“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

Ahmednagar Zilla Gramsevakanchi Sahakar Patsanstha Maryadit, Ahilyanagar vs. PCIT, Pune-1, Pune

In the result, the appeal of the assessee is allowed

ITA 1301/PUN/2025[2020-21]Status: DisposedITAT Pune25 Nov 2025AY 2020-21

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.1301/Pun/2025 निर्धारण वर्ष / Assessment Year : 2020-21 Ahmednagar Zilla Gramsevakanchi Sahakari Patsanstha Maryadit, 1, Opp. Sardar Patel Karyala, Behind Vs. Ketkar Hospital, Ahilyanagar-414001 The Pr. Cit, Pune-1 Pan : Aaaaa6582G अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Department By : Date Of Hearing : Date Of Pronouncement : Shri Prasad S Bhandari Shri Amol Khairnar 11-09-2025 25-11-2025 आदेश / Order Per Astha Chandra, Jm : The Appeal Filed By The Assessee Is Directed Against The Order Dated 22.03.2025 Of The Ld. Principal Commissioner Of Income Tax, Pune-1 (“Pcit)” Passed U/S 263 Of The Income Tax Act, 1961 (The “Act”) Pertaining To Assessment Year (“Ay”) 2020-21. 2. The Assessee Has Raised The Following Grounds Of Appeal : “1. On The Facts & In The Prevailing Circumstances Of The Case, Respected Pcit Pune -1 Erred Passing The Impugned Revision Order Under Section 263 Without Appreciating The Fact That Interest On The Deposits Made By A Co-Operative Society With The Co-For Operative Bank Is Eligible Deduction Under Section 80P Of The Act. Hence, The Impugned Order Under Section 263 May Please Be Squashed. 2. On The Facts & In The Prevailing Circumstances Of The Case, Respected Pcit Pune 1 Erred Passing The Impugned Revision Order Under Section 263 Without Appreciating The Submission Made By The Assessee Society & The Judgments Of Hon'Ble Jurisdictional Pune

For Appellant: Department byFor Respondent: Date of hearing

Section 143(2)Section 143(3)Section 263Section 56Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

order, the Ld. PCIT opined that income earned by the assessee from investments in co-operative banks would come in the category of 'Income from other sources' taxable u/s 56 and would not qualify for deduction as business income u/s 80P(2)(a)/(d) of the Act. The Ld. PCIT ... corporate (in this case, co-operative bank) from which such interest income is derived will not change the character of income, viz. the income from other sources, which is ineligible for deduction under section 80P(2)(d) of the Act. The definition of co-operative society as contained in Section

Azim Kassam Boblai, Mumbai vs. ITO Ward 41(1)(3), Mumbai

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

ITA 4391/MUM/2025[2016-17]Status: DisposedITAT Mumbai25 Nov 2025AY 2016-17

Bench: Hon’Ble Shri Sandeep Gosain & Azim Kassam Boblai Vs. Ito, Ward 41(1)(3), A/204, Roshni Mahal, Mumbai Mumbai Puna Road Thane, Kautilya Bhawan, C41- Diwa B.O, Nagaon, Thane, 43, Avenue 3, Near Mumbai- 400612 Videsh Bhavan, G Block Bkc, Gilban Area, Bandra Kurla Complex, Bandra East, Mumbai- 400051 Pan/Gir No. Aetpb414J (Applicant) (Respondent)

Section 139(1)Section 143(2)Section 148Section 250

without prejudice basis, the Ld. CIT(A) has erred in confirming the addition of 15,00,000 made under the head income from other sources which was representing the sale consideration of furniture being personal effects. 2. Ground No.1 raised by the assessee relates to challenging the order of assessment

Charanjeet Singh, Panipat vs. Income Tax Officer, Ward 1, Panipat

In the result, appeal of the assessee is allowed

ITA 6387/DEL/2025[2018-19]Status: DisposedITAT Delhi25 Nov 2025AY 2018-19

Bench: Shri Satbeer Singh Godaraassessment Year: 2018-19 Sh. Charanjeet Singh, Vs. Income Tax Officer, H. No. 115, Baholi, Ward-1, Panipat Refinery, Panipat Panipat, Haryana Pan: Ddaps7473H (Appellant) (Respondent) Assessee By Sh. Suresh Gupta, Ca Department By Sh. Manoj Kumar, Sr. Dr

