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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

The Sonikampa Group Seva Sahakari Mandali Limited, Arvalli vs. Tha ITO, Ward-1, Modasa

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

ITA 1341/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad23 Sept 2025AY 2018-19

Bench: Shri Siddhartha Nautiyal, Judicial Member\nAnd Shri Narendra Prasad Sinha, Accountant Member\nITA No. 1341/Ahd/2025\nAssessment Year 2018-19\nThe Sonikampa Group\nSeva Sahakari\nMandali Ltd.\nMarket Yard, Talod\nRoad Dhansura,\nArvalli-383310,\nGujarat, India\nPAN:AAAJT1386N\n(Appellant)\nThe ITO,\nWard-1, Modasa\nVs\n(Respondent)\nAssessee Represented: Shri M.K. Patel, Advocate\nRevenue Represented: Shri Suresh Chand Meena, Sr.D.R.\nDate of hearing : 27-08-2025\nDate of pronouncement : 23-

Section 143(3)Section 80PSection 80P(2)(d)

from bank deposits and dividend was not from members or domestic companies, the AO treated this income of Rs.3,13,020/- as income from other sources and disallowed the deduction under section 80P of the Act. 4. In appeal, CIT(Appeals) dismissed the appeal of the assessee, with the following ... operative banks/commercial banks and other financial institution is not being attributable to main business of the appellant hence d be assessed as 'income from other sources and not as 'business profits. 5. 6. Accordingly, the observations and the findings of the AO appear to be in order which does

Shri Mahaveer Nagari Sahakari Pat San Kini, Maharashtra vs. Income Tax Officer Ward-1 Ichalkaranji, Ichalkaranji

In the result, the appeal filed by the assessee is allowed as per terms indicated above

ITA 1990/PUN/2025[2020-21]Status: DisposedITAT Pune23 Sept 2025AY 2020-21

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: NoneFor Respondent: Shri Harish Bist
Section 143(3)Section 250Section 80PSection 80P(2)(d)

eligible for deduction u/s.80P of the Act for the interest income earned from Cooperative Banks and added it under the head ‘Income from Other Sources’ and assessed the income at Rs.16,67,198/-. 5. Thereafter, assessee preferred appeal before ld.CIT(A). However, inspite of submissions filed by the assessee ... disallowed the interest income of Rs.1,63,98,998/- earned out of the Fixed deposits/Investments made with Cooperative Banks treating the same as Income from Other Source. Ld.CIT(A) dismissed the appeal in limine without discussing anything on merits of the issues and on the ground that the assessee

Dr. Pratap Pandhiranath Patil, Pune vs. PCIT - 2, Pune

In the result, the appeal filed by the assessee is allowed as per terms indicated above

ITA 1026/PUN/2025[2020-21]Status: DisposedITAT Pune23 Sept 2025AY 2020-21

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri A.V.Iyer and Shri Siddhant G. BiswasFor Respondent: Shri Amit Bobde
Section 143(3)Section 263Section 263(1)

Rs.38,46,424/- and unexplained Agricultural Expenditure at Rs.4,36,820/- has been wrongly added by the ld. Assessing Officer by treating as ‘Income from Other Sources’ rather than making addition for the sum invoking u/s.68 and 69C r.w.s.115BBE of the Act. 6. Brief facts of the case are that ... unexplained Agricultural Income at Rs.38,46,424/- and also 5 Dr. Pratap Pandharinath Patil disallowed Agricultural Expenses at Rs.4,36,820/- as ‘Income from Other Sources’ and assessed income at Rs.47,66,534/-. 7. Thereafter, ld. Principal Commissioner of Income-tax (PCIT) called for the assessment records and issued show

Deputy Commissioner of Income Tax, Nungambakkam vs. Sathyabama Ramachandran, Alwarthirunagar

The appeal of the revenue is dismissed

ITA 821/CHNY/2025[2017-18]Status: DisposedITAT Chennai23 Sept 2025AY 2017-18

Bench: SHRI MANU KUMAR GIRI (Judicial Member), SHRI S.R. RAGHUNATHA (Accountant Member)

