“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

Income Tax Officer-4(1), Raipur, Central Revenue Building vs. Mohammad Ibrahim, Prop Janta Sanitation

In the result, this appeal of Revenue is allowed for statistical purposes

ITA 698/RPR/2025[2022-23]Status: DisposedITAT Raipur05 Mar 2026AY 2022-23

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 698/Rpr/2025 (िनधा"रण वष" Assessment Year: 2022-23) Income Tax Officer, Ward - 4(1), Vs Mohammand Ibrahim, Aayakar Bhawan, Civil Lines, Ring Road No. 1, Pachpedinaka Raipur- 492001, C.G. Raipur- 492001, C.G. Pan: Aigpm6755J (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : None राज" की ओर से / Revenue By : Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 06/01/2026 घोषणा की तारीख / Date Of : 05/03/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: The Appeal For Assessment Year (‘Ay’) 2022-23 Filed By The Revenue Is Directed Against The Order Dated 08.09.2025 Of The Commissioner Of Income Tax (Appeals) [Cit(A)], National Faceless Appeal Centre (“Nfac”), Delhi.

For Appellant: NoneFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 132Section 132(4)Section 148Section 69C

allowances/claims/expenditures etc. In section 145(1) of the Act, while making it mandatory to compute the income under head 'business & profession' or 'Income from other sources' based on cash or mercantile system of accounting being regularly followed by the assessee, the word 'shall' have been specifically used to make

Bijay Kumar Garodia, Kolkata vs. DCIT, Central Circle 3(4), Kolkata

In the result, the appeal of the revenue is dismissed

ITA 2938/KOL/2025[2013-2014]Status: DisposedITAT Kolkata05 Mar 2026AY 2013-2014

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 132Section 132(1)Section 143(3)Section 250Section 271A

various seized documents/income arising from errors & omissions Total 5,75,00,000/- 4. The said income was disclosed as income from other sources and no penalty is imposable in terms of Explanation (c) to Section 271AAB. However, the AO levied penalty u/s 271AAB(1)(c) of the Act @ 10% vide ... Bandra Flat and others aggregating to Rs. 5,75,00,000/- while the same was shown in the return of income as income from other sources. The assessee is not maintaining any books of accounts as he is not having business or profession, therefore, the case of the assessee falls

Nagaraju Muniyappa, Kaggalipura Post, Kanakapu Bade Katte vs. Income Tax Officer Ward 7(2)(5), Bangalore, Karnataka

In the result, the appeal is allowed for statistical purposes

ITA 2499/BANG/2025[2016-17]Status: DisposedITAT Bangalore05 Mar 2026AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2016-17

For Appellant: Shri Siddesh Gaddi, CAFor Respondent: Shri Subramanian, JCIT (DR)

Section 144Section 250Section 251(1)(a)

fresh examination after providing due opportunity to the assessee. 4.4 With regard to the addition of ₹97,625 treated as income from other sources on account of interest income, the Ld. CIT(A) observed that the assessee had not furnished any proper explanation or material to rebut the findings

Mamatha Mahesh Shetty, Chikkamagaluru vs. Income Tax Officer, Ward-1, Chikmagalur

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

ITA 2382/BANG/2025[2016-17]Status: DisposedITAT Bangalore05 Mar 2026AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2016-17

For Appellant: Shri Ravishankar S.V, AdvocateFor Respondent: Shri Ganesh R Ghale, Advocate – Standing

Section 250

held that the assessee failed to explain the genuineness of agricultural income through direct evidence. Hence the AO treated the same as income from other sources and levied tax as per the provision of section 115BBE of the Act. 11. The aggrieved assessee preferred to file an appeal before ... evidence such as details of crop pattern, yield, expenses incurred and sale proceeds. Therefore, the AO was justified in treating the same as income from other sources. The learned DR accordingly supported the addition made by the AO and sustained by the learned CIT(A). 16. We have heard