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 263Section 28Section 56(2)(viii)Section 57

taxmann.com 301 (Del.) wherein the department has succeeded before their lordships that the impugned interest component ought to be assessed as income from “other” sources only. 4. I have given my thoughtful consideration to the assessee’s pleadings and Revenue’s foregoing vehement contention. It emerges that this tribunal ... capital receipt' forming part of enhanced compensation as envisaged in section 45(5) of the Act to 'revenue receipt' chargeable to tax as income from other sources. The view taken by the Ld. AO that interest under section 28 of Land Acquisition Act received by the assessee is exempt under

Baramati Taluka Sahakari Phalutpadam Sangh, Pune vs. ITO Ward-14(50, Pune

In the result, appeal of the Assessee is allowed for statistical purpose

ITA 2104/PUN/2025[2018-19]Status: DisposedITAT Pune24 Nov 2025AY 2018-19

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita Nos.2103 & 2104/Pun/2025 निर्धारण वषा / Assessment Year: 2018-19 Baramati Taluka V The Income Tax Officer, Sahakariphalutpadan Sangh, S Ward-14(5), Pune. At Pipmaliatpimpali Post Pimpali Taluka Baramati District Pune – 413102. Maharashtra. Pan: Aaatb5269Q Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod Shingte Revenue By Shri Arvind Renge – Addl.Cit(Virtual) Date Of Hearing 04/11/2025 Date Of Pronouncement 24/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2018-19 Dated 25.07.2025 & 07.08.2025 Respectively; Against The Order U/S.143(3) Dated 05.03.2021 & Penalty Order U/S.270A Of The Act, Dated 09.08.2021 Respectively.For The Sake Of Convenience

Section 143(3)Section 250Section 270ASection 80PSection 80P(2)(a)Section 80P(2)(d)

being income from SB account and income from FD respectively received from other co-operative banks, as income from other sources without realizing the fact that earning of interest income is integral part of business activity of appellant society and therefore, appellant has rightly claimed deduction under section

Baramati Taluka Sahakari Phalutpadam Sangh, Pune vs. ITO Ward-14(5), Pune

In the result, appeal of the Assessee is allowed for statistical purpose

ITA 2103/PUN/2025[2018-19]Status: DisposedITAT Pune24 Nov 2025AY 2018-19

Section 143(3)Section 250Section 270ASection 80PSection 80P(2)(a)Section 80P(2)(d)

Abdul Jaleel, Bangalore Karantaka vs. Income Tax Officer Ward 1(2)(1) Bangalore, Bangalore

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

ITA 585/BANG/2025[2015-16]Status: DisposedITAT Bangalore24 Nov 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2015-16

For Appellant: Sri Siddesh N Gaddi, A.RFor Respondent: Sri Balusamy N., D.R

Section 142(1)Section 143(2)Section 147Section 148Section 151Section 250Section 68Section 80T

brought to tax u/s 68 of the Act. Further, savings bank interest received amounting to Rs.76,297/- was added under the head “income from other sources” and the also deduction claimed under Chapter VIA u/s 80TTA of Act amounting to Rs.10,000/- was also not allowed to the assessee. Abdul ... assessee in his trading & profit & loss account. Further, we also direct the AO to treat the savings bank account interest as “income from other sources” and allow the deduction u/s 80TTA amounting to Rs.10,000/- as eligible to be claimed by the assessee. It is ordered accordingly

Kayum Razak Dhanani, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bengaluru

Appeal of the assessee is allowed

ITA 634/BANG/2024[2015-16]Status: DisposedITAT Bangalore24 Nov 2025AY 2015-16

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year: 2015-16

For Appellant: Shri V. Chandrashekar, AdvocateFor Respondent: Shri Shivanand Kalakeri, CIT(DR)(ITAT), Bengaluru

Section 127Section 132Section 139Section 143Section 143(3)Section 153ASection 56(2)(vii)

year 2015 – 16 on 25th of August 2015 at a total income of ₹ 27,343,010/–. The assessee derives income from business and income from other sources. Pursuant to the search the notification under section 127 of the act was passed on 15/5/2018 centralising the case of the assessee ... being the difference between the fair market value and consideration paid. He also agreed that on allotment of 22,52,124 shares the income from other sources in the hands of the assessee and his family Page 5 of 13 members arrive at ₹ 180,169,920 and he agreed

Kantar Analytics India Private Limited (Formerly Known As Firefly Market Reserch India Private Limited (Successor of Analytics Quotient Service India Private Limited), Mumbai vs. Assistant Commissioner of Income Tax, Circle 1(3)(1), Mumbai

In the result the appeal filed by the assessee stands allowed

ITA 4733/MUM/2024[2020-21]Status: DisposedITAT Mumbai24 Nov 2025AY 2020-21

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 143(3)Section 153Section 270ASection 92CSection 92C(1)