For Appellant: Shri A. Raghava Simhan, C.AFor Respondent: Ms. Gouthami Manivasam, JCIT
Section 147Section 148

Assessing Officer added this amount to the income of the assessee, considering it as "Goodwill" receipt, which is included in the income from "Other Sources." 5. During the reassessment proceedings, the assessee contended that this sum was received for the reduction in the profit-sharing ratio and not as goodwill ... hence, should not be treated as income from other sources. The CIT(A) in his ruling, agreed with the assessee’s contention, stating that such receipt does not amount to goodwill under the provisions of the Income Tax Act and should not be included in the total income

Sri Venugopalakrishna Credit Cooperative Society Limited, Bangalore vs. Income Tax Officer, Ward-5(2)(4), Bangalore

In the result, the appeals filed by the assessee are partly allowed for statistical purposes

ITA 1313/BANG/2025[2011-12]Status: DisposedITAT Bangalore23 Sept 2025AY 2011-12

Bench: Shri Laxmi Prasad Sahuassessment Year : 2011-12 Sri Venugopalakrishna Credit Co-Operative Vs. Ito, Society, Ward – 5(2)(4), No.123/3, 9Th Cross, 2Nd Main Chamajpet, Bangalore. Bangalore – 560 018. Pan :Aabas 6974 R Appellant Respondent Assessee By : Shri. H. Guruswamy, Itp Revenue By : Shri. Ganesh R. Ghale, Advocate, Standing Counsel For Revenue. Date Of Hearing : 10.09.2025 Date Of Pronouncement : 23.09.2025

For Appellant: Shri. H. Guruswamy, ITPFor Respondent: Shri. Ganesh R. Ghale, Advocate, Standing Counsel for Revenue
Section 148Section 250Section 57Section 80PSection 80P(2)(a)Section 80P(2)(d)

that the entire amount of Rs. 18,59,846/- earned by the assessee which was held to be income chargeable under the head income from other sources and therefore, not eligible for deduction u/s 80P(2)(a)(i) shall also not be eligible for deduction ... well established in law that an assessee is entitled to deduct the expenses incurred in earning income taxable under the head "Income from Other Sources." Such a deduction is allowable under the provisions of Section 57 of the Act. Considering this legal position, we agree with the arguments advanced

Shri Jamanlal N Gulati HUF, Mumbai vs. ACIT, 20(2), Mumbai

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

ITA 4691/MUM/2025[2013-14]Status: DisposedITAT Mumbai23 Sept 2025AY 2013-14

Bench: Shri Om Prakash Kant & Shri. Raj Kumar Chauhan

Section 142(1)Section 143(2)Section 250Section 54Section 54F

brief facts as culled out from the proceedings of authorities below are that the assessee is an HUF deriving income from business and income from other sources. The return of income for the assessment year under appeal was e-filed on 20.09.2013 showing total income

Shirguppi Sugar Works Limited, Belagavi vs. Income Tax Officer, Ward - 1(1), Belgaum

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

ITA 252/PAN/2025[2012-13]Status: DisposedITAT Panaji22 Sept 2025AY 2012-13

Bench: Shri Pavan Kumar Gadalei T A. No.252/Pan/2025 (A.Y. 2012-13) Shirguppi Sugar Works Vs Ito-Ward-1(1), Limited, Feroj Khimjibhai Cpx, No.62,Ambi Galli, Civil Hospital Road At Post- Manjari, Belagavi-590001. Tal Chikodi, Karnataka. Belagavi-591213, Karnataka.

raised the grounds of appeal challenging the order of CIT(A) sustaining the addition of interest on fixed deposits and weighment charges under income from other sources made by the assessing officer. 2. The brief facts of the case are that, the assessee company is engaged in the business ... operative expenses. But the A.O. is of the view that the interest income earned during the preproduction period should be taxed under income from other sources and in reply the assesse has filed the submissions vide letter dated 19.08.2014 substantiating the claim of setoff of interest income on fixed deposits

