“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

Jayshree Chandrasingh Kabali, Mumbai vs. DCIT Circle 27 (1), Mumbai

In the result, both the stay petitions of the assessee are dismissed and both the appeals are allowed for statistical purposes

ITA 7226/MUM/2025[2017-18]Status: DisposedITAT Mumbai21 Nov 2025AY 2017-18

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawal

For Appellant: Shri Mehul Shah, CAFor Respondent: Shri Annavaram K., Sr. DR

Section 142(1)Section 143(3)Section 144Section 147Section 148Section 271ASection 69

record and gone through the orders of the authorities below. Brief facts of the case are that assessee is a senior citizen earning income from other sources. She filed her return of income on 13.03.2018 reporting total income at Rs.57,99,540/- which was selected for limited scrutiny under CASS

Jayshree Chandrasingh Kabali, Mumbai vs. DCIT Circle 27 (1), Mumbai

In the result, both the stay petitions of the assessee are dismissed and both the appeals are allowed for statistical purposes

ITA 7225/MUM/2025[2017-18]Status: DisposedITAT Mumbai21 Nov 2025AY 2017-18

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawal

For Appellant: Shri Mehul Shah, CAFor Respondent: Shri Annavaram K., Sr. DR

Section 142(1)Section 143(3)Section 144Section 147Section 148Section 271ASection 69

M/S. D.S Enterprises, Mumbai vs. DCIT, Circle 22(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 4778/MUM/2025[2023-24]Status: DisposedITAT Mumbai21 Nov 2025AY 2023-24

Bench: Smt. Beena Pillai & Smt.Renu Jauhri7 (A.Y.2023-24)

For Appellant: Ms Dinkle Hariya & Ms SrutiFor Respondent: Shri Annaravan Kosuri- Sr. AR

Section 143(3)Section 250Section 40

paid to the partners in accordance with the provisions of section 40(b) of the Act and taxing this amount under the head 'Income from Other Sources'. 3.2 While doing so, the CIT (A) erred in: (i) Basing his action on surmises, suspicion and conjecture; (ii) Taking into account irrelevant

Sukhsagar Co Operative Credit Society Ltd, Mumbai vs. Income Tax Officer Ward 32(1)(1), Mumbai

ITA 4336/MUM/2025[2018-19]Status: DisposedITAT Mumbai21 Nov 2025AY 2018-19

Bench: Shri Narender Kumar Choudhry

For Appellant: Shri Kumar Kale, Ld. A.RFor Respondent: Shri Vikas Chandra, Ld. Sr. D.R

Section 147Section 250Section 56Section 80PSection 80P(1)Section 80P(2)(d)

income declaring total income at Rs."Nil”, which was considered by the AO, who ultimately disallowed the said interest income treating as income from other sources u/s 56 of the Act, vide assessment order dated 17.03.2023 u/s 147 r.w.s.144B of the Act. 4. Thus, the Assessee, being aggrieved, challenged

Sukhsagar Co Operative Credit Society Ltd, Mumbai vs. Income Tax Officer Ward 32(1)(1), Mumbai

The appeal of the assessee is allowed in the

ITA 4335/MUM/2025[2020-21]Status: DisposedITAT Mumbai21 Nov 2025AY 2020-21

Bench: Shri Narender Kumar Choudhry

For Appellant: Shri Kumar Kale, Ld. A.RFor Respondent: Shri Vikas Chandra, Ld. Sr. D.R

Section 147Section 250Section 56Section 80PSection 80P(1)Section 80P(2)(d)

income declaring total income at Rs.”Nil”, which was considered by the AO, who ultimately disallowed the said interest income treating as income from other sources u/s 56 of the Act, vide assessment order dated 17.03.2023 u/s 147 r.w.s. 144B of the Act. 4. Thus, the Assessee, being aggrieved, challenged

