“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

Assistant Commissioner of Income Tax, Circle-1(1), Tirupati vs. Venkata Swamy Ravuri, Chittoor

In the result, the appeal of the Revenue is allowed for

ITA 257/HYD/2022[2017-18]Status: DisposedITAT Hyderabad17 Oct 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Vice- & Shri Madhusudan Sawdia

For Appellant: Advocate Sashank Dundu

Section 143(3)Section 2Section 68

Revenue pertain to the deletion of addition of Rs.5,50,280/- made by Ld. AO by treating the agricultural income as income from other sources. During the course of assessment proceedings, the Ld. AO observed that the assessee had shown agricultural income of Rs.5,50,280/-. In the absence ... held that the assessee failed to substantiate the claim of having earned such agricultural income and, therefore, treated the said amount as income from other sources. The Ld. CIT(A) deleted the addition by holding that the assessee owned 12 acres of agricultural land, as evidenced by Form

Manoj Kumar Khandelwal, Kolkata vs. ACIT, Central Cir 4(4), Kolkata

In the result, the appeals of the assessee are allowed

ITA 422/KOL/2025[2019-20]Status: DisposedITAT Kolkata17 Oct 2025AY 2019-20

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm It(Ss)A No.160/Kol/2024 (Assessment Year:2013-14)

For Appellant: S/Shri S.M. Surana &For Respondent: Shri Sanat Kumar Raha, DR

Section 132Section 132(4)Section 69

OIN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, KOLKATA BEFORE SHRI RAJESH KUMAR, AM AND SHRIPRADIP KUMAR CHOUBEY, JM IT

Razak Rowther Mohamed Saleem, Dindigul vs. ITO, Ward-1, Dindigul

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

ITA 1731/CHNY/2025[2016-17]Status: DisposedITAT Chennai17 Oct 2025AY 2016-17

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.1731/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 Razak Rowther Mohamed Saleem, Vs. The Income Tax Officer, No. 29A, Manthinapalli Vasal Street, Ward 1, Batlagundu Road, Begampur, Dindigul. Dindigul 624 002. [Pan:Acfpm9762L] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. S. Vidya, C.A. ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 10.09.2025 घोषणा की तारीख /Date Of Pronouncement : 17.10.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 15.05.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2016-17. 2. The Assessee Raised 3 Grounds Of Appeal Amongst Which, The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is 2

For Appellant: Ms. S. Vidya, C.AFor Respondent: Ms. Gouthami Manivasagam, JCIT

Section 143(1)Section 143(2)Section 2

confirming the order of the Assessing Officer in denying the claim of agricultural income, consequently, the addition made thereon on account of income from other sources is deleted. Thus, the ground raised by the assessee is allowed. 10. In the result, the appeal filed by the assessee is allowed. Order

Pratima Hitesh Mehta, Mumbai vs. DCIT, CC -4(1), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 232/MUM/2025[1992-1993]Status: DisposedITAT Mumbai17 Oct 2025AY 1992-1993

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 1992-1993 Pratima Hitesh Mehta Vs Deputy Commissioner Of 32, Madhuli Apartment, Income-Tax, Cc -4(1), 3Rd Floor, Dr. A.B Road, Worli, Mumbai Mumbai - 400018 [Pan: Abnpm8226G] Appellant Respondent Present For: Appellant By : Shri Dharmesh Shah & Ms. Mitali Parekh, Advocates Respondent By : Dr. P. Daniel (Special Counsel For Dept.) Date Of Hearing : 29.07.2025 Date Of Pronouncement : 17.10.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of Cit(A)-52, Mumbai, Vide Order No. Itba/Apl/S/250/2024-25/1070774879(1), Dated 29.11.2025 Passed Against The Assessment Order By Deputy Commissioner Of Income-Tax, Cc-4(1), Mumbai, U/S. 144 R.W.S. 254 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 19.07.2024 For Assessment Year 1992-93. 2. Grounds Taken By The Assessee Are Reproduced As Under: 1. The Ld. Cit(A) Has Erred In Law & In Fact In Partly Confirming The Assessment Order Passed U/S. 144 R.W.S. 254 Of The Act Dated 19.07.2024. 2. The Ld. Cit(A) Has Erred In Law & In Fact In Not Quashing The Assessment Order Which Is Time Barred & Hence Void.

