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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

The Satara Zilla Krishi Bank Karmachari Sahakari Patsanstha Ltd, Satara vs. ACIT, Satara, Cir-Satara

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

ITA 2156/PUN/2025[2020-21]Status: DisposedITAT Pune28 Nov 2025AY 2020-21

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.2155 & 2156/Pun/2025 निर्धारण वर्ष / Assessment Year : 2020-21 The Satara Zilla Krishi Bank Karmachari Sahakari Patsanstha Ltd., Ajinkya Complex, 512, Ch. Shivaji Road, Camp, Sadar Bazar, Satara-415001 Asst. Commissioner Of Income Tax, Satara Circle, Vs. Satara Pan: Aaaat1502B अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Department By : Date Of Hearing : Date Of Pronouncement : Ms. Renuka Arunrao Ghatge Shri S. Sadananda Singh 11-11-2025 28-11-2025 आदेश / Order Per Astha Chandra, Jm : The Above Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Both Dated 15.07.2025 Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi [“Cit(A)”/“Nfac"] Pertaining To Assessment Year (“Ay") 2020-21. For The Sake Of Convenience, Both These Appeals Were Heard Together & Are Being Disposed Of By This Common Order.

For Appellant: Department byFor Respondent: Date of hearing
Section 139(1)Section 143(2)Section 144Section 41(1)Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(b)Section 80P(2)(d)

providing credit facilities to its members. Hence, it is not the operational income of the society and is to be treated as Income from Other Sources. The Ld. A.O. has failed to appreciate that as per the Statement of Facts, the appellant has earned interest and dividend income of Rs.39 ... surplus funds deposited with cooperative Banks. Hence, it is not the operational income of the society, it is to be treated as income from other sources. Further, section 80(P)(2)(d) provides deduction in respect of any income by way of interest or dividends derived by the co-operative

The Satara Zilla Krishi Bank Karmachari Sahakari Patsanstha Ltd, Satara vs. ACIT, Satara, Cir-Satara

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

ITA 2155/PUN/2025[2020-21]Status: DisposedITAT Pune28 Nov 2025AY 2020-21

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.2155 & 2156/Pun/2025 निर्धारण वर्ष / Assessment Year : 2020-21 The Satara Zilla Krishi Bank Karmachari Sahakari Patsanstha Ltd., Ajinkya Complex, 512, Ch. Shivaji Road, Camp, Sadar Bazar, Satara-415001 Pan: Aaaat1502B अपीलार्थी / Appellant Assessee By : Department By : Date Of Hearing : Date Of Pronouncement : Asst. Commissioner Of Income Tax, Satara Circle, Vs. Satara प्रत्यर्थी / Respondent Ms. Renuka Arunrao Ghatge Shri S. Sadananda Singh 11-11-2025 28-11-2025 आदेश / Order Per Astha Chandra, Jm : The Above Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Both Dated 15.07.2025 Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi [“Cit(A)”/“Nfac"] Pertaining To Assessment Year (“Ay") 2020-21. For The Sake Of Convenience, Both These Appeals Were Heard Together & Are Being Disposed Of By This Common Order.

For Appellant: Department byFor Respondent: Date of hearing
Section 139(1)Section 143(2)Section 144Section 41(1)Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(b)Section 80P(2)(d)

providing credit facilities to its members. Hence, it is not the operational income of the society and is to be treated as Income from Other Sources. The Ld. A.O. has failed to appreciate that as per the Statement of Facts, the appellant has earned interest and dividend income of Rs.39 ... surplus funds deposited with cooperative Banks. Hence, it is not the operational income of the society, it is to be treated as income from other sources. Further, Section 80P(2)(d) provides deduction in respect of any income by way of interest or dividends derived by the co-operative society

Country Club Hospitality & Holidays Limited, Hyderabad vs. DCIT., Circle 1(1), Hyderabad

In the result, the appeal filed by the assessee company is allowed in terms of our aforesaid observations

ITA 891/HYD/2025[2021-22]Status: DisposedITAT Hyderabad26 Nov 2025AY 2021-22

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.891/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2021-22) Country Club Hospitality Vs. Deputy Commissioner & Holidays Limited, Of Income Tax, Hyderabad. Circle-1(1), Pan: Aaacc8276B Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 19/11/2025 घोषणा की तारीख/Date Of 26/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Order Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi (For Short, “Cit(A)”), Dated 22.04.2025, Which In Turn Arises From The Assessment Order Passed By The Ao Under Section 143(3) R.W.S. 144B Of The Income-Tax Act, 1961 (For Short, “Act”), Dated 26.12.2022 For Ay 2021-22. The Assessee Company

For Appellant: Shri P. Murali Mohan RaoFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 133(6)Section 143Section 143(3)Section 194HSection 250

declaring a business loss of Rs. 33,88,31,712/- and an income of Rs. 5,80,20,640/- under the head “Income from other sources”. Thereafter, the case of the assessee company was selected for scrutiny assessment under CASS on the issue of “Large payments made u/s 194H