11/02/2021 declaring total income of Rs.21,09,48,186/- under the head income from business and Rs.3,14,14,990/- effort as income from other sources. The case of selected for scrutiny under CASS for verification of following issues: I. II. Imports International related party transaction and services III. Loss

Meenu, Govindpur, Allahabad vs. Income Tax Officer CPC (NFAC, Delhi)

Appeal stands dismissed in- limine on the ground of limitation

ITA 135/ALLD/2025[2017-18]Status: DisposedITAT Allahabad21 Nov 2025AY 2017-18

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2017-18 Meenu V. The Income Tax Officer Mig-23, Govindpur Cpc A-503, Satpushp Apartment Civil Lines, Allahabad Pan:Akfpm3770J (Appellant) (Respondent) Appellant By: Shri S. K. Yogeshwar, Advocate Respondent By: Shri A. K. Singh, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 09.02.2023, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2017-18. 2.0 The Brief Facts Of The Case Are That The Assessee Filed Her Return Of Income For The Year Under Consideration On 05.08.2017, Declaring A Total Income Of Rs.8,30,470/-. The Centralized Processing Centre (Cpc), Bangalore, Vide Intimation Under Section 143(1) Of The Income Tax Act, 1961 (Hereinafter Called “The Act’), Dated 26.03.2019 Assessed The Total Income Of The Assessee At Rs.16,12,650/-.

For Appellant: Shri S. K. Yogeshwar, AdvocateFor Respondent: Shri A. K. Singh, D.R

Section 143(1)Section 253(3)Section 253(5)

sustaining the addition of Rs.2,87,478/- out of the total addition of Rs.7,82,176/- made by the CPC under the head ‘income from other sources’. 2.2 Being further aggrieved, now the assessee has approached this Tribunal challenging the order of the NFAC, by raising the following grounds

Rameshbhai Popatbhai Dakhra Legal Heir of Popatbhai Virabhai Dakhra, Surat vs. ITO, Ward 2(3)(3), Surat

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

ITA 170/SRT/2025[NA]Status: DisposedITAT Surat21 Nov 2025

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.170/Srt/2025 Assessment Year: 2017-18 (Physical Hearing) Rameshbhai Popatbhai Dakhra Income Tax Officer Ward-2(3)(3), बनाम/ Legal Heir Of Popatbhai Surat, Aayakar Bhavan, Surat-395 Vs. Virabhai Dakhra 001 Plot No.17,Ganesh Row House, Nr. Shyamdham Temple, Sarthana, Jakatnaka, Surat- 395 006 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aknpd 3920 H (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Appellant By Shri Mehul Shah, Ca राज" की ओर से /Respondent By Shri Ajay Uke, Sr-Dr सुनवाई की तारीख/Date Of Hearing 01/09/2025 उद्घोषणा की तारीख/Date Of Pronouncement 21/11/2025

Section 143(2)Section 144Section 250Section 69A

erred in confirming the action of Assessing Office in making addition of Rs.14,97,000/- by considering the exempt agriculture income as income from other sources. 6. It is therefore prayed that the addition made by Assessing Officer and confirmed by the learned CIT(A) may please be deleted ... without incurring expenditure, therefore, the AO concluded that the assessee had claimed bogus agriculture income and accordingly, treated the bogus agriculture income as income from other sources u/s 56 of the Act and added to the total income of the assessee. Accordingly, AO finalized the order u/s.144

Ch Veerraju Co, Rajahmundry vs. DCIT, Circle-1, Rajahmundry

The appeal of the assessee is partly allowed in terms of our aforesaid observations

ITA 561/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam21 Nov 2025AY 2018-19

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.561/Viz/2025 (निर्धारण वर्ा/Assessment Year: 2018-19) Ch. Veerraju & Co, Vs. Deputy Commissioner Of Rajahmundry. Income Tax, Pan: Aacfc8959Q Circle-1, Rajahmundry. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Smt. A. Aruna, Advocate रधजस्‍व द्वधरध/Revenue By: Dr. Aparna Villuri, Sr. Ar सुिवधई की तधरीख/Date Of 18/11/2025 Hearing: घोर्णध की तधरीख/Date Of 21/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm : The Present Appeal Filed By The Assessee Firm Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 26/08/2025 Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 143(3) R.W.S143(3A) & 143(3B) Of The Income-Tax Act, 1961 (For Short, “The Act”), Dated 15/04/2021 For The Assessment Year 2018-19. The 2 Ch Veerraju & Co Vs. Dcit