Bishnu Charan Panda, Puri vs. Assessment Unit, Delhi

In the result, both appeals of the assesee are partly allowed for

ITA 15/CTK/2025[2018-2019]Status: DisposedITAT Cuttack22 Sept 2025AY 2018-2019

Bench: SHRI GEORGE MATHAN (Judicial Member)

For Appellant: Shri Chitrasen Parida, AdvocateFor Respondent: Shri Vijay Singh, Sr. DR
Section 44A

additions in the form of cash deposit during the demonetization period has also been disallowed and there has been addition under the head income from other sources. 3. In reply, ld. Sr. DR submitted that he had no objection if the issues are restored to the file ... assessment year 2017- 2018 added the cash deposited during the demonetization period. There has also been certain addition on account of income from other sources. Admittedly, the turnover of the assesee is in excess of Rs.2 crores. Obviously, the provisions of Section 44AD of the Act would not apply. Even

Bishnu Charan Panda, Puri vs. Income Tax Officer, Puri

In the result, both appeals of the assesee are partly allowed for

ITA 14/CTK/2025[2017-2018]Status: DisposedITAT Cuttack22 Sept 2025AY 2017-2018

Bench: SHRI GEORGE MATHAN (Judicial Member)

For Appellant: Shri Chitrasen Parida, AdvocateFor Respondent: Shri Vijay Singh, Sr. DR
Section 44A

additions in the form of cash deposit during the demonetization period has also been disallowed and there has been addition under the head income from other sources. 3. In reply, ld. Sr. DR submitted that he had no objection if the issues are restored to the file ... assessment year 2017- 2018 added the cash deposited during the demonetization period. There has also been certain addition on account of income from other sources. Admittedly, the turnover of the assesee is in excess of Rs.2 crores. Obviously, the provisions of Section 44AD of the Act would not apply. Even

Shri Vishwakarama Jewellers, Akola vs. DCIT Akola Circle, Akola

In the result, assessee’s appeal is allowed

ITA 99/NAG/2025[2017-18]Status: DisposedITAT Nagpur22 Sept 2025AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri K.M. Roy, Accountant, Member

For Appellant: Shri S.G. GandhiFor Respondent: Shri Surjit Kumar Saha
Section 115BSection 133ASection 143(3)Section 69B

declaration of additional income of ` 85,00,000 was part of its business income. The Assessing Officer held this additional income as income from undisclosed sources under section 69B of the Act. Accordingly, the Partners' remuneration was reduced proportionately. Further, the Assessing Officer taxed the income under section ... section 14-(1) 'salary', (ii) income from house property, (iii) 'profits and gains from business or profession', (iv) 'capital gains' and (v) 'income from other sources cannot at all be adjusted against unexplained investment or expenditure. What is necessary as per Hon'ble Gujarat High Court is that source

Nirmalkumar Agrawal HUF, Nagpur vs. Income Tax Officer, Ward-2, Bhandara

In the result, assessee’s appeal stands allowed

ITA 242/NAG/2025[2018-19]Status: DisposedITAT Nagpur22 Sept 2025AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Rohan Loya a/wFor Respondent: Shri Pankaj Kumar
Section 139(1)Section 143(1)(a)Section 144BSection 147Section 148Section 263

under section 139(1) of the Act on 25.08.2018 disclosing total income of ` ` 2,60,860, which includes income from capital gain and income from other sources. The Finance Intelligence Unit (FIU) had credible information which indicated that Navdurga Advisory Private Limited (NAPL) was a shell company and consequent

DCIT Akola Circle, Akola vs. The Akola Janata Commercial Co-Operative Bank Ltd., Akola

In the result, Revenue’s appeal is dismissed

ITA 189/NAG/2025[2020-21]Status: DisposedITAT Nagpur22 Sept 2025AY 2020-21

Bench: Shri Narender Kumar Choudhry & Shri K.M. Roy, Accountant, Member

For Appellant: Shri S.G. GandhiFor Respondent: Shri Pankaj Kumar
Section 143(1)Section 143(3)Section 147Section 154

respect of its 8 The Akola Janata Commercial Co–operative Bank Ltd. ITA no.189/Nag./2025 income assessable as business income and not as income from other sources if it carries on business of the banking or providing credit facilities to its members and has income assessable under the head business