For Appellant: Shri Dharmesh Shah and Ms. Mitali Parekh, AdvocatesFor Respondent: Dr. P. Daniel (Special Counsel for Dept.)

Section 132Section 132(4)Section 144Section 220Section 234D

receipt of dividend is merely due to the shareholding of the assessee and interest expenditure has nexus with the income under the head ‘income from other sources’, including dividend income even though not direct. Coordinate Bench, thus directed the ld. AO to allow the interest expenditure claimed by the assessee ... find that the assessee claimed interest on bank loans of Rs. 2,46,33,261 against the income under the head "income from other sources". It is evident from the record that the learned CIT(A) placed reliance upon the decision of the Hon'ble jurisdictional High Court

Subhash Chand Choraria, Guwahati vs. The Assistant Commissioner of Income Tax, Circle - 2, Guwahati

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

ITA 63/GTY/2024[2017-18]Status: DisposedITAT Guwahati16 Oct 2025AY 2017-18

Bench: Shri Manomohan Das & Shri Rakesh Mishra

Section 115BSection 143(2)Section 143(3)Section 250Section 69A

hearing was issued to furnish certain particulars as asked for by the Ld. AO. The assessee had earned income from house property and income from other sources. A sum of ₹37 Lakh was found deposited during the demonetization period and the source of income was from rental income which

Alka Khandaka, Jaipur vs. Income Tax Officer Ward 1(2), Jaipur

In the result, the appeal of the assessee is partly allowed

ITA 1014/JPR/2025[2017-2018]Status: DisposedITAT Jaipur16 Oct 2025AY 2017-2018

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Sauravh Harsh, AdvFor Respondent: Mrs. Anita Rinesh, JCIT

Section 131Section 142(1)Section 143(2)Section 143(3)Section 44ASection 68

further submitted that provisions of Section 115BBE are applicable only on the income which is taxable under the head Income From Other Sources. Since in this case, the source of cash deposit in bank is income from business thus section 115BBE is not applicable. It is further submitted that ... further submitted that provisions of Section 115BBE are applicable only on the income which is taxable under the head Income From Other Sources. Sinza in this use, the source of cash deposit in bank is income. from business thus section 115BBE is not applicable. It is further submitted that

Vipul Kamal Prakash Sud, Sidhpur vs. The Pr. CIT-3, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 841/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad16 Oct 2025AY 2021-22

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2021-22

Section 143(3)Section 263Section 54

case was selected for complete scrutiny under CASS. The assessee had disclosed income from business, income from house property, capital gain and income from other sources. In the course of assessment, the Assessing Officer had examined the capital gain Vipul Kamal Prakash Sud vs. PCIT-3 Page

Base Metal Chemicals, Vadodara vs. The ACIT, Circle-1(3) Now Circle-1(1)(1), Vadodara

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

ITA 361/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad16 Oct 2025AY 2016-17

Bench: The First Appellate Authority Which Was Decided By Ld. Cit(A) Vide The Impugned Order & The Appeal Of The Assessee Was Dismissed.