Mona Sanjay Shah, Mumbai vs. Asst. CIT Circle 19(1), Mumbai

In the result, assessee’s appeal is allowed for statistical purposes

ITA 1062/MUM/2025[2018-19]Status: DisposedITAT Mumbai21 Nov 2025AY 2018-19

Bench: Smt Beena Pillai & Smt.Renu Jauhri7 (A.Y.2018-19)

For Appellant: Shri D C Jain, AdvocateFor Respondent: Shri Umashankar Prasad (CIT

Section 143(3)Section 250Section 68

learned Assessing Officer erred in making addition of Rs. 1, 39, 94, 607/-being interest Received Under the head income from other sources as against business offered by the appellant. P a g e | 2 ITA NO. 1062/mum/2025. Further the learned A.O. as well as learned CIT (Appeals) failed ... fact that the said interest received is already included in Audited Profit & Loss Account of the appellant and again added the same income from Other Sources amounts to double addition of same Income. 2. Under the facts and circumstances and in law the learned A.O. erred in computing G.P Ratio

Laveena Jain, Meerut vs. ITO Ward 1(1)(4), Meerut

In the result assessee’s appeal is allowed

ITA 5163/DEL/2025[2017-18]Status: DisposedITAT Delhi21 Nov 2025AY 2017-18

Section 139(5)Section 142(1)Section 143(2)Section 143(3)

Perusal of return reveals that the income of Rs. 2,63,579/- has been shown under the head "Income from other Sources" The case of the assessee was selected for limited scrutiny under CASS and the notice u/s 143(2) was issued on 11.8.2018 in which the reason for selection ... cash deposited by her in bank account during demonetization period amounting to Rs. 13,00,000/- should not be treated as her income from undisclosed sources. In response to the notice dated 15.10.2019 the assessee vide her reply dated 30.10.2019 has submitted that the returns of both the assessment years

Saini Co-Operative Tharift and Credit Society Ltd, Delhi vs. ITO Ward-48(1), Delhi

In the result, the appeal is allowed

ITA 4261/DEL/2025[2016-17]Status: DisposedITAT Delhi21 Nov 2025AY 2016-17

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

For Appellant: Sh. V. Rajakumar, AdvFor Respondent: Sh. Jitender Singh, CIT-DR

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

parties or nonmembers does not quality for exemption u/s.80P. It is an admitted position that the interest so earned should be taxed as 'income from other sources' There is a cleavage of judicial opinion among several High Courts on the issue of eligibility of this kind of income for exemption

Saini Co-Operative Tharift and Credit Society Ltd, Delhi vs. ITO Ward-48(1), Delhi

In the result, the appeal is allowed

ITA 4260/DEL/2025[2016-17]Status: DisposedITAT Delhi21 Nov 2025AY 2016-17

Bench: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

For Appellant: Sh. V. Rajakumar, AdvFor Respondent: Sh. Jitender Singh, CIT-DR

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

Lm Wind Power As, Denmark vs. Assistant Commissioner of Income Tax, Circle International Tax 2(2)(1), Delhi

In the result, ground raised by the assessee is allowed

ITA 4280/DEL/2024[2020-21]Status: DisposedITAT Delhi21 Nov 2025AY 2020-21

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.Lm Wind Power As, Vs, Acit, Circle Juptervej 6, 6000 Kolding, International Tax 2(2)(1), Denmark – 999999. Delhi (Pan :Aabcl8590Q) (Appellant) (Respondent) Assessee By : Shri Ajay Vohra, Sr. Advocate Shri Aditya Vohra, Advocate Shri Arpitgoyal, Ca Revenue By : Shri Saroj Kumar Dubey, Cit Dr Date Of Hearing : 27.08.2025 Date Of Order : 21.11.2025 Order Per S. Rifaur Rahman: 1. This Appealpreferred By The Assessee Is Directed Against The Assessment Order Dated 27.01.2025 Passed By The Acit, Circle Int. Tax 2(2)(1), Delhi Under Section 143(3) R.W.S. 144C(13) Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2020-21 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act Raising Following Grounds Of Appeal :- “1. That On The Facts & Circumstances Of The Case & In Law, The Assessment Order Dated 29.07.2024 Passed Under Section 143(3) Read With Section 144C(13) Of The Income-Tax Act, 1961 (He Act") For Assessment Year 2020-21 Assessing The Total Income Of The Assessee At Rs.81,14, 14,893 Is Bad In Law, Void- Ab-Initio & Therefore, Liable To Be Quashed And/ Or Set Aside.

