Light Business Centre, Adajan-Hazira Road, Surat-395007 Road, Adajan, Surat-395007 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacpb 9748 E (अपीलाथ" /Assessee) (""थ" /Respondent) िनधा"रती की ओर से /Assessee By : Shri Mehul K.Patel, Advocate राज" की ओर से/Revenue By : Shri Ashok B. Koli, Cit-Dr सुनवाई क" तार"ख/ Date Of Hearing : 21/03/2023 घोषणा क" तार"ख/Date Of Pronouncement : 16/06/2023 आदेश / O R D E R Per Dr. A. L. Saini: Captioned Appeal Filed By The Revenue, Pertaining To Assessment Year (Ay) 2015-16, Is Directed Against The Order Passed By The Learned Commissioner Of Income-Tax (Appeals)-2, Surat [Ld. Cit(A) For Short] Dated 28.08.2019 Which In Turn Arises Out Of An Assessment Order Passed By Assessing Officer Under Section 143(3) Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”] Dated 29.12.2017. 2. Grounds Of Appeal Raised By The Revenue Are As Follows: “1) Whether On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Is Justified In Deleting The Addition Of Rs.3,97,77,965/- Made On Account Of Profit From Future & Options Ignoring That Assessee Has Failed To Tender Evidence & Explanation In This Regard? 2) Whether On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Is Justified In Deleting The Addition Of Rs.5,60,54,528/- Made On Account Of Unexplained Increase In Capital Holding That The Capital Accumulation Is Fully Explained On The Basis Of Capital In The Itr Of A.Y 2011-12 & Accumulated Income In The Roi For A.Y 2012-13 To A.Y 2014-15 Ignoring That Assessee Has Shown Nil Capital Balance In Itr Filed For A.Y 2014-15?

For Appellant: Shri Mehul K.Patel, AdvocateFor Respondent: Shri Ashok B. Koli, CIT-DR

Section 143(2)Section 143(3)

future and options and profit from its partnership firm. The assessee also shown income from short term capital gain on listed securities and income from other sources comprising interest and dividend income. 5. During the assessment proceedings, the assessing officer observed that there is difference in profit earned from future

Gautam Dhan Co-Op. Housing Society Ltd., Mumbai vs. ITO Ward 34(2)(1), Mumbai

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

ITA 997/MUM/2023[2019-20]Status: DisposedITAT Mumbai15 Jun 2023AY 2019-20

Bench: Shri Pavan Kumar Gadalegautam Dhan Co-Op Ito, Ward 34(2)(1), Housing Society Ltd., 815, Kautilya Bhavan बनाम/ 368, Bajaj Road, Bkc,Bandra (E), Vs. Vile Parle (W), Mumbai- 400051. Mumbai- 400056. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaabg0540K (""थ" / Respondent) (अपीलाथ" /Appellant)

For Appellant: Mr. Manan Mathuria.ARFor Respondent: Ms. Kavita Kaushik.DR

Section 143(1)Section 250Section 80PSection 80P(2)(d)

referred in the Sec. 80P(2)(d) of the Act and therefore the interest income from cooperative banks has to be taxed under income from other sources and assessed the total income of Rs.2,79,060/- Further the assessee has filed the rectification petition U/sec

Shiraz Co-Operative Housing Society Ltd, Mumbai vs. DCIT/ACIT, CPC, Bangalore

In the result, appeal filed by the assessee is allowed

ITA 820/MUM/2023[2020-21]Status: DisposedITAT Mumbai15 Jun 2023AY 2020-21

Bench: Shri Pavan Kumar Gadale, Hon’Ble & Shri S. Rifaur Rahman, Hon'Bleshiraz Co-Operative Housing V. Dcit/Acit, Cpc, Bangalore Society Ltd Kautilya Bhavan Plot No. 9/10, Shiraz Chs Mumbai- 400051 Telli Galli, Andheri (East) Mumbai- 400069 Pan: Aabas5242A (Appellant) (Respondent) Assessee Represented By : Shri. Bhupendra Shah Department Represented By : Ms. Deepika Arora

Section 143(3)Section 154Section 234ASection 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

Ld.AO erred in not granting deduction u/s 80P(2)(d) amounting to Rs. 1,81,728/- by way of income from other sources in respect of interest earned on fixed deposit with Co-operative bank. 2. In the facts and circumstances of the case

Shree Krishna Educational Society, Visakhapatnam vs. Income Tax Officer, Exemption Ward, Visakhapatnam

In the result, appeal of the assessee is allowed

ITA 91/VIZ/2023[2018-19]Status: DisposedITAT Visakhapatnam15 Jun 2023AY 2018-19

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri G.V.N. Hari, ARFor Respondent: Sri Sankar Pandi, Sr. AR

Section 10Section 143(1)Section 143(3)Section 271BSection 44A

15/07/2021 was also issued and served on the assessee. In response, the assessee submitted that the Ld. AO has assessed the income under ‘income from other sources’ during the scrutiny assessment proceedings and hence it is not required to be audited U/s. 44AB of the Act. After carefully considering ... 271B of the Act. 5. At the outset, the Ld. AR argued that the assessee filed its return of income declaring it as income from other sources. The CPC while processing the return U/s. 143(1) of the Act has also considered the income of the assessee as income from

Chhattisgarh State Power Generation Co. Ltd., Raipur vs. Dy. Commissioner of Income Tax-1(1), Raipur

In the result, the appeal of the assessee in ITA No

ITA 24/RPR/2022[2018-19]Status: DisposedITAT Raipur15 Jun 2023AY 2018-19

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.16/Rpr/2017 "नधा"रण वष" / Assessment Year : 2009-10 Chhattisgarh State Power Generation Company Ltd. O/O. Executive Director-Finance Ground Floor, Vidyut Seva Bhawan, Daganiya, Raipur-492 001 (C.G.) Pan : Aadcc5772F .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax, Circle-1(2), Raipur (C.G.) ……""यथ" / Respondent आयकर अपील सं. / Ita No.24/Rpr/2022 "नधा"रण वष" / Assessment Year : 2018-19 Chhattisgarh State Power Generation Company Ltd. Ground Floor, Vidyut Seva Bhawan, Daganiya, Raipur-492 001 (C.G.) Pan : Aadcc5772F .......अपीलाथ" / Appellant बनाम / V/S.

For Appellant: Shri R.B Doshi, CAFor Respondent: Shri V.K Singh, CIT-DR

Section 143(2)Section 143(3)Section 32

head "Profits & gains of business or profession" in spite of the fact that said income was already offered for taxation under the head "Income from other sources" while filing revised return of income for the year under consideration. 5). On the facts and in the circumstances of the case ... 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.” 36. Significantly, the same Finance Act, 1987 also introduced provisos to Section 43B, through amendment (clause 10 of the Finance Bill). The memorandum

The Chhattisgarh State Power Generation Company Limited, Raipur, Raipur (Cg) vs. The Asstt. Commissioner of Income Tax 1(2), Raipur, Raipur (Cg)

In the result, the appeal of the assessee in ITA No

ITA 16/BIL/2017[2009-10]Status: DisposedITAT Raipur15 Jun 2023AY 2009-10

For Appellant: Shri R.B Doshi, CAFor Respondent: Shri V.K Singh, CIT-DR

Section 143(2)Section 143(3)Section 32

Gopal Singh S/O Devi Singh, Baran vs. Income Tax Officer, Ward, Baran

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

ITA 252/JPR/2023[2011-12]Status: DisposedITAT Jaipur15 Jun 2023AY 2011-12

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: NoneFor Respondent: Smt. Monisha Choudhary (Addl.CIT)

