“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

Canon India Pvt. Ltd, Gurugram vs. Neac, Delhi

In the result, to sum up and conclude:

ITA 585/DEL/2021[2003-04]Status: DisposedITAT Delhi10 Nov 2025AY 2003-04

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Shri Vijay B. Basanta, CIT-DR

Section 10ASection 143(3)Section 254Section 92C

Total PGBP Income (A + B) (4,49,52,527) Income under the head 'Capital Gains (11,94,328) Income from other Sources 1,18,217 Total Income (4,48,34,310) 6. During the Assessment Year 2003-04, the assessee earned certain income from its operations in Japan, on which

Anil Kumar Vellaga, Guntur vs. Income Tax Officer, Ward-1(1), Guntur

In the result, appeal of the assessee is dismissed

ITA 511/VIZ/2025[2022-23]Status: DisposedITAT Visakhapatnam07 Nov 2025AY 2022-23

Bench: Shri Ravish Sood, Hon’Ble

Section 132(1)Section 142(1)Section 143(3)Section 69A

Exemption / deduction under the head salary income and Rs.1,44,64,870/- as addition on account of lottery income under the head income from other sources. 3. On being aggrieved by the order of the Ld. AO, assessee carried the matter before the Ld. CIT(A). Ld. CIT(A) dismissed

Jain Babulal Champatlal, Vijayawada vs. Income Tax Officer, Ward 2(1), Vijayawada

In the result, both the appeals filed by the assessee are 9

ITA 395/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam07 Nov 2025AY 2017-18

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.394 & 395/Viz/2025 (निर्धारणवर्ा/ Assessment Year:2017-18) Vs. Jain Babulal Champatlal Income Tax Officer – Ward – 2(1) Cr Building, 1St Floor Annex 40-1-155, Lgf Mg Road, Vijayawada – 520002 Ripples Mall, M.G. Road Andhra Pradesh Vijayawada-520010 Andhra Pradesh [Pan:Aefpc1220F]

Section 142(1)Section 143(2)Section 143(3)Section 270ASection 57

claimed deduction under section 57 of the Act to the interest payments made by the assessee. Ld. AO observed that assessee has admitted income from other sources at Rs.35,28,219/- and Page. No 2 I.T.A.Nos.394 & 395/VIZ/2025 Jain Babulal Champatlal claimed deduction under section ... Rs.28,75,925/- and after deduction the income from other sources was returned at Rs.6,70,294/-. After considering the details furnished by the assessee, Ld. AO completed the assessment under section 143(3) of the Act on 20.12.2019 and determined that interest payment to the tune of Rs.7

Jain Babulal Champatlal, Vijayawada vs. Income Tax Officer, Ward 2(1), Vijayawada

In the result, both the appeals filed by the assessee are 9

ITA 394/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam07 Nov 2025AY 2017-18

Section 142(1)Section 143(2)Section 143(3)Section 270ASection 57

Pentyala Madhavi, Hyderabad vs. Income Tax Officer, Ward-12(1), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 392/HYD/2025[2015-2016]Status: DisposedITAT Hyderabad07 Nov 2025AY 2015-2016

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

Section 139Section 142(1)Section 144Section 147Section 148Section 69A

agricultural income of Rs. 1,75,000/- claimed by the assessee in her return of income filed on 28-05- 2022 as income from other sources. 3. Aggrieved by the order of the A.O., the assessee preferred an appeal before the Ld. CIT(A). 4. Before ... made by the A.O. towards cash deposits into the bank account and also the addition of Rs. 1,75,000/- under the head “Income from Other Sources” towards agricultural income reported in the 4 Pentyala Madhavi. return of income. The Ld. CIT(A), after considering the submissions of the assessee

Meraj Anjum, Hyderabad vs. Income Tax Officer, Ward-7(1), Hyderabad

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

ITA 1467/HYD/2025[2017-2018]Status: DisposedITAT Hyderabad07 Nov 2025AY 2017-2018

Bench: the Ld. CIT(A).