For Appellant: Smt. A. Aruna, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 143(3)

justified in sustaining the addition of Rs. 22,67,968/- made by the Assessing Officer by treating the agricultural income as income from other sources.” 2. Succinctly stated, the assessee firm which is engaged in the business of quarry and crusher maintenance had e-filed its return of income ... assessee of having derived agricultural income and held the entire amount that it had disclosed under the said head as its income from other sources. 5. Aggrieved, the assessee firm carried the matter in appeal before the CIT(A) but without success. For the sake of clarity, the observations

Kuruvambalam Service Co Operative Bank Limited, Kuruvambalam vs. Income Tax Officer, National Faceless Assessment Centre, Delhi

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

ITA 816/COCH/2025[2020-21]Status: DisposedITAT Cochin21 Nov 2025AY 2020-21

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2020-21 Kuruvambalam Service Co-Op. Bank Ltd. .......... Appellant Chemmalassery, Malappuram 679328 [Pan: Aacak3292M] Vs. The Income Tax Officer, Tirur .......... Respondent Assessee By: ------- None ------- Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 06.11.2025 Date Of Pronouncement: 21.11.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 02.09.2025 For Assessment Year (Ay) 2020-21. 2. Brief Facts Of The Case Are That Appellant Is A Co-Operative Society Registered Under The Kerala State Co-Operative Societies Act, 1969. It Is Classified As A Primary Agricultural Credit Co-Operative Society. It Is Engaged In The Business Of Accepting Deposits From Members & Providing Credit Facilities To Members. The Appellant Filed The Return Of Income For Ay 2020-21 On 10.02.2021 Declaring Income Of Rs. 1,00,160/- After Claiming Deduction Of Rs. 37,89,750/-

For Appellant: ------- None -------For Respondent: Smt. Leena Lal, Sr. D.R

Section 143(3)Section 56Section 63Section 64Section 80P(2)(a)

While doing so, the AO made addition u/s. 56 of the Act of Rs. 17,00,000/- on account of income from other sources. 3. Being aggrieved, an appeal was filed before the CIT(A), who vide the impugned order confirmed the action of the AO. 4. Being aggrieved

Sourabh Sharma, Indore vs. National Faceless Assessment Centre Delhi, Delhi

The appeal of the assesse is allowed

ITA 342/IND/2025[2016-17]Status: DisposedITAT Indore21 Nov 2025AY 2016-17

Bench: Shri B.M. Biyani

Section 142(1)Section 144Section 147Section 148Section 148ASection 250Section 253

treated as business income was at Rs.7,46,35,926/-. The addition /variation in respect of issue of interest income under the head income from other sources was at Rs.87,666/-. That the aforesaid assessment order bears No. ITBA/AST/S/147/2023-24/1060544604(1) and that the same is dated 06.02.2024 which is hereinafter ... assessee is hereby show caused as to why the addition of Rs. 87,766/- be not made as your income from other sources besides initiation of penalty as per provisions of Income Tax, 1961. The assessee is again requested to furnish the complete reply/information in chronological order as called vide

Late Shri Ramanand Taparia Th/Lh Chandadevi Taparia, Indore vs. National Faceless Assessment Centreq, Delhi

ITA 262/IND/2025[2013-14]Status: DisposedITAT Indore21 Nov 2025AY 2013-14

Bench: Shri B.M. Biyani & Shri Paresh M Joshi

Section 142(1)Section 143(2)Section 147Section 148Section 250Section 253Section 271(1)(c)

assessee in response to the notice u/s 148 it is seen the assessee declared total income of Rs 2,71,730, and income from other sources is 203030. the income of the assessee is not sufficient enough to make such huge investment. Further the assessee has reflected proprietor's capital

Late Shri Ramanand Taparia Th/Lh Chanda Devi Taparia, Indore vs. National Faceless Assessment Centre, Delhi

ITA 261/IND/2025[2014-15]Status: DisposedITAT Indore21 Nov 2025AY 2014-15

Bench: Shri B.M. Biyani & Shri Paresh M Joshi

Section 142(1)Section 143(2)Section 147Section 148Section 250Section 253Section 271(1)(c)

Asst. Commissioner of Income Tax, Central Circle-2, Nashik vs. Madanlal Lalchand Jain, Nandurbar