Anita Sharma, Shimla vs. Income Tax Officer, Ward- Shimla

The appeal stand allowed for statistical purposes

ITA 808/CHANDI/2025[2015-16]Status: DisposedITAT Chandigarh22 Sept 2025AY 2015-16

Bench: SHRI LALIET KUMAR (Judicial Member), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Sh. Sudhir Sehgal (Advocate) – Ld. ARFor Respondent: Dr Ranjit Kaur (Addl. CIT) – Ld. Sr. DR
Section 143(3)

days in the appeal which stand condoned. In the assessment order, Ld. AO made addition of Rs.2.25 Lacs under the head ‘income from other sources’. The Ld. CIT(A) confirmed the same for want of any representation from the assessee. Aggrieved, the assessee is in further appeal before

Radhey Shyam Garments, Chandigarh vs. The Income Tax Officer Ward3(3) Chd Jao ITO Ward 2(1) Chandigarh, Chandigarh

The appeal stand allowed for statistical purposes

ITA 800/CHANDI/2025[2016-2017]Status: DisposedITAT Chandigarh22 Sept 2025AY 2016-2017

Bench: SHRI LALIET KUMAR (Judicial Member), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Sh. Sudhir Sehgal (Advocate) – Ld. ARFor Respondent: Dr Ranjit Kaur (Addl. CIT) – Ld. Sr. DR
Section 143(3)

days in the appeal which stand condoned. In the assessment order, Ld. AO made addition of Rs.2.25 Lacs under the head ‘income from other sources’. The Ld. CIT(A) confirmed the same for want of any representation from the assessee. Aggrieved, the assessee is in further appeal before

Shree Datta Nagari Sahakari Pat Sanstha, Sangli vs. ITO Ward-5, Sangli

In the result, both the appeals of the assessee for AY 2018-19 (ITA

ITA 626/PUN/2025[2018-19]Status: DisposedITAT Pune22 Sept 2025AY 2018-19

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Sarang S. GudhateFor Respondent: Shri Ramnath P. Murkunde
Section 139(1)Section 142(1)Section 56Section 80Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)Section 80P(4)

mutuality. The assessee is squarely hit by many judicial pronouncements where the Apex Court also held that the income is taxable as "Income from other sources and taxable accordingly. Reliance is placed on the Supreme Court decision in case of Totagar's Co-operative Sale Society Ltd. (Supra ... Rs.1,56,70,940/-is not eligible for deduction u/sec. 80P of the I.T. Act, 1961 and is required to be treated as Income from Other Sources. Accordingly, the claim of deduction u/s 80P is withdrawn to the extent of Rs.1,56,70,940/- and added to the total income

Shree Datta Nagari Sahakari Pat Sanstha, Sangli vs. ITO Ward-5, Sangli

In the result, both the appeals of the assessee for AY 2018-19 (ITA

ITA 625/PUN/2025[2020-21]Status: DisposedITAT Pune22 Sept 2025AY 2020-21

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Sarang S. GudhateFor Respondent: Shri Ramnath P. Murkunde
Section 139(1)Section 142(1)Section 56Section 80Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)Section 80P(4)

mutuality. The assessee is squarely hit by many judicial pronouncements where the Apex Court also held that the income is taxable as "Income from other sources and taxable accordingly. Reliance is placed on the Supreme Court decision in case of Totagar's Co-operative Sale Society Ltd. (Supra ... Rs.1,56,70,940/-is not eligible for deduction u/sec. 80P of the I.T. Act, 1961 and is required to be treated as Income from Other Sources. Accordingly, the claim of deduction u/s 80P is withdrawn to the extent of Rs.1,56,70,940/- and added to the total income