Section 69A

bank account, which she had inherited from her husband, and apart from this, she does not have any other source of income. Further, the source of cash deposits was explained out of cash withdrawal from the very same bank account for the purpose of her daughter's marriage. Since ... available with her out of withdrawals from bank account during the demonetization period. 10. We find that, the assessee is an individual deriving income from other sources, being interest income from fixed deposits in bank account. Except income from other sources, the assessee does not have any other source

Ravi Shroff, Mumbai vs. Assistant Commissioner of Income Tax - 25(3), Mumbai, Bandra (East)

In the result, all remaining ground are allowed with the aforesaid directions

ITA 4186/MUM/2023[2015-16]Status: DisposedITAT Mumbai07 Nov 2025AY 2015-16

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 234BSection 234CSection 250Section 254(1)Section 28Section 28(1)

total income of Rs. 3.14 crore. In the computation of income, the assessee has shown income from salary of Rs. 31,47,555/- income from other sources of Rs. 9,70,278/- and long-term capital gain of Rs. 2.75 crore. Case was selected for scrutiny. During assessment the assessing

Prashant Kumar, Delhi vs. Asst CIT, Circle 70(1), Delhi

Appeal is allowed in the aforesaid terms

ITA 5624/DEL/2025[2017-18]Status: DisposedITAT Delhi07 Nov 2025AY 2017-18

Bench: Shri Mahavir Singh, Hon’Bleasstt. Year : 2017-18

For Appellant: Sh. M.K. Bhatt, CA & Sh. Malav Gosowami, AdvFor Respondent: Shri Manoj Kumar, Sr. DR

Section 142(1)Section 143(2)Section 15BSection 69A

necessary details as called on ITBA, which are placed on record. During the year under consideration, the appellant derived income from Salary and income from other sources. As per information available on system and bank statement, the appellant has deposited cash of Rs. 15 lakhs during the demonetization period

DCIT, Circle 4(2), New Delhi vs. Ms Communique Marketing Solutions Pvt Ltd, New Delhi

In the result, the appeal of Revenue is dismissed and cross-objection of Assessee is allowed

ITA 4762/DEL/2024[2017-18]Status: DisposedITAT Delhi07 Nov 2025AY 2017-18

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2017-18 Deputy Commissioner Of Income Vs. Ms Commmunique Marketing Tax, Circle 4(2), Solutions (P) Ltd., 5407, Arya Samaj New Delhi. Road, Karol Bagh, New Delhi-110005 Pan :Aaccc3432F (Appellant) (Respondent)

Section 115Section 115BSection 142(1)Section 143(1)Section 143(2)Section 250Section 37Section 68

while section 145[1] provides that it is for computation of income under the heads "Profits and Gains of Business and Profession" or "Income from Other Sources". Therefore addition u/s 68 is not an addition under the head business or profession and hence section 145[3 i.e. rejection of books

Deputy Commissioner of Income Tax, Delhi vs. Indian Hydro Electric Power Pvt. Ltd., Delhi

ITA 3907/DEL/2023[2019-20]Status: DisposedITAT Delhi07 Nov 2025AY 2019-20

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 132Section 132(4)Section 153ASection 250Section 68Section 69C

Nos.3906 & 3907/Del/2023 addresses and were not engaged in any regular and genuine business activity, and all were showing very meagre income from other sources and no income was shown from regular business activities. Ld. CIT DR thus contended that the additions were made of INR 25.05 crores in the year

Deputy Commissioner of Income Tax, Central Circle-20, Delhi vs. Indian Hydro Electric Power Pvt. Ltd., Delhi

ITA 3906/DEL/2023[2018-19]Status: DisposedITAT Delhi07 Nov 2025AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 132Section 132(4)Section 153ASection 250Section 68Section 69C

Babubhai Kanjibhai Sakaria, Jetpur vs. ITO WD 1(2)(1), Rajkot

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

ITA 156/RJT/2025[2016-17]Status: DisposedITAT Rajkot06 Nov 2025AY 2016-17

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 156/Rjt/2025 (Assessment Year: 2016-17) Babubhai Kanjibhai Sakariya Vs. Ito, Wd 1(2)(1), Rajkot Plot No. 82 Satyam Park, Amarnagar Aaykar Bhavan, Race Course Ring Road, Jetpur,(Rajkot-Gujarat) -360370 Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Agnps7407C (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: Shri Rajendra Singhal, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 194ASection 250Section 28

should not be treated as receipts in assessee`s hands and it should be taxable under the head income from other sources. 4. In compliances thereto, the assessee, submitted its reply, along with documentary evidences, before the assessing officer, vide reply dated 03.12.2018. The assessee submitted before the assessing officer ... viii) of the Income Tax Act, 1961, therefore, interest of Rs.47,37,762/- will also not be chargeable to tax under the head income from other sources. Page 4 of 19 Babubhai K. Sakaria 5. However, the assessing officer rejected the above contention of the assessee and observed that