Marigold Meridian Co-Operative Housing Society Ltd, Mumbai vs. ITO Ward, Mumbai

In the result, the appeal of the assessee is allowed for statistical purpose

ITA 9072/MUM/2025[2018-19]Status: DisposedITAT Mumbai05 Mar 2026AY 2018-19

Bench: Shri Rahul Chaudhary & Shri Bijayananda Pruseth

Section 143(1)Section 143(1)(a)Section 2(19)Section 250Section 80P(2)(a)Section 80P(2)(d)Section 80P(4)

Sale Society Ltd. Vs. ITO, 322 ITR 283 (SC) held that interest income earned from deposit of co-operative bank is assessable as “income from other sources” and not business income, and not eligible for deduction u/s 80P(2)(a)(i) of the Act. The CIT(A) held that

Marigold Meridian Co-Operative Housing Society Ltd, Mumbai vs. ITO Ward-41(2)(3), Mumbai

In the result, the appeal of the assessee is allowed for statistical purpose

ITA 9071/MUM/2025[2021-22]Status: DisposedITAT Mumbai05 Mar 2026AY 2021-22

Bench: Shri Rahul Chaudhary & Shri Bijayananda Pruseth

Section 143(1)Section 143(1)(a)Section 2(19)Section 250Section 80P(2)(a)Section 80P(2)(d)Section 80P(4)

Marigold Meridian Co-Operative Housing Society Ltd, Mumbai vs. ITO Ward-41(2)(3), Mumbai

In the result, the appeal of the assessee is allowed for statistical purpose

ITA 9070/MUM/2025[2020-21]Status: DisposedITAT Mumbai05 Mar 2026AY 2020-21

Bench: Shri Rahul Chaudhary & Shri Bijayananda Pruseth

Section 143(1)Section 143(1)(a)Section 2(19)Section 250Section 80P(2)(a)Section 80P(2)(d)Section 80P(4)

Dharmbati, Faridabad vs. Income Tax Inspector Faridabad, Faridabad

In the result, appeal of the assessee is allowed

ITA 5672/DEL/2025[2018-19]Status: DisposedITAT Delhi05 Mar 2026AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2018-19 Dharmbati, Vs. Income Tax Inspector, H. No. 523, Chandawali, Faridabad Ballabhgarh, Faridabad Pan: Azipb6400G (Appellant) (Respondent) Assessee By None Department By Ms. Monika Singh, Cit(Dr) Date Of Hearing 05.03.2026 Date Of Pronouncement 05.03.2026 Order Per Satbeer Singh Godara, Jm This Assessee’S Appeal For Assessment Year 2018-19, Arises Against The Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre [In Short, The “Cit(A)/Nfac”], Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1077406804(1), Dated 23.06.2025 Involving Proceedings Under Section 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’). Case Called Twice. None Appears At The Assessee’S Behest. He Is Accordingly Proceeded Ex-Parte. 2. It Emerges During The Course Of Hearing That The Sole Substantive Issue Between The Parties Is That Of Correctness Of The Learned Lower Authorities’ Action Assessing The Assessee’S Interest Component Of Land Acquisition Compensation U/S 28 Of The Land Acquisition Act, 1894, While Invoking Section 57(Iv) R.W.S. 56(1)(A) R.W.S. 145A(B) Of The Act. 3. Learned Sr. Dr Representing The Department Vehemently Argued That The Instant Issue Is No More Res Integra In Light Of Mahender Pal Narang Vs. Cbdt (2020) 423 Itr 13 (P&H) As Well As Pcit Vs. Inderjit Singh Sodhi Huf (2024) 161 Taxmann.Com 301 (Del.) Wherein The Department Has Succeeded Before Their Lordships That The Impugned Interest Component Ought To Be Assessed As Income From “Other” Sources Only. 4. We Have Given Our Thoughtful Consideration To The Assessee’S Pleadings & Revenue’S Foregoing Vehement Contention. It Emerges That This Tribunal’S Recent Decision In Pawan Kumar Vs. Pcit (2024) 159 Taxmann.Com 61 (Del.-Trib.) Has Distinguished The Said Case Law As Under:

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 263Section 28Section 56(2)(viii)Section 57

taxmann.com 301 (Del.) wherein the department has succeeded before their lordships that the impugned interest component ought to be assessed as income from “other” sources only. 4. We have given our thoughtful consideration to the assessee’s pleadings and Revenue’s foregoing vehement contention. It emerges that this tribunal ... capital receipt' forming part of enhanced compensation as envisaged in section 45(5) of the Act to 'revenue receipt' chargeable to tax as income from other sources. The view taken by the Ld. AO that interest under section 28 of Land Acquisition Act received by the assessee is exempt under

Gopal Reddy Gattu, Hyderabad vs. ACIT., Circle-5(1), Hyderabad

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

ITA 1011/HYD/2025[2021-22]Status: DisposedITAT Hyderabad04 Mar 2026AY 2021-22

Section 143(3)Section 263

total turnover of Rs. 270,73,79,478/-. The A.O. had also made addition of Rs. 4,95,000/- under the head “Income from other sources” towards agricultural income claimed by the assessee. 8. The case has been subsequently taken up for revision proceedings and a show-cause notice under ... estimating net profit of 5% on total turnover and making addition of Rs. 4,95,000/- under the head ‘income from other sources’ towards agricultural income claimed by the assessee. However, while completing the assessment, the A.O. failed to consider the direct and indirect income reported by the assessee

Ravi Vijayalakshmi, Athipattu vs. ITO, Ncw-6(1), Chennai

ITA 2887/CHNY/2025[2016-17]Status: DisposedITAT Chennai04 Mar 2026AY 2016-17

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

For Appellant: Shri. Y. Sridhar, F.C.AFor Respondent: Ms. R. Anitha, Addl. CIT

Section 143(3)Section 271(1)(c)Section 56(2)(vii)

differential value of Rs.2,82,80,000/- was added to the total income and brought to tax as ‘Income from Other Sources’ u/s.56(2)(vii)(b) of the Act by passing an order u/s.143(3) r.w.s 263 of the Act dated 29.03.2022, by arriving at a total income of Rs.3

Ramesh Nanji Gami, Navi Mumbai vs. Assistant Commissioner of Income Tax, Navi Mumbai

In the result, appeal of the assessee is allowed

ITA 6027/MUM/2025[2017-2018]Status: DisposedITAT Mumbai04 Mar 2026AY 2017-2018

Bench: Shri Sandeep Gosain & Shri Omkareshwar Chidara

Section 143(3)Section 250Section 36Section 36(1)Section 57

interest income from capital balance in partnership firm is assessed under the Profit and Gains of business and profession and not under head income from other sources. Appellant contends that NFAC and Ld.AO both have failed to appreciate that once revised return is filed by Appellant, the provision of section ... deduction of Rs. 48,89,313/- u/s 57 of the Act. 4. The AO noticed that there is no nexus with the income from other sources and disallowed the claim of interest. The assessee had strongly contended that the same should have been allowed

Deputy Commissioner of Income Tax, Chennai vs. Olympia Tech Park (Chennai) Private Limited, Chennai

In the result, the appeals of the Revenue for AY 2014-15 & 2015-16

ITA 3084/CHNY/2025[2015-16]Status: DisposedITAT Chennai03 Mar 2026AY 2015-16

Bench: Ms. Padmavathy.S & Shri Manu Kumar Giriआयकर अपील सं./Ita Nos.3081 & 3084/Chny/2025 िनधा#रण वष# /Assessment Years: 2014-15 & 2015-16

For Appellant: Mr. Ajith Kumar Choradia, C.A ()For Respondent: Mr. Bipin C.N, CIT

Section 143(3)Section 250Section 80I

with the arguments of the assessee. 14. Having said so, let us examine, whether entire interest income should be taxed under the head income from other sources. The answer is No, because there is a direct link between the funds utilized for keeping fixed deposits in bank and interest income ... earned from banks. If interest income is to be assessed under the head income from other source, then corresponding interest paid on loan borrowed for the purpose of funds utilized for making fixed deposits also needs to be allowed as deduction. Therefore, we direct the Assessing Officer to exclude interest

Deputy Commissioner of Income Tax, Chennai vs. Olympia Tech Park (Chennai) Private Limited, Chennai

In the result, the appeals of the Revenue for AY 2014-15 & 2015-16

ITA 3081/CHNY/2025[2014-15]Status: DisposedITAT Chennai03 Mar 2026AY 2014-15

Bench: Ms. Padmavathy.S & Shri Manu Kumar Giriआयकर अपील सं./Ita Nos.3081 & 3084/Chny/2025 िनधा#रण वष# /Assessment Years: 2014-15 & 2015-16

For Appellant: Mr. Ajith Kumar Choradia, C.A ()For Respondent: Mr. Bipin C.N, CIT

Section 143(3)Section 250Section 80I

Hotel Maleekara Pattina Souharda Sahakaari Sangha Niyamitha, Tumkur vs. Income Tax Officer, Ward-1 & Tps, Tumkur

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

ITA 1110/BANG/2025[2017-18]Status: DisposedITAT Bangalore03 Mar 2026AY 2017-18

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri A. Shivaram, CA

Section 142(1)Section 143(2)Section 234ASection 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

interest income earned by way of interest on the deposits in the co-operative banks and scheduled banks are to be treated as income from other sources. The AO had relied on some decisions of the Hon’ble High Court and made the assessment by disallowing the claim made

Ambika Laxminiwas Chowdhary, Ahmedabad vs. Income Tax Officer Ward 3(3)(1), Ahmedabad

In the result, the appeal of the assessee is partly allowed for statistical purpose

ITA 1880/AHD/2025[2011-12]Status: DisposedITAT Ahmedabad02 Mar 2026AY 2011-12

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2011-12

For Appellant: NoneFor Respondent: Shri Veerbadram Vislavath, Sr. D.R

Section 132Section 153CSection 68

appellant craves liberty to add, amend or delete any other grounds of appeal.” 3. The assessee is an individual and has income from other sources as well as rent income. The assessee filed return of income on 14-11-2011 declaring total income

Deepak Jayantilal Jain, Mumbai vs. Income Tax Officer 19(1)(1), Mumbai

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

ITA 6766/MUM/2025[2017-18]Status: DisposedITAT Mumbai02 Mar 2026AY 2017-18

Bench: Shri Narender Kumar Choudhryshri Jagadish

For Appellant: Shri Niraj Punamiya (VirtuallyFor Respondent: Shri Annavaram Kosuri (Sr

Section 147Section 250Section 50CSection 69

Rs.1,25,000/- and Rs.1,10,00,000/- on account of variation in the market value and actual consideration of the property being income from other sources u/s 50C and 56(2) of the Act, and unexplained investment u/s. 69 of the Act, respectively. 3. The Assessee being aggrieved against

Kejal Bhavesh Shah, Mumbai vs. Income Tax Officer 19(2)(2), Mumbai

Appeal of the assessee is allowed

ITA 6115/MUM/2025[2018-19]Status: DisposedITAT Mumbai02 Mar 2026AY 2018-19

Bench: Justice (Retd.) C.V. Bhadang & Shri Vikram Singh Yadav.: A.Y. : 2018-19 Kejal Bhavesh Shah Vs. Income Tax Officer 19(2)(2), 207, Shivtirth Bldng. Mumbai 10-12, Sindhi Lane, Near Kumbharwada Mumbai-400 004 Pan : Alfpj9412K (Appellant) (Respondent)

