← All Phrases

“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

Shri Lakhbir Singh, Taran Taran vs. Income Tax Officer Ward, Tarn Taran

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

ITA 357/ASR/2024[2013-14]Status: DisposedITAT Amritsar25 Aug 2025AY 2013-14

Bench: Shri Udayan Das Gupta & Shri Brajesh Kumar Singh[Assessment Year: 2013-14]

Section 133(6)Section 142(1)Section 147Section 69A

income amounting to Rs.40,00,211/- as no evidence was submitted and therefore the AO added a sum of Rs.51,99,752/- as ‘Income from Other Sources’ being the agricultural income as well as agricultural expenses claimed by the assessee The AO further added as sum of Rs.57

Kamla Verma, Kanpur vs. ITO-1(2)(2), Kanpur

The appeal of the assessee stands allowed

ITA 364/LKW/2024[2017-18]Status: DisposedITAT Lucknow25 Aug 2025AY 2017-18

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2017-18 Kamla Verma V. The Income Tax Officer 185/7, Vijay Nagar Ward 1(2)(2) Kanpur Kanpur Tan/Pan:Akcpv2921K (Appellant) (Respondent) Appellant By: Shri Rakesh Garg, Advocate Respondent By: Shri Sunil Kumar Rajwanshi, D.R. O R D E R

For Appellant: Shri Rakesh Garg, AdvocateFor Respondent: Shri Sunil Kumar Rajwanshi, D.R
Section 115BSection 144Section 271ASection 69A

amounts received by her on retirement and withdrawn from bank and held a cash, cannot be treated as unexplained and be added as income from other sources, the addition made be deleted. ITA No.364/LKW/2024 Page 4 of 8 03. Because the CIT(A) has failed to appreciate the facts that

Vimal Kumar Banka, Kanpur vs. ITO Ward-1(2)(1), Kanpur

The appeal of the assessee is allowed

ITA 25/LKW/2024[2012-13]Status: DisposedITAT Lucknow25 Aug 2025AY 2012-13

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2012-13 Vimal Kumar Banka V. The Ito 5/P/25, Dabauli Ward 1(2)(1) Kanpur Kanpur Tan/Pan:Afzb1801J (Appellant) (Respondent) Appellant By: Shri Rakesh Garg, Advocate Respondent By: Shri Sunil Kumar Rajwanshi, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against Order Dated 24.11.2023, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2012-13. 2.0 The Brief Facts Of The Case Are That As Per The Assessing Officer (Ao), The Assessee Had Not Filed The Return Of Income For The Year Under Consideration. The Income Tax Department Was In Possession Of Information That The Assessee Had Sold An Immovable Property, Jointly Held With Mrs Kanchan Talwar, During The Year Under Consideration For A Consideration Of Rs.10,00,000/- & The Value Of The Same As Per The Stamp Valuation Authority Was Rs.23,15,000/-. The Assessing Officer (Ao), Therefore, Reopened The Case Of The Assessee Under Section 147 Of The Income Tax Act, 1961 (Hereinafter Called “The Act’)

For Appellant: Shri Rakesh Garg, AdvocateFor Respondent: Shri Sunil Kumar Rajwanshi, D.R
Section 142(1)Section 144Section 144BSection 147Section 148Section 148(2)Section 151

computing the income of the assessee as under: ITA No.25/LKW/2024 Page 3 of 10 Income from salary : Rs.1,29,708/- Income from other sources : Rs.26,237/- Undisclosed income from LTCG : Rs.5,62,730/- Total assessed income : Rs.7,18,675/- 2.1 The AO also initiated penalty proceedings under sections 274 read

Kad Steel Rolling Mills, Ahmedabad vs. Income Tax Officer, Ward - 2, TDS, Ashram Road

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

ITA 652/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad25 Aug 2025AY 2013-14

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Divya Agarwal, ARFor Respondent: Shri Rajenkumar M Vasavda, Sr. DR
Section 119(2)(b)Section 201Section 201(1)

income in it’s return of income. The payees / recipients have taken into account the amount paid by the assessee under the head “income from other sources” in their respective returns of income. The Counsel for the assessee submitted that since the payees / recipients have already offered this income

Kheralu Taluka Primary Teachers Co. Op. Credit Society Niyamit, Mehsana vs. NFAC, Delhi Present Jurisdiction -the ITO, Ward-1, Patan

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

ITA 1235/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad25 Aug 2025AY 2018-19

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Adjournment Application filedFor Respondent: Shri Rajenkumar M Vasavda, Sr. DR
Section 250Section 57Section 80PSection 80P(2)(a)Section 80P(2)(d)

earned from cooperative banks. Subsequently, the assessee submitted a revised computation offering the ₹3,66,426/- interest from nationalized banks under the head "Income from Other Sources" instead of "Profits and Gains from Business," and claimed proportionate administrative expenses of ₹3,16,873 under section ... income of ₹26,31,656 from various banks as not eligible for deduction under Section 80P, and taxed the same under the head "Income from Other Sources." Before ITAT, the assessