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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

Shri Brahmanath Credit Souhard Sahakari Sangh Niyamit, Nippani vs. ITO 1 Nippani, Nippani

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

ITA 66/PAN/2026[2013-14]Status: DisposedITAT Panaji10 Mar 2026AY 2013-14

Bench: Shri Pavan Kumar Gadalei T A. Nos.66/Pan/2026 (A.Y. 2013-14 ) Shri Brahmanath Credit Vs I.T.O-Ward-1, Souhard Sahakari Sangh Nemchand Building, . Niyamat, 747,Ashoknagar, 185/C, Chikodi Road, Nippani-591237, Nippani, Karnataka. Belagavi-591237, Karnataka. Pan .No. Aaaas1063Q (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.U.G.Ammangi.Ar Revenue By Smt.Rijula Uniyal.Sr.Dr सुनवाई की तारीख/Date Of Hearing 09.03.2026 घोषणा की तारीख/Date Of Pronouncement 10.03.2026 Order Per Pavan Kumar Gadale, Jm: The Appeal Is Filed By The Assesse Against The Order Of Nfac/Cit(A) U/Sec 250 Of The Act. The Assessee Has Raised The Grounds Of Appeal Challenging The Order Of The Cit(A) Sustaining The Denial Of Deduction Of Interest Income From Cooperative Society, Cooperative Banks & Nationalized Banks U/Sec80P(2)(D) Of The Act. 2. The Brief Facts Of The Case Are That, The Assessee Is A Cooperative Credit Society & Is Engaged In Activities Of Providing Credit Facilities To Its Members. The Assessee Has Filed The Return Of Income For The A.Y 2013-14 On 2 Ita. No..66/Pan/2026 Shri Brahmanath Credit Souhard Sahakari Sangh Niyamit. 30.09.2013 Disclosing A Total Income Of Rs.Nil After Claiming Deduction Of Rs.78,06,780/- U/Sec 80P(2)(A)(I) Of The Act. Subsequently The Case Was Selected For Scrutiny Under Cass & Order U/Sec143(3) Of The Act Was Passed Disallowing The Claim U/Sec80P(2)(A)(I) Of The Act Of Rs.78,06,780/- & Disallowance U/Sec40(A)(Ia) Of The Act Of Rs.76,274/- & Assessed The Total Income Of Rs.78,83,054/- Vide Order Dated21.07.2021.Aggrived By The Order, On Appeal To The Cit(A), The Appeal Was Partly Allowed & The Assessee Has Preferred Second Appeal Before The Honble Tribunal & Vide By Order

Section 80PSection 80P(2)(a)Section 80P(2)(d)

investment in non-SLR securities need to be disallowed u/s 57(i) of the Act as interest on non-SLR securities is income from other sources." 2. Clause (id) of sub-section (1) of Section 56 of the Act provides that income by way of interest on securities shall ... chargeable to income tax under the head "Income from Other Sources", if, the income is not chargeable to income-tax under the head "Profits and Gains of Business and Profession". 3. The matter has been examined in light of the judicial decisions on this issue. In the case

Rajendrakumar Ichubhai Kothari, Bharuch vs. ITO, Ward-1(1), Bharuch

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

ITA 836/SRT/2025[2013-14]Status: DisposedITAT Surat09 Mar 2026AY 2013-14

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita Nos.835/Srt/2025 आयकर अपील सं /Ita Nos.836/Srt/2025 िनधा"रण वष" /Assessment Year : 2013-14 Rajendrakumar Ichubhai The Ito बनाम/ Kothari Ward-1(4) V/S. 2 119 Parkhetiafaliyu Kervada Bharuch – 356 069 Amod Bharuch Bharuch – 392 025 "थायी लेखा सं./Pan: Cfupk 6177 B (अपीलाथ(/ Appellant) (!) यथ(/ Respondent) Assessee By : Shri Surendra Modiani, Ca Revenue By : Shri Ajay Uke, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 10/12/2025 घोषणा की तारीख /Date Of Pronouncement: 09/03/2026 आदेश/O R D E R Per Sanjay Garg: The Present Two Appeals Have Been Preferred By The Assessee Against The Separate Orders Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 11/06/2025 (Quantum Appeal) & 12/06/2025 (Penalty Appeal) Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Years (Ays) 2013-14. Ita Nos.835 & 836/Srt/2025 Rajendrakumar Ichubhai Kothari Vs. Ito Asst. Year : 2013-14

For Appellant: Shri Surendra Modiani, CAFor Respondent: Shri Ajay Uke, Sr.DR
Section 139Section 147Section 148Section 250Section 271(1)(c)Section 56

income pertained to the assessee only. He, accordingly, treated the entire interest income to the tune of Rs.22,43,934/- as assessee's income from other sources u/s 56 of the Act and added back the same to the income of the assessee. He also initiated penalty proceedings ... viii) of the Act which refers to income way of interest received on compensation or on enhanced compensation to be treated as income from other sources and further as per the provisions of section 57(iv) of the Act which states that in case of income of the nature referred