Section 133(6)Section 143(3)Section 40

evidence on record, the learned NFAC has grievously erred in confirming the addition of Rs.23,94,498/-made as Income from other sources in respect of interest received from partner. (6) That on facts, in law, and on evidence on record, the learned NFAC has grievously erred in confirming ... charged on the debit balance of partners, there was no rational for making separate addition for this amount as income from other source. This addition made by the AO had led to double addition. Since, the assessee had separately charged interest on the debit balance of the partners, the addition

Naresh Bansilal Jain, Mumbai vs. Income Tax Officer, Ward 20(1)(1) Mumbai, Mumbai

In the result, the appeal of the assessee is allowed for 4

ITA 643/MUM/2025[2021-2022]Status: DisposedITAT Mumbai16 Oct 2025AY 2021-2022

Bench: Shri Om Prakash Kant () & Shri Narender Kumar Choudhry () Assessment Year: 2021-22

For Appellant: Mr. Satyaprakash SinghFor Respondent: 04/09/2025

Section 132(4)Section 56(2)(x)

valuation in respect of a flat purchased by the assessee and the consequent addition of consequent addition of ₹64,49,214/- as income from other sources. as income from other sources. 2.1 Briefly stated, the facts are that the assessee, an individual, is riefly stated, the facts are that ... made additions of . The AO has made additions of Rs. 64,49,214/ Rs. 64,49,214/- under head income from other source u/s under head income from other source u/s 56(2)(x) of the IT Act during the year. The contention

Income Tax Officer, Ward 3(1), Kalyan vs. Vitthal Rukmini Sahakari Patpedthi, Kalyan

In the result, appeal of the assessee is allowed and appeal of the revenue is dismissed

ITA 2307/MUM/2025[2017-18]Status: DisposedITAT Mumbai16 Oct 2025AY 2017-18

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri Sushant Alme, A/RFor Respondent: Ms. Kavitha Kaushik, Sr. D/R

Section 194A(3)(v)Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

However, NFAC has wrongly observed that interest on fixed deposit is taxable under the head "Income from Other Sources" eligible for deduction u/s 80P(2)(d) of the Act. 5. On the facts and in the circumstances of the case and in law, the Ld. NFAC has wrongly interpreted provisions

Vitthal Rukmini Sahakari Patpedhi Ltd, Kalyan vs. DCIT Circle 3 Kalyan, Kalyan

In the result, appeal of the assessee is allowed and appeal of the revenue is dismissed

ITA 1570/MUM/2025[2017-18]Status: DisposedITAT Mumbai16 Oct 2025AY 2017-18

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri Sushant Alme, A/RFor Respondent: Ms. Kavitha Kaushik, Sr. D/R

Section 194A(3)(v)Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

Pradeep Kumar Dusad, Jaipur vs. Dy. Commissioner of Income Tax Central Circle-2, Jaipur

47. As a result, ITA No

ITA 722/JPR/2025[2016-17]Status: DisposedITAT Jaipur15 Oct 2025AY 2016-17

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Sh. S. B. Natani, Ld. C.AFor Respondent: Shri Rajesh Ojha, Ld. CIT

Section 10(38)Section 115BSection 132Section 133ASection 143(3)Section 147Section 148Section 150Section 153CSection 250

assessee under section 10(38) of the Act, while holding that an amount of Rs. 44,68,330/-was to be treated as Income from Other sources, for the reasons recorded by him; (ii) of Rs. 89,367/-Relating to Commission paid for acquisition of an accommodation entry, as discussed

Sanjay Kumar Karnani, Jaipur vs. ACIT, Central Circle-3, Jaipur

ITA 675/JPR/2025[2018-19]Status: DisposedITAT Jaipur15 Oct 2025AY 2018-19

Section 153ASection 250Section 68

आIT A Nos.56 to 61/JP/2025 Shri Ambika Garments vs. ACIT आयकर अपीलीय अधिकरण, जयपुर न्यायाधी, जयपुर IN THE INCOME TAX

Sanjay Kumar Karnani, Jaipur vs. ACIT, Central Circle-3, Jaipur

In the result, all appeals of the assessee are disposed off in terms of

ITA 673/JPR/2025[2016-17]Status: DisposedITAT Jaipur15 Oct 2025AY 2016-17

Bench: AO on 12-04-2021 18. Reply filed before AO on 15-07-2021 19. Additional Written Submissions filed before CIT(A) for AY 2014-15 on 11-11-2024 20. Written Submissions filed before CIT(A) for AY 2014-15 21. Written Submissions filed before CIT(A) for AY 2015-16 on 10-10-2024 22. Written Submissions filed before CIT(A) for AY 2016-17 on 10-10-2024 23. Written Submissions filed before CIT(A) for AY 2017-18 on 15-10-2024 24. Written Submissions filed before CIT(A) for AY 2018-19 on 15-10-2024 25.