Section 144Section 147Section 148Section 250

Income Tax (Appeals) has erred in confirming the action of assessing officer in making addition of Rs. 9,00,000/- as Undisclosed Income from Other sources. 5. The appellant craves leave to add, amend, alter vary and/or withdraw any or all the above grounds of appeal. 2. None appeared

Manish Bachubhai Dani, Mumbai vs. National Faceless Appeal Centre, Mumbai

In the result, the appeal filed by the assessee is allowed and the appeal filed by the revenue is dismissed

ITA 873/MUM/2023[20122-13]Status: DisposedITAT Mumbai14 Jun 2023

Bench: Shri Pavan Kumar Gadale & Shri S Rifaur Rahmanmanish Bachubai Dani Nfac, No-245-A, 702, Prakash Tower, North Block, बनाम/ Opp Raja Hotel, New Delhi, Vs. Shankarrao Chowk, Delhi-110001. Kalyan(W)- 421301, Maharashtra. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabhm0031L (""थ" / Respondent) (अपीलाथ" /Appellant) Ito, Ward 3(2), Manish Bachubai 2Ndfloor,Ranimansion, Dani बनाम/ Murbad Road, 702, Prakash Tower, Vs. Kalyan(W)-421301, Opp Raja Hotel, Maharashtra. Shankarrao Chowk, Kalyan(W)- 421301, Maharashtra "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabhm0031L (""थ" / Respondent) (अपीलाथ" /Appellant)

For Appellant: Ms. Kavita Kaushik.DRFor Respondent: Mr. Ajay Singh.AR

Section 143(1)Section 143(2)Section 143(3)Section 148Section 69A

sales. The Ld. AR has referred to statement of income at page 2 of the paper book where the assessee has disclosed under Income from other sources i.e other income from of business of Iron scrap of Rs.1,94,800/-.The contentions of the Ld. AR that, the assessee

Barclays Merchant Bank ( Singapore ) Ltd., Mumbai vs. CIT (International Circle) Range-1, Mumbai

In the result, the appeal of the assesse stand dismissed

ITA 907/MUM/2021[2014-15]Status: DisposedITAT Mumbai14 Jun 2023AY 2014-15

For Appellant: Madhur AgarwalFor Respondent: Rajesh Meshram

Section 143(3)Section 263

India as per the treaty with Singapore. However, The ld. CIT(A) was of the view that transactions in foreign exchange contracts were income from other sources and not capital gains as per Article 23 of the Indo-Singapore DTAA. The ld. CIT further stated that A.O has accepted ... treaty with Singapore. It may be brought to your notice that the gains made through transaction in foreign exchange contracts is income from other sources and not capital gains as per Article 23 of the Indo Singapore DTAA. However, the Assessing Officer has accepted the same as short term capital

Estate of Late Shri.Davendra Chtandas Ahuja(Through Mrs. Tania Deol, the Legal Representative of the Estat/Will), Mumbai vs. Income Tax Officer-17(1)(3), Mumbai

In the result, the appeal of the assessee stands dismissed

ITA 2011/MUM/2018[2004-05]Status: DisposedITAT Mumbai14 Jun 2023AY 2004-05

Bench: Shri Aby T. Varkey, Jm & Shri S. Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No.2011/Mum/2018 (निर्धारण वर्ा / Assessment Years: 2004-05) Estate Of Late Shri बिधम/ Ito, Ward-17(1)(3) Davendra Chetandas Ahuja Room No. 116, 1St Floor, Vs. (Through Mrs. Tania Deol, Aayakar Bhavan, The Legal Representative Of Mumbai-400020. The Estate/Will) 502, Raheja Chambers, Nariman Point, Mumbai- 400021. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaapa8072C (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: None Revenue By: Smt. Riddhi Mishra (Dr) सुनवाई की तारीख / Date Of Hearing: 29/05/2023 घोषणा की तारीख /Date Of Pronouncement: 14/06/2023 आदेश / O R D E R Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Assessee Against The Order Of The Ld. Cit(A)-28, Mumbai Dated 06.12.2017 For The Ay 2004-05. 2. At The Outset, The Ld. Cit-Dr Brought To Our Notice That Despite This Appeal Being Fixed Several Times For Hearing, The Assessee/Ld. Ar Does Not Appear, Therefore, The Appeal May Be Heard & Disposed Off Ex-Parte Qua Assessee. 3. We Have Heard The Ld. Cit-Dr & Perused The Material On Records. We Note That The Appeal Has Been Fixed For Hearing Twenty (20) Times & Non-Appeared For The Assessee After 29.12.2022. We Note That The Assessee Has Raised Legal Issue Challenging The Reopening Of The Assessment. We Note That The Ao Has Given The Reason For Reopening Which Reads As Under: -

