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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

Ranjit Singh, Ropar vs. ITO, Ward-2(2), Ropar

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

ITA 807/CHANDI/2025[2013-14]Status: DisposedITAT Chandigarh17 Nov 2025AY 2013-14

Bench: Shri Laliet Kumarआयकर अपील सं./ Ita No. 807/Chd/2025 "नधा"रण वष" / Assessment Year : 2013-14 Ranjit Singh, The Ito, Kiri Afghana Behlolpur बना Warad 2 (2), Chamkaur Sahib, Rupnagar म Rupnagar 141121 Vs. "थायी लेखा सं./Pan No: Gmqps5933A अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Sh Parikshit Aggarwal, Ca राज"व क" ओर से/ Revenue By : Sh. Vinod Kumar Chaudhary, Jcit, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 12-11-2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 17-11-2025 आदेश/Order This Appeal By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals), Nfac, Dated 22.08.2024, For The Assessment Year 2013-14. 2. The Grounds Of Appeal Raised By The Assessee Are As Under: -

For Appellant: Sh Parikshit Aggarwal, CAFor Respondent: Sh. Vinod Kumar Chaudhary, JCIT
Section 144Section 148Section 250Section 69

erroneously holding the cash deposit in bank account to be from unexplained sources and treating the same as income from other sources. 4. That on facts, circumstances and legal position of the case, the orders passed by Ld. AO and then by Worthy CIT(A) deserves to be quashed since ... made by the Assessing Officer and confirming the cash deposit in bank account to be from unexplained sources and treating the same as income from other sources. 7. Briefly stated the facts of the case as culled out from the order of lower authorities are that the Assessee had made

The Sangli Salary Earners Co Op Society Ltd, Sangli vs. Income Tax Officer Ward 3 Sangli, Sangli

In the result, appeal of the assessee is allowed

ITA 2254/PUN/2025[2020-21]Status: DisposedITAT Pune17 Nov 2025AY 2020-21

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2254/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 The Sangli Salary Earners Co V The Income Tax Officer, Op Society Ltd., S. Ward-3, Sangli. 1104 B, Harbhat Road, Main City, Sangli – 416416 Pan: Aaaat0980D Appellant/ Assessee Respondent / Revenue Assessee By Shri Amit Sudhir Shintre(Virtual) Revenue By Smt. Saumya Pandey Jain-Addl.Cit Date Of Hearing 17/11/2025 Date Of Pronouncement 17/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Is Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2020-21, Dated 27.08.2025 Emanating From Assessment Order U/S.143(3) Read With Section 143(3) R.W.S 144B Of The Income Tax Act, 1961 Dated 26.09.2022. The Assessee Has Raised Following Grounds Of Appeal : “1. Deduction U/S 80P(2)(A)(I) Relying On The Decision Of Totgars Co-

Section 143(3)Section 250Section 57Section 80PSection 80P(2)(a)Section 80P(2)(c)Section 80P(2)(d)Section 80P(4)

Income- tax Act, 1961, against the interest income of ₹3,71,88,591/-, even after treating the same as "Income from Other Sources". The Appellant submits that such interest income has been earned out of statutory and working capital funds, on which substantial interest and administrative costs were incurred ... pleased to: a) Delete the addition of ₹3,71,88,591/-made by the Assessing Officer by treating the interest income as "Income from Other Sources and consequently allow the deduction under section 80P(2)(a)(i) and/or 80P(2)(d) of the Income

Kashipur Brihandayatan Credit Cooperative Society Ltd., Purulia vs. ITO, Ward- 3(2), Purulia

In the result, appeal of the Revenue is dismissed

ITA 249/KOL/2025[2017-18]Status: DisposedITAT Kolkata17 Nov 2025AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 249/Kol/2025 Assessment Year: 2017-2018 Kashipur Brihadayatan Credit Cooperative Society Limited,………………………………………Appellant Vill. & P.O. Kalapathar, District-Purulia-723121, West Bengal [Pan:Aaaak9453E] -Vs.- Income Tax Officer,…………………………..…..Respondent Ward-3(2), Purulia, South Lake Road, Purulia-723101, W.B. Appearances By: Shri M. Goenka, C.A. & Shri S. Goenka, C.A., Appeared On Behalf Of The Assessee Shri Susanta Saha, Sr. D.R., Addl. Cit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: September 03, 2025 Date Of Pronouncing The Order: November 17, 2025 O R D E R

Section 142(1)Section 143(2)Section 3Section 80PSection 80P(2)(a)

being satisfied, the ld. Assessing Officer disallowed Rs.11,08,044/- and added to the total income of the assessee under the head “income from other sources”. 2 Kashipur Brihadayatan Credit Cooperative Society Limited 3. On being aggrieved, the assessee preferred an appeal before the ld. CIT(Appeals). The ld. Addl ... Apex Court has held that interest earned from retaining the amount payable to its members shall not be considered as income from other sources. However, in the instant case the facts are distinguishable and hence in our view the ratio laid down in the case of M/s. Totgars Cooperative Sale