For Appellant: Shri Sambhav ShahFor Respondent: Shri Rajesh Sakhardande, Sr.DR

Section 143(1)Section 143(3)Section 69ASection 80C

short). The appeal relates to A.Y.2018- 19. 2. The appellant is an individual and derives her income from salary and income from other sources. For the relevant year in question, the assessee had declared an income at Rs.1,87,500/- after claiming loss from house property on account of interest

Shri K.P. Magennavar Laxmi Credit Souharda Sahakari Sangh Ltd.Manjari., Chikodi vs. Income Tax Officer, Ward-1, Nippani

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

ITA 33/PAN/2026[2015-2016]Status: DisposedITAT Panaji27 Feb 2026AY 2015-2016

Bench: Shri Pavan Kumar Gadalei T A. No.33/Pan/2026 (A.Y. 2015-16 ) Shri K.P.Magennavar Laxmi Vs I.T.O-Ward-1, Credit Souharda Sahakari Nemchand Building, . Sangh Limited, 747,Ashoknagar, 521,Laxmibuilding,Mainroad, Nipani-591237, Manjari, Chikodi, Karnataka. Belagavi-591213, Karnataka. Pan .No. Aabas3175N (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.Jaykumar Patil.Ar Revenue By Smt.Thamba Mahendra.Sr.Dr सुनवाई की तारीख/Date Of Hearing 25.02.2026 घोषणा की तारीख/Date Of Pronouncement 27.02.2026 Order Per Pavan Kumar Gadale, Jm: The Assessee Has Filed The Appeal Against The Order Of Addl/Jcit(A)-7 Mumbai Passed U/Se 143(3) & U/Sec250 Of The Act. The Assessee Has Raised The Grounds Of Appeal Challenging The Order Of The Cit(A) Sustaining The Denial Of Claim Of Deduction U/Sec80P(2)(A)(I) Of The Ac & Without Prejudice Alternate Relief U/Sec80P(2)(D) Of The Act On Interest Income From Cooperative Banks & Scheduled Banks. 2. The Brief Facts Of The Case Are That, The Assessee Souhard Credit Cooperative Society Is Engaged In Providing

Section 80P(2)(a)Section 80P(2)(d)

investment in non-SLR securities need to be disallowed u/s 57(i) of the Act as interest on non-SLR securities is income from other sources." 2. Clause (id) of sub-section (1) of Section 56 of the Act provides that income by way of interest on securities shall ... chargeable to income tax under the head "Income from Other Sources", if, the income is not chargeable to income-tax under the head "Profits and Gains of Business and Profession". 3. The matter has been examined in light of the judicial decisions on this issue. In the case

Raju Jada, Krishna Dist vs. Income Tax Officer, Ward-1, Machilipatnam

In the result, the appeals of the assessee are allowed for statistical purpose for both the assessment years

ITA 618/VIZ/2025[2022-23]Status: DisposedITAT Visakhapatnam27 Feb 2026AY 2022-23

Bench: the Ld.CIT(A). The Ld.CIT(A) has given five opportunities and also one show cause notice and required the assessee to establish the source of deposits and the amount paid to Gameskraft Technologies Private Limited. At the time of filing of

Section 115BSection 143(3)Section 144BSection 2(24)(ix)Section 69A

above information was shared by Gameskraft Technologies Private Limited. The Ld.AO has mentioned that the said earning /loss falls under the head “income from other sources” as having been earned by way of winnings from lotteries, crossword puzzles, races, games, gambling, betting etc. referred to in section

Raju Jada, Manda Krishna vs. Income Tax Officer, Ward-1, Machilipatanam

In the result, the appeals of the assessee are allowed for statistical purpose for both the assessment years

ITA 617/VIZ/2025[2021-22]Status: DisposedITAT Visakhapatnam27 Feb 2026AY 2021-22

Bench: Shri Ravish Sood, Hon'ble (Judicial Member), Shri Omkareshwar Chidara, Hon'ble (Accountant Member)

Section 115BSection 143(3)Section 144BSection 2(24)(ix)Section 69A