For Appellant: NoneFor Respondent: Smt. Riddhi Mishra (DR)

Section 147Section 148Section 68

assessee. Accordingly, an addition of Rs. 43,35,30,427/- is made to the total income of the assessee under the head Income from Other Sources.” 6. The Ld. CIT(A) has confirmed the addition made by AO at page one hundred and twenty four (124) of his order

Shri Raman Gupta, Amritsar vs. Deputy Commissioner of Income Tax Central Circle, Amritsar

In the result, the appeals of the assessee bearing ITA No

ITA 66/ASR/2023[2019-20]Status: DisposedITAT Amritsar14 Jun 2023AY 2019-20

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 115BSection 133Section 139Section 143Section 143(3)Section 250Section 44ASection 69

Expenditure incurred Rs.13,31,900/- Rs. 49,89,638/- TOTAL During assessment proceeding the ld. AO treated the surrendered income as income from other sources and addition was framed u/s 69 of the Act. Accordingly, the tax was calculated under the special rate u/s 115BBE of the Act. The assessee ... assessment order is reproduced as below: “3.4 It is observed that assessee has shown surrender amount of Rs.49,89,638/- under the head “ Income from other sources” as any other income. Thus, evidently, source of investment cash, purchase of stock and investment in construction of house neither claimed nor proved

Shri Rakesh Kumar, Amritsar vs. Deputy Commissioner of Income Tax Central Circle, Amritsar

In the result, the appeals of the assessee bearing ITA No

ITA 65/ASR/2023[2019-20]Status: DisposedITAT Amritsar14 Jun 2023AY 2019-20

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 115BSection 133Section 139Section 143Section 143(3)Section 250Section 44ASection 69

ACIT, Circle-10(1), New Delhi vs. Hydrabad Distilleries & Wineries P.Ltd, New Delhi

ITA 1289/DEL/2022[2017-18]Status: DisposedITAT Delhi14 Jun 2023AY 2017-18

Bench: Sh. Anil Chaturvedi & Sh. Anubhav Sharmaita No.6122/Del/2019 (Assessment Year : 2016-17) Dcit, Vs. M/S. Hyderabad Distilleries & Central Circle-4, Wineries Pvt. Ltd. 4Th Floor, Bhandari House, New Delhi 91, Nehru Place, Newdelhi Pan : Aaach2679B (Appellant) (Respondent) Acit, Vs. M/S. Hyderabad Distilleries & Central Circle-10(1), Wineries Pvt. Ltd. 4Th Floor, Bhandari House, New Delhi 91, Nehru Place, Newdelhi Pan : Aaach2679B (Appellant) (Respondent)

Section 143(3)

IMFL products paying royalty to JIL. 3. Ld. AO considered the lease rent and packaging charges derived under agreements with JIL to be income from other sources and not business income of the appellant. Further on aforesaid consideration of income form lease and packaging, certain expenses were disallowed on proportionate

DCIT, Central Circle-4, New Delhi vs. Hyderabad Distilleries and Wineries Pvt. Ltd., New Delhi

ITA 6122/DEL/2019[2016-17]Status: DisposedITAT Delhi14 Jun 2023AY 2016-17

Section 143(3)