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri Saroj Kumar Dubey, CIT DR

Section 143(3)Section 144C(13)Section 144C(5)Section 271ASection 44DSection 5Section 92C

Omitted by the Finance Act, 1988] C - Income from house property D - Profits and gains of business or profession E - Capital gains F - Income from other sources 8.1. The income in the present case, if at all, is traceable to 'Capital gains' which is one of the heads of income

Tulika Kedia, New Delhi, Delhi vs. Assistant Commissioner of Income Tax, Central Circle-1, Raipur

ITA 147/RPR/2025[2020-21]Status: DisposedITAT Raipur20 Nov 2025AY 2020-21

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 147/Rpr/2025 (िनधा"रण वष" Assessment Year: 2020-21)

For Appellant: Shri S. R. Rao, AdvFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 143(3)Section 153DSection 250Section 271BSection 44A

amount shown as profit from business for Rs.12,83,18,445/- comprises of income of salary, income from house property, capital gains and income from other sources, therefore, the perception of Ld. AO that the assessee’s turnover exceeds the prescribed limit as per section 44AB was a misconception

Income Tax Officer, Kota vs. Kota Karamachari Sahakari Samiti Limited, Kota

Appeal is allowed

ITA 1432/JPR/2025[2018-19]Status: DisposedITAT Jaipur20 Nov 2025AY 2018-19

For Appellant: Shri P.C.Parwal, FCAFor Respondent: Sh. Rajesh Ojha, CIT

Section 143(1)Section 143(2)Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

assessee at Rs.10,31,70,261/- by making addition of said amount, treating the said income by way of interest as "income from other sources", and disallowing the claim of the assessee for deduction as per provisions of section 80P(2)(d) of the Act. 3 ITA No. 1432/JPR/2025 Kota ... income is not eligible for deduction u/s 80P(2)(a)(i) also. The interest income was required to be taxed under the head "Income from Other Sources and not as "Business Income". Reliance is placed on the Hon'ble Supreme Court decision in the case of Totgars Co-operative Sale

Income Tax Officer, Ward-6(1), Pune vs. Shravani Land Private Limited, Pune

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

ITA 857/PUN/2024[2009-10]Status: DisposedITAT Pune20 Nov 2025AY 2009-10

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.857/Pun/2024 िनधा"रण वष" / Assessment Year : 2009-10 Ito, Ward-6(1), Pune. Vs. Shravani Land Private Limited, Utkarsha, Plot No.14, Yogi Arbindo Society, Sahakar Nagar-2, Pune- 411009. Pan : Aalcs1473M Appellant Respondent Revenue By : Shri Manish Kumar Sinha Assessee By : None Date Of Hearing : 15.09.2025 Date Of Pronouncement : 20.11.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Revenue Is Directed Against The Order Dated 26.02.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2009-10. 2. The Revenue Has Raised The Following Grounds Of Appeal :- “1. On The Facts & In The Circumstances Of The Case & In Law, The Id. Cit(A) Erred In Deleting The Addition Of Rs. 2,43,35,511/-

For Appellant: NoneFor Respondent: Shri Manish Kumar Sinha

Section 142(1)Section 143(3)Section 148Section 68

submit any explanation in this regard and therefore the Assessing Officer added the amount of Rs.2,43,35,511/- under the head ‘income from other sources’ being unexplained cash credit shown in the balance sheet in the name of unsecured loan. Accordingly, vide order dated 16.12.2016 the Assessing Officer completed

