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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

Dinesh Kumar Jeetendra Bhandari, Chennai vs. Asst. Commissioner of Income Tax, Chenai

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

ITA 1686/CHNY/2025[2016-2017]Status: DisposedITAT Chennai13 Nov 2025AY 2016-2017

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.1686/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 Dinesh Kumar Jeetendra Bhandari, Vs. The Assistant Commissioner Of No. 27B, Mooker Nallamuthu Street, Income Tax, Chennai G.P.O., Parrys, Corporate Circle 1(2), Chennai 600 001. Chennai. [Pan:Aaapb6406F] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Hitesh, Advocate ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 06.11.2025 घोषणा की तारीख /Date Of Pronouncement : 13.11.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi:

For Appellant: Shri Hitesh, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 57

material available on record. It is noted from the details of interest received are reflected in the income returned under the head “income from other sources” and the break-up is also detailed therein. On perusal of the same, which clearly demonstrates the interest expenditure incurred by the assessee ... Bhandari Foils & Tubes Ltd., Bhandari Steels Pvt. Ltd. Adinath Finance Services and shown income from the said 4 entities under the head “income from other sources”. We find no dispute that the assessee made investments in the above said 4 entities, but, however, the respondent-revenue denied full deduction

Shital Nilesh Parakh, Ahilyanagar vs. ITO, Ward-2, Ahilyanagar

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

ITA 182/PUN/2025[2020-21]Status: DisposedITAT Pune12 Nov 2025AY 2020-21

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.182/Pun/2025 िनधा"रण वष" / Assessment Year : 2020-21 Shital Nilesh Parakh, Vs. Ito, Ward-2, 1, Main Road, Vambori, Ahilyanagar. Tal. Rahuri, Dist. Ahilyanagar- 413704. Pan : Aptpp5302G Appellant Respondent Assessee By : Shri Prasad Bhandari Revenue By : Shri Shashank Ojha Date Of Hearing : 19.08.2025 Date Of Pronouncement : 12.11.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 27.11.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2020-21. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. On The Facts & In The Prevailing Circumstances Of The Case & In Law, The Learned Cit(A)-Nfac Erred In Not Accepting The Agriculture Income Of Rs. 89,50,214 Without Appreciating The Submission Made By The Assessee. Hence, The Impugned Order

For Appellant: Shri Prasad BhandariFor Respondent: Shri Shashank Ojha
Section 142(1)Section 143(3)Section 44ASection 69C

income returned by the assessee at Rs.3,23,460/-. The above assessed income includes addition of Rs.89,50,214/- agricultural receipt treated as income from other sources. 4. Being aggrieved with the above assessment order, the assessee preferred an appeal before Ld. CIT(A)/NFAC. After considering the reply

Laxminarayan Ramswarup Maniyar, Jalgaon vs. Circle-1, Jalgaon

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

ITA 1203/PUN/2025[2021-22]Status: DisposedITAT Pune12 Nov 2025AY 2021-22

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1203/Pun/2025 िनधा"रण वष" / Assessment Year : 2021-22 Laxminarayan Ramswarup Vs. Acit, Circle-1, Jalgaon. Maniyar, Sitaram Ramswarup, 105, Polan Peth, Dana Bazar, Jalgaon- 425001. Pan : Aaqpm9220L Appellant Respondent Assessee By : Shri Vinay V. Kawdia Revenue By : Shri Harshit Bari Date Of Hearing : 21.08.2025 Date Of Pronouncement : 12.11.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 13.03.2025 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2021-22. 2. The Assessee Has Raised The Following Grounds Of Appeal :- “1) In The Absence Of Conditions Precedent For Invoking Provisions Of S. 143(1)(A)(Iii) Of The Act, The Learned Cit(A), Nfac Has Erred In Confirming The Adjustment Of Rs. 8,03,196/- Made By Cpc U/S 143(1)(A)(Iii) Of The Act By Denying The Set Off Of Brought Forward Unabsorbed Depreciation Of Earlier Years Against Current Years Income.

For Appellant: Shri Vinay V. KawdiaFor Respondent: Shri Harshit Bari
Section 139(1)Section 143(1)Section 143(1)(a)Section 154

disallowing the set off of brought forward unabsorbed depreciation loss of earlier years against current years income from House property (Rs.82,085/-) and income from other sources (Rs. 7,21,111/-). The assessee is fully eligible for set off and the same may please be allowed in full ... case, in brief, are that the assessee is an individual having income from salary, business and profession, income from house property and income from other sources. The return of income was furnished on 07.01.2022 declaring taxable income of Rs.7,33,000/-. Vide an intimation dated 14.07.2022, CPC processed the return

Income Tax Officer Ward 2(2) Pune, Pune vs. The Ammunition Factory Co Op Credit Society Limited, Pune

In the result, the appeal of the Revenue in ITA

ITA 1100/PUN/2025[2020-21]Status: DisposedITAT Pune12 Nov 2025AY 2020-21

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1099 & 1100/Pun/2025 िनधा"रण वष" / Assessment Years : 2018-19 & 2020-21 Ito, Ward-2(2), Pune. Vs. The Ammunition Factory Co-Op. Credit Society Limited, Nehru Marg, Khadki, Pune- 411003. Pan : Aaajt0095N Appellant Respondent Revenue By : Shri Amit Bobde & Shir Shashank Ojha Assessee By : Shri Rohit C. Kasat Date Of Hearing : 20.08.2025 Date Of Pronouncement : 12.11.2025 आदेश / Order Per Vinay Bhamore, Jm: Both The Above Captioned Appeals Filed By The Revenue Are Directed Against The Separate Orders Dated 12.02.2025 & 28.02.2025 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2018-19 & 2020-21 Respectively. 2. Since Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals Of The Revenue, Therefore, We Proceed To Dispose Of The Same By This Common Order.

For Appellant: Shri Rohit C. KasatFor Respondent: Shri Amit Bobde &
Section 143(1)(a)Section 143(2)Section 143(3)Section 56Section 80Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

Court in PCIT Vs. Totgar’s Co- op Sale Society (2017) 395 ITR 611 which held that such interest income is taxable under Income from Other sources. 3. The appellant craves leave to add, amend, modify, or withdraw any of the above grounds of appeal before or at the time ... from cooperative bank which is not a co- operative society and was therefore liable to be taxed u/s 56 of the Act as income from other sources. For this purpose the Assessing Officer relied on the judgement passed by Hon’ble Supreme Court & also by Hon’ble Karnataka High Court

Income Tax Officer Ward 2(2) Pune, Pune vs. The Ammunition Factory Co Op Credit Society Limited, Pune

In the result, the appeal of the Revenue in ITA

ITA 1099/PUN/2025[2018-19]Status: DisposedITAT Pune12 Nov 2025AY 2018-19

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1099 & 1100/Pun/2025 िनधा"रण वष" / Assessment Years : 2018-19 & 2020-21 Ito, Ward-2(2), Pune. Vs. The Ammunition Factory Co-Op. Credit Society Limited, Nehru Marg, Khadki, Pune- 411003. Pan : Aaajt0095N Appellant Respondent Revenue By : Shri Amit Bobde & Shir Shashank Ojha Assessee By : Shri Rohit C. Kasat Date Of Hearing : 20.08.2025 Date Of Pronouncement : 12.11.2025 आदेश / Order Per Vinay Bhamore, Jm: Both The Above Captioned Appeals Filed By The Revenue Are Directed Against The Separate Orders Dated 12.02.2025 & 28.02.2025 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2018-19 & 2020-21 Respectively. 2. Since Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals Of The Revenue, Therefore, We Proceed To Dispose Of The Same By This Common Order.

For Appellant: Shri Rohit C. KasatFor Respondent: Shri Amit Bobde &
Section 143(1)(a)Section 143(2)Section 143(3)Section 56Section 80Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

Court in PCIT Vs. Totgar’s Co- op Sale Society (2017) 395 ITR 611 which held that such interest income is taxable under Income from Other sources. 3. The appellant craves leave to add, amend, modify, or withdraw any of the above grounds of appeal before or at the time ... from cooperative bank which is not a co- operative society and was therefore liable to be taxed u/s 56 of the Act as income from other sources. For this purpose the Assessing Officer relied on the judgement passed by Hon’ble Supreme Court & also by Hon’ble Karnataka High Court