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

ITA 1572/PUN/2025[2021-22]Status: DisposedITAT Pune21 Nov 2025AY 2021-22

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2021-22 Madanlal Lalchand Jain Acit, Central Circle-2, Vibhare Building, Nashik Near City Police Station, Vs. Hat Darwaja Station Road, Nandurbar – 425412 Pan: Abkpj3633K (Appellant) (Respondent) Assessment Year : 2021-22 Acit, Central Circle-2, Madanlal Lalchand Jain Nashik Vibhare Building, Vs. Near City Police Station, Hat Darwaja Station Road, Nandurbar – 425412 Pan: Abkpj3633K (Appellant) (Respondent) Co No.42/Pun/2025 Assessment Year : 2021-22 Madanlal Lalchand Jain Acit, Central Circle-2, Vibhare Building, Nashik Near City Police Station, Vs. Hat Darwaja Station Road, Nandurbar – 425412 Pan: Abkpj3633K (Appellant) (Respondent) Assessment Year : 2022-23 Madanlal Lalchand Jain Acit, Central Circle-2, Vibhare Building, Nashik Near City Police Station, Vs. Hat Darwaja Station Road, Nandurbar – 425412 Pan: Abkpj3633K (Appellant) (Respondent) : Shri Nikhil S Pathak Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 03-11-2025 Date Of Pronouncement : 21-11-2025 O R D E R Per Bench:

For Respondent: Shri Amol Khairnar, CIT-DR

Section 132Section 139(1)Section 142(1)Section 143(1)Section 143(2)Section 69B

assessee stated that it is his own income, the Assessing Officer has never said that it is not the assessee’s own income. Further, the source of income found by the Assessing Officer was out of the activity of sale of plots where capital gain and business income has been ... survey operation had declared an amount of Rs.2 crore as additional income which was offered in the return of income under the head ‘Income from other sources’. Further, the assessee has claimed current year loss of Rs.86,98,901/- and adjusted the same against the rental income of Rs.72

Madanlal Lalchand Jain, Nandurbar vs. ACIT Central Circle 2, Nashik

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

ITA 1404/PUN/2025[2022-23]Status: DisposedITAT Pune21 Nov 2025AY 2022-23

For Respondent: Shri Amol Khairnar, CIT-DR

Section 132Section 139(1)Section 142(1)Section 143(1)Section 143(2)Section 69B

Madanlal Lalchand Jain, Nandurbar vs. ACIT Central Circle 2, Nashik

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

ITA 1403/PUN/2025[2021-22]Status: DisposedITAT Pune21 Nov 2025AY 2021-22

For Respondent: Shri Amol Khairnar, CIT-DR

Section 132Section 139(1)Section 142(1)Section 143(1)Section 143(2)Section 69B

Shri Chatrapati Shivaji Vividoddeshagala Sahakari Sangha Niyamita Haliyal, Haliyal vs. Pr. Commissioner of Income Tax, Hubbali

ITA 1186/BANG/2025[2020-21]Status: DisposedITAT Bangalore21 Nov 2025AY 2020-21

Bench: Shri.Laxmi Prasad Sahu & Shri. Keshav Dubeyassessment Year : 2020-21 M/S. Shri Chatrapati Shivaji Vividoddeshagala Vs. Pcit, Sahakari Sangha Niyamita, Hubli. Near Mlc Office, Bus Stand Road, Haliyal – 581 329, Karnataka. Pan : Aajas 9684 G Appellant Respondent Assessee By : Shri. Vinay K Kulkarni, Ca Revenue By : Shri. Subramanian S, Jcit(Dr)(Itat), Bangalore. Date Of Hearing : 30.10.2025 Date Of Pronouncement : 21.11.2025

For Appellant: Shri. Vinay K Kulkarni, CAFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore

Section 139(1)Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

Sale Society Ltd., Vs. ITO reported in 322 ITR 283 (SC) that utilization of surplus funds / investments taxable are taxable under the head “income from other sources” and not under section 80P of the Act. Accordingly, show cause notice was issued to the assessee and in this regard assessee submitted

DCIT, Circle 3(1)(1), Bengaluru, Bmtc Building, Koramangala vs. Gtr Aluminium Private Limited, Bengaluru

In the result the appeal filed by the revenue is dismissed

ITA 165/BANG/2024[2015-16]Status: DisposedITAT Bangalore21 Nov 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2015-16

For Appellant: Sri Monish Sowkhar, A.RFor Respondent: Sri Balusamy N., D.R

Section 143(3)Section 250Section 253Section 263Section 56(2)(viib)

r.w.s. 263 of the Act dated 31.03.2022, thereby making an addition to the extent of Rs. 5,22,24,080/- as income from other sources as per the provisions of section 56(2)(viib) of the Act, wherein the AO held that the value at which the shares were issued ... Aluminium Pvt. Ltd., Bangalore Page 4 of 16 31.03.2022 preferred an appeal wherein the addition made of 5,22,24,080/- as income from other sources as per the provisions of section 56(2)(viib) of the Act, was contested before the ld. CIT(A)/NFAC