Rahul Arunkumar Pandit, Pune vs. DCIT, Circle 3, Pune

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

ITA 1926/PUN/2025[2017-18]Status: DisposedITAT Pune22 Sept 2025AY 2017-18

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1926/Pun/2025 िनधा"रण वष" / Assessment Year : 2017-18 Rahul Arunkumar Pandit, Vs. Dcit, Circle-3, Pune. Flat No.-5, Gopadma No.39, Plot No.18, Prabhat Road, Lane No.9, Pune- 411004. Pan : Abypp1142R Appellant Respondent Assessee By : None Revenue By : Shri Manishkumar Sinha Date Of Hearing : 18.09.2025 Date Of Pronouncement : 22.09.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 17.06.2025 Passed By Ld. Addl./Jcit(A)-1, Kolkata [‘Ld. Cit(A)’] For The Assessment Year 2017-18. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1] The Ld. Jcit(A) Has Erred In Confirming The Assessed Income Of The Appellant At Rs. 55,36,400/-. The Additions Made Without Considering The Fact Of The Case Are Illegal & Unsustainable In Law & The Same May Please Be Deleted. 2] The Ld. Jcit(A) Has Erred In Dismissing The Case Ex-Parte Without Waiting For Appellant To Furnish The Submission & Evidences. The Ld. Jcit(A) Ought To Have Appreciated That The Appellant Could Not Respond To The Notices, As He Has Changed His

For Appellant: NoneFor Respondent: Shri Manishkumar Sinha
Section 143(3)Section 57

partner in the firm Pandit Javdekar Associates and apart from above is also in receipt of income from house property and income from other sources i.e. interest from the parties. The case was selected for limited scrutiny under CASS for the reason of large deduction claimed ... that the assessee could not prove in his submission that the deduction u/s 57 claimed by him is for the purpose of earning income from other sources, hence the deduction u/s 57 of interest payment of Rs.25,93,670/- was disallowed and added back to the total income

Manicam Narayanan, Chennai vs. ACIT, Ncc-20(1), Chennai

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

ITA 1975/CHNY/2025[2017-18]Status: DisposedITAT Chennai22 Sept 2025AY 2017-18

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Mr. V. Balaji, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 139Section 139(1)Section 142(1)Section 144Section 148Section 69A

from House Property of Rs.1,.03,16,886/-, Capital gains of Rs.3.50 Crores, Profits and gains from business/Profession of Rs.65,61,000/- and Income from Other Sources of Rs.4,10,476/- and made a addition. In addition, the assessee deposited SBNs to the tune of Rs.48

Meeran Abdul Zahid, Bellary vs. DCIT, Circle-1, Bellary

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

ITA 835/BANG/2025[2015-16]Status: DisposedITAT Bangalore22 Sept 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2015-16

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Sri Ganesh R. Ghale, Standing Counsel for Department
Section 250Section 69A

total cash deposited of Rs. 30,50,000/- as unexplained cash deposits u/s 69A of the Act and added as Income under head “Income from other sources”. Further, we also take note of the fact that during the appellate proceedings, the assessee could not submit any response despite four opportunities

Vilasben Purohit, Mumbai vs. Income Tax Officer 42(1)(5), Mumbai

ITA 4879/MUM/2025[2016-2017]Status: DisposedITAT Mumbai22 Sept 2025AY 2016-2017

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2016-17 Vilasben Purohit, Ito 42(1)(5), A 404, Snehal Tower, Sayar Pada, Kautilya Bhavan, Bandra Kurla Borivali, Vs. Complex, Mumbai-400066. Mumbai-400051. Pan No. Aqqpp 6847 J Appellant Respondent

For Appellant: Ms. Kavitha Kaushik, Sr. DRFor Respondent: Mr. Ashish Thakurdesai
Section 148Section 148ASection 234ASection 234BSection 69

income In response, the assessee filed her return of income In response, the assessee filed her return of income on 12.04.2023 declaring income from other sources of ₹4,01,250/-. 12.04.2023 declaring income from other sources of 12.04.2023 declaring income from other sources of Thereafter, notice under section