Rajendrakumar Ichubhai Kothari, Bharuch vs. ITO, Ward-1(1), Bharuch

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

ITA 835/SRT/2025[2013-14]Status: DisposedITAT Surat09 Mar 2026AY 2013-14

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita Nos.835/Srt/2025 आयकर अपील सं /Ita Nos.836/Srt/2025 िनधा"रण वष" /Assessment Year : 2013-14 Rajendrakumar Ichubhai The Ito बनाम/ Kothari Ward-1(4) V/S. 2 119 Parkhetiafaliyu Kervada Bharuch – 356 069 Amod Bharuch Bharuch – 392 025 "थायी लेखा सं./Pan: Cfupk 6177 B (अपीलाथ(/ Appellant) (!) यथ(/ Respondent) Assessee By : Shri Surendra Modiani, Ca Revenue By : Shri Ajay Uke, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 10/12/2025 घोषणा की तारीख /Date Of Pronouncement: 09/03/2026 आदेश/O R D E R Per Sanjay Garg: The Present Two Appeals Have Been Preferred By The Assessee Against The Separate Orders Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 11/06/2025 (Quantum Appeal) & 12/06/2025 (Penalty Appeal) Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Years (Ays) 2013-14. Ita Nos.835 & 836/Srt/2025 Rajendrakumar Ichubhai Kothari Vs. Ito Asst. Year : 2013-14

For Appellant: Shri Surendra Modiani, CAFor Respondent: Shri Ajay Uke, Sr.DR
Section 139Section 147Section 148Section 250Section 271(1)(c)Section 56

income pertained to the assessee only. He, accordingly, treated the entire interest income to the tune of Rs.22,43,934/- as assessee's income from other sources u/s 56 of the Act and added back the same to the income of the assessee. He also initiated penalty proceedings ... viii) of the Act which refers to income way of interest received on compensation or on enhanced compensation to be treated as income from other sources and further as per the provisions of section 57(iv) of the Act which states that in case of income of the nature referred

Assistant Commissioner of Income Tax (Internation Taxation) Vadodara, Vadodara vs. Ahmed Mahomed Pandor, Bharuch

ITA 1667/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad09 Mar 2026AY 2016-17

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha1.आयकर अपील सं /Ita No.1667/Ahd/2025 – By Revenue 2.आयकर अपील सं /Ita No.1602/Ahd/2025 – By Assessee (िनधा"रण वष" /Assessment Year : 2016-17) 1. The Acit 1. Ahmed Mahomed बनाम (Internation Taxation) Pandor / Vadodara – 390 007 Moti Masjid Falia V/S. Jitali Ankleshwar Bharuch – 393 001 2. Ahmed Mahomed 2. The Acit Circle Pandor Int. Txn, Ankleshwar Vadodara – 390 007 Bharuch – 393 001 "थायी लेखा सं./Pan: Cwupp 2469 N (अपीलाथ(/ Appellant) (") यथ(/ Respondent) Assessee By : Shri Rasesh Shah, Ar Revenue By : Shri Sher Singh, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 10/12/2025 घोषणा की तारीख /Date Of Pronouncement: 09/03/2026 आदेश/O R D E R Per Sanjay Garg: The Present Are Cross-Appeals One By The Revenue & The Other By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 06/06/2025 Passed U/S.250 Of The Income Tax

For Appellant: Shri Rasesh Shah, ARFor Respondent: Shri Sher Singh, CIT-DR
Section 147Section 148Section 2(14)Section 2(14)(iii)Section 250

issued. In response, the assessee filed return of income, wherein he had shown total income of Rs. 6,88,630/- as income from other sources. Assessee did not show any capital gains income earned on the sale of the aforesaid immovable property. The assessee claimed before the AO that ... assessee and made the impugned addition of Rs.8,75,97,656/- into the income of the assessee apart from assessing the income from other sources as declared by the assessee in the return filed in response to notice u/s 148 of the Act. In appeal, the Ld. CIT(A) deleted

Ahmed Mahomed Pandor, Bharuch vs. ACIT, Circle Int.Txn., Vadodara, Baroda

ITA 1602/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad09 Mar 2026AY 2016-17

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha1.आयकर अपील सं /Ita No.1667/Ahd/2025 – By Revenue 2.आयकर अपील सं /Ita No.1602/Ahd/2025 – By Assessee (िनधा"रण वष" /Assessment Year : 2016-17) 1. The Acit 1. Ahmed Mahomed बनाम (Internation Taxation) Pandor / Vadodara – 390 007 Moti Masjid Falia V/S. Jitali Ankleshwar Bharuch – 393 001 2. Ahmed Mahomed 2. The Acit Circle Pandor Int. Txn, Ankleshwar Vadodara – 390 007 Bharuch – 393 001 "थायी लेखा सं./Pan: Cwupp 2469 N (अपीलाथ(/ Appellant) (") यथ(/ Respondent) Assessee By : Shri Rasesh Shah, Ar Revenue By : Shri Sher Singh, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 10/12/2025 घोषणा की तारीख /Date Of Pronouncement: 09/03/2026 आदेश/O R D E R Per Sanjay Garg: The Present Are Cross-Appeals One By The Revenue & The Other By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 06/06/2025 Passed U/S.250 Of The Income Tax

For Appellant: Shri Rasesh Shah, ARFor Respondent: Shri Sher Singh, CIT-DR
Section 147Section 148Section 2(14)Section 2(14)(iii)Section 250

issued. In response, the assessee filed return of income, wherein he had shown total income of Rs. 6,88,630/- as income from other sources. Assessee did not show any capital gains income earned on the sale of the aforesaid immovable property. The assessee claimed before the AO that ... assessee and made the impugned addition of Rs.8,75,97,656/- into the income of the assessee apart from assessing the income from other sources as declared by the assessee in the return filed in response to notice u/s 148 of the Act. In appeal, the Ld. CIT(A) deleted