For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT

Section 153ASection 250Section 68

income is from any particular source. It is for the assessee to prove that even if the cash credit represents income it is income from a source which has already been taxed". As per the headnotes "Section 145 of the Income-tax Act, 1961 [Corresponding to section ... income is from any particular source. It is for the assessee to prove that even if the cash credit represents income it is income from a source which has already been taxed. In the case of Roshan Di Hatti v. Commissioner of Income

Sanjay Kumar Karnani, Jaipur vs. ACIT, Central Circle-3, Jaipur

In the result, all appeals of the assessee are disposed off in terms of

ITA 672/JPR/2025[2015-16]Status: DisposedITAT Jaipur15 Oct 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT

Section 153ASection 250Section 68

Shri Ambica Garments, Jodhpur vs. ACIT, Central Circle-3, Jaipur

In the result, all appeals of the assessee are disposed off in terms of

ITA 61/JPR/2025[2019-20]Status: DisposedITAT Jaipur15 Oct 2025AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT

Section 153ASection 250Section 68

Shri Ambica Garments, Jodhpur vs. ACIT, Cental Circle-3, Jaipur, Jodhpur

In the result, all appeals of the assessee are disposed off in terms of

ITA 59/JPR/2025[2017-18]Status: DisposedITAT Jaipur15 Oct 2025AY 2017-18

For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT

Section 153ASection 250Section 68

Shri Ambica Garments, Jodhpur vs. ACIT, Cental Circle-3, Jaipur

In the result, all appeals of the assessee are disposed off in terms of

ITA 57/JPR/2025[2015-16]Status: DisposedITAT Jaipur15 Oct 2025AY 2015-16

For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT

Section 153ASection 250Section 68

Shri Ambica Garments, Jodhpur vs. ACIT, Cental Circle-3, Jaipur

ITA 56/JPR/2025[2014-15]Status: DisposedITAT Jaipur15 Oct 2025AY 2014-15

For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Alka Gautam, CIT

Section 153ASection 250Section 68

such deemed income is not income from salary, house property, profits and gains of business or profession, or capital gains, nor is it income from 'other sources' because the provisions of sections 69, 69A, 69B, and 69C treat unexplained investments, unexplained money, bullion, etc., and unexplained expenditure as deemed income ... explained or satisfactorily explained. Therefore, in these cases, the source not being known, such deemed income will not fall even under the head, 'Income from other sources'. Therefore, the corresponding deductions, which are applicable to the incomes under any of these various heads, will not be attracted in case

Bhawna Puri, Mandi vs. Income Tax Officer Ward, Mandi

The appeal of the assessee is partly allowed in the above terms

ITA 978/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh15 Oct 2025AY 2017-18

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Vishal Mohan, Sr. Advocate with Shri Parveen Sharma, Advocate (Virtual)For Respondent: Shri Vivek Vardhan, Addl. CIT

Section 115BSection 68

addition of Rs.33,39,000/- made on account of cash deposits in the bank account of the assessee by treating the said income from undisclosed sources. The addition so made by the Ld. Assessing Officer is not sustainable in the eyes of law. 3. That in the facts and circumstances ... case the Ld. Commissioner of Income Tax (Appeals) is not justified upholding the assessment of agricultural receipt of Rs.2,77,472/- as income from undisclosed sources. 4. That the order of the Ld. Commissioner of Income Tax Appeals and Ld. Assessing Officer are bad in law. 2 3. Briefly