Sridharpur Co-Operative Bank, Bardhaman vs. ITO, Ward-3(2), Burdwan

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

ITA 672/KOL/2024[2017-18]Status: DisposedITAT Kolkata20 Nov 2025AY 2017-18

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 250Section 68

invoked the provisions of section 68 of the Act and added the total amount of SBNs received at ₹10,07,14,500/- as income from other sources. Aggrieved with the assessment order, the assessee filed an appeal before the Ld. CIT(A) who considered the facts of the case ... reported in 123 taxmann.com 161 held that the interest income derived from non-members is assessable u/s 56 as income from other sources and therefore, not eligible for benefit u/s 80P(2)(a)(i). However, the same has not been applied in the present case. The AO may initiate action

M/S Estin Tie Up Pvt. Ltd., Kolkata vs. A.C.I.T., Central Circle-1(2), Kolkata

In the result, the two cross appeals filed by the assessee as well as the Revenue are partly allowed for statistical purposes

ITA 32/KOL/2020[2013-14]Status: DisposedITAT Kolkata20 Nov 2025AY 2013-14

Bench: Shri Duvvuru Rl Reddy & Shri Rakesh Mishra

Section 143(3)Section 50C(1)Section 55A

premium of Rs.990/-. However, the assessee had computed the profit, purportedly LTCG, by taking the cost of acquisition of property at Rs.8.51 cr. ………. ………. 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 ... Income-tax under the 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. Since the amounts received by the assesseee appears to be not properly fitting Into any of the items

A.C.I.T., Central Circle-1(2), Kolkata vs. M/S Estin Tie Up Pvt. Ltd., Kolkata

In the result, the two cross appeals filed by the assessee as well as the Revenue are partly allowed for statistical purposes

ITA 141/KOL/2020[2013-14]Status: DisposedITAT Kolkata20 Nov 2025AY 2013-14

Bench: Shri Duvvuru Rl Reddy & Shri Rakesh Mishra

Section 143(3)Section 50C(1)Section 55A

Gmedapadu Pacs, Gmedapadu vs. ITO, Ward-1, Kakinada

ITA 574/VIZ/2025[2020-21]Status: DisposedITAT Visakhapatnam19 Nov 2025AY 2020-21

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.574/Viz/2025 ("नधा"रण वष"/Assessment Year: 2020-21) G Medapadu Pacs, Vs. Income Tax Officer, East Godavari District, Ward-1, Andhra Pradesh. Kakinada. Pan: Aaaag8455A (Appellant) (Respondent) "नधा"रती "वारा/Assessee By: Sri Kss Sarma, Ca राज" व "वारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई क" तार"ख/Date Of 16/10/2025 Hearing: घोषणा क" तार"ख/Date Of 14/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M:

For Appellant: Sri KSS Sarma, CAFor Respondent: Dr. Aparna Villuri, Sr. AR

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

that the contractual obligation and corresponding payments were between the society and its members, rather than a third party (APSCSCL). The nature of income and its source must be examined in substance, not merely by the form of routing. e) Even if the procurement was undertaken under government supervision ... deposits made with the District Central Co-operative Bank (DCCB) has been rightly brought to tax by the Assessing Officer under the head "Income from Other Sources." The appellant claimed deduction on this income under Sections 80P(2)(a)(i) and 80P(2)(d) of the Income

Amli Mohammed Taj, Kurnool vs. DCIT, Central Circle-2, Guntur

ITA 397/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam19 Nov 2025AY 2018-19

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.397/Viz/2025 (निर्धारण वर्ा/Assessment Year: 2018-19) Amli Mohammed Taj, Vs. Dcit, Kurnool. Central Circle-2, Pan: Achpt2412N Guntur. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S. Rama Rao, Advocate रधजस्‍व द्वधरध/Revenue By: Dr. Aparna Villuri, Sr. Ar सुिवधई की तधरीख/Date Of 06/11/2025 Hearing: घोर्णध की तधरीख/Date Of 19/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm : The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), Visakhapatnam-3, Dated 04/04/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 154 Of The Income-Tax Act, 1961 (For Short, “Act”), Dated 19/05/2023 For The Assessment Year 2018-19. The Assessee Has Assailed The Impugned Order On The Following Grounds Of Appeal Before Us:

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 115BSection 142(1)Section 143(2)Section 153ASection 154Section 69A

Returned Income Rs. 26,80,500/- Income estimated from Rs. 98,009/- Business 7 Amli Mohammed Taj vs. DCIT Income from other sources Rs. 3,25,670/- Bank Interest Rs. 13,120/- Income from plying of lorry Rs. 90,000/- Unexplained cash seized 69A Rs. 26,82,200/- Assessed Income ... dated 28/09/2021, had rejected the assessee’s claim that the cash seizure of Rs. 26,82,200/- was his income that was sourced from his earnings from crossword puzzles. In fact, we find on a perusal of the assessment order that the AO had categorically observed that, for want

Riddhi Siddhi Mahila Nagari Co-Op Credit Society Ltd, Karad vs. CIT (Appeals), Delhi

ITA 2216/PUN/2025[2019-20]Status: DisposedITAT Pune19 Nov 2025AY 2019-20

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2216/Pun/2025 िनधा"रण वष" / Assessment Year : 2019-20 Riddhi Siddhi Mahila Nagari Vs. Assessment Unit, Co-Op. Credit Society Ltd., Income Tax Department. Palkar House, 157, Guruwar Peth, Shri Vitthal Chouk, Karad- 415110. Pan : Aacar0958D Appellant Respondent Assessee By : Shri Vijaykumar N. Kashirsagar Revenue By : Shri Vinod Pawar (Virtual) Date Of Hearing : 28.10.2025 Date Of Pronouncement : 19.11.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 28.08.2025 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2019-20. 2. Facts Of The Case, In Brief, Are That The Assessee Is A Primary Credit Co-Operative Society Engaged In The Business Of Providing Credit Facilities To Its Members & Also In Accepting Deposits From Them. On The Basis Of Information That The Assessee Has Made One Time Deposit Of Rs.5,95,522/- & Tds Of More Than Rs.7,72,686/-

For Appellant: Shri Vijaykumar N. KashirsagarFor Respondent: Shri Vinod Pawar (Virtual)

Section 139(1)Section 142(1)Section 147Section 148Section 194ASection 80ASection 80P(2)(c)Section 80P(2)(d)

assessee society with other cooperative banks, details of secured and unsecured loan taken and repaid during the year and details of income from other sources i.e. interest from other cooperative banks and details of interest income on loans and advances from members and also details of interest income received

Penninti Vivekananda Rao, Hyderabad vs. ADIT (Int Taxn)-2, Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1494/HYD/2025[2020-21]Status: DisposedITAT Hyderabad19 Nov 2025AY 2020-21

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1494/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2020-21) Shri Penninti Vivekananda Vs. Adit (International Rao, Hyderabad Taxation)-2 Pan:Ayupp1895L Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate H Srinivasulu राज" व "ारा/Revenue By:: Smt. U Mini Chandran, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 13/11/2025 घोषणा की तारीख/Pronouncement: 19/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Penninti Vivekananda Rao (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-10, Hyderabad (“Ld. Cit(A)”) Dated 29.07.2025 For The A.Y 2020-21. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Advocate H SrinivasuluFor Respondent: : Smt. U Mini Chandran, CIT(DR)

Section 143(2)Section 270A

declaring a total income of Rs.5,20,66,038/-, consisting of Capital Gains of Rs.4,78,14,391/- and Income from Other Sources of Rs.42,61,647/-. Out of the total capital gains, the assessee had shown Rs.3,22,68,672/- arising from surrender of three Equity Plus Fund issued ... During the assessment proceedings, the Ld. AO held that the gain on surrender of Bajaj Equity Plus Fund is taxable under the head “Income from Other Sources” and not “Capital Gains.” Accordingly, the Ld. AO initiated the penalty proceedings under section 270A of the Act for misreporting of income