The Kattoor Service Cooperative Bank Limited, Thrissur vs. Income Tax Officer, Ward 2(1), Thrissur

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

ITA 714/COCH/2025[2022-23]Status: DisposedITAT Cochin06 Nov 2025AY 2022-23

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm Assessment Year: 2022-23 Kattoor Service Co-Op. Bank Ltd. .......... Appellant Kattoor P.O., Thrissur 680702 [Pan: Aacat3937A] Vs. The Income Tax Officer, Ward-2(1), Thrissur ......... Respondent Assessee By: Shri Amaljith P.J., Ca Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 03.11.2025 Date Of Pronouncement: 06.11.2025 O R D E R Per Manu Kumar Giri, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [“Cit(A)” In Short] Dated 25.08.2025 For Assessment Year (Ay) 2022-23. 2. Brief Facts Of The Case Are That The Appellant Is A Co-Operative Society Registered Under The Kerala State Co-Operative Societies Act, 1961. 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 Return Of 2 Kattoor Service Co-Op. Bank Ltd. Income For Ay 2022-23 Was Filed On 05.11.2022 Disclosing Nil Income After Claiming Deduction U/S. 80P Of The Income Tax Act, 1961 (The Act). Against The Said Return Of Income, The Assessment Was Completed By The Assessment Unit, Income Tax Department (Hereinafter Called "The Ao") Vide Order Dated 19.03.2024 Passes U/S. 143(3) R.W.S. 144B Of The Act At A Total Income Of Rs.5,21,52,939/-. While Doing So, The Ao Denied Deduction U/S.80P(2)(A)(I) & U/S. 80P(2)(D) Of The Act.

For Appellant: Shri Amaljith P.J., CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR

Section 143(3)Section 63Section 64Section 80PSection 80P(2)(a)Section 80P(2)(d)

Bank/State Co-operative Bank, in the facts and circumstances of the case, do come within Section 80P(2)(d). Therefore, the income constitutes income from other sources and the only eligible deduction is covered by Section 80P(2)(d) viz. Interest or dividend derived by the assessee from its investments

Dharmadanga Samabay Krishi Unnayan Samity Ltd., Kalna, Purba Bardhaman vs. I.T.O., Ward - 1(3), Burdwan

In the result, the appeal of the assessee is allowed

ITA 1116/KOL/2025[2014-2015]Status: DisposedITAT Kolkata06 Nov 2025AY 2014-2015

Bench: Shri Sonjoy Sarma & Shri Sanjay Awasthi

For Appellant: NoneFor Respondent: Pampa Ray, Sr. DR

Section 250Section 80PSection 80P(2)(a)

benefit of the individual members and not to the Society itself; that in relation to the Society, it was to be treated as income from other sources since the interest income had lost its nexus with the principal income earned by the Society. The facts in the instant cases

Bani Broto Banerjee, Kolkata vs. ACIT Circle 58(1), Kolkata

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

ITA 1095/KOL/2023[2016-17]Status: DisposedITAT Kolkata06 Nov 2025AY 2016-17

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(2)Section 143(3)Section 250Section 57

Bani Broto Banerjee. 3. Brief facts of the case are that the assessee is an individual earning income from business/profession and income from other sources and had filed the return of income showing total income of ₹35,12,350/-. The case was selected for complete scrutiny through Computer Assisted Scrutiny ... expenses claimed by the Assessing Officer (hereinafter referred to as Ld. 'AO'). The Ld. AO disallowed the claim of expenses under the head ‘income from other sources’ being bank interest of ₹42,38,818/- and added the same to the income of the assessee and assessed the total income

Vishal Kumar, Yamuna Nagar vs. ITO Ward-5 Yamunanagar, Yamunan Nagar

In the result, appeal of the assessee stands allowed

ITA 494/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh04 Nov 2025AY 2018-19

Bench: SH. SANJAY GARG (Judicial Member)

For Appellant: Shri Shrawan Kumar Gupta, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr.DR

Section 44A

revised computation wherein the income from remuneration of partnership firm was shown at Rs.10,04,782/- and interest income of Rs.3013/- and further income from other sources of Rs.17,304/-, totaling Rs.10,25,100/-. The assessee also deposited the self-assessed tax on the said income and pleaded before

Ishwarbhai Gordhanbhai Prajapati, Ahmedabad vs. Income Tax Office Ward 3(3)(5) Ahmedabad, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1344/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad04 Nov 2025AY 2018-19

For Appellant: Shri Sulabh Padshah, ARFor Respondent: Shri C Dharani Nath, Sr.DR

Section 250Section 50CSection 50C(2)Section 56(2)(x)

stamp duty purposes. The Assessing Officer invoked the provisions of section 56(2)(x) of the Act and treated this difference as income from other sources, holding that the assessee had received property for consideration less than its fair market value. Consequently, the AO made an addition

Akashdeep Cloth Centre, Kannad vs. Principal CIT, Nashik

In the result, both the appeals filed by the respective assessees are allowed

ITA 959/PUN/2024[2019-20]Status: DisposedITAT Pune04 Nov 2025AY 2019-20

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2019-20

For Appellant: S/Shri Shubham N. Rathi and Ashutosh DhootFor Respondent: Shri Amol Khairnar, CIT-DR

Section 115BSection 142(1)Section 143(3)Section 263Section 69Section 69B

source. The General Manager at the time of recording of statement had stated that the said cash has been generated out of income from other sources. In these facts, the Hon’ble High Court held that such unexplained cash was assessable as deemed income ... cash found during the survey. Further, the additional income surrendered during the survey was offered in the return of income under the head ‘Income from other sources’. Under these circumstances, the Tribunal held that the excess cash found is to be taxed u/s 115BBE of the Act. He accordingly submitted

Manmandir Cloth Centre, Kannad vs. PCIT, Nashik

In the result, both the appeals filed by the respective assessees are allowed

ITA 1012/PUN/2024[2019-20]Status: DisposedITAT Pune04 Nov 2025AY 2019-20

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2019-20

For Appellant: S/Shri Shubham N. Rathi and Ashutosh DhootFor Respondent: Shri Amol Khairnar, CIT-DR

Section 115BSection 142(1)Section 143(3)Section 263Section 69Section 69B

Yunush Mallick, Kolkata vs. ITO, Ward 61(3), Kolkata

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

ITA 1990/KOL/2025[2017-2018]Status: DisposedITAT Kolkata04 Nov 2025AY 2017-2018

Bench: Shri Sonjoy Sarma & Shri Sanjay Awasthiआयकर अपील सं/Ita No.1990/Kol/2025 ("नधा"रण वष" / Assessment Year : 2017-2018) Yunush Mallick Vs Ito, Ward-61(3), Kolkata 114, Type-Ii, Crpf Campus, Sector-V, Salt Lake City, Kol-91. Pan No. :Acgpy2435D (अपीलाथ" /Appellant) (""यथ" / Respondent) .. "नधा"रती क" ओर से /Assessee By : None राज"व क" ओर से /Revenue By : Pampa Ray, Sr. Dr सुनवाई क" तार"ख / Date Of Hearing : 03/11/2025 घोषणा क" तार"ख/Date Of Pronouncement : 04/11/2025

For Appellant: NoneFor Respondent: Pampa Ray, Sr. DR

Section 144Section 147Section 250Section 56(2)(x)Section 69A

Section 144, making the following additions: ₹10,75,000 as unexplained investment under Section 69A of the Act; and ₹26,01,610 as income from other sources under Section 56(2)(x) of the Act. The total income was thus determined at ₹43,40,360 as against the returned income ... investment in the property, but sustained the addition of ₹26,01,610 made under Section 56(2)(x) of the Act as income from other sources. 4. The assessee is now in further appeal before the Tribunal. From the records, it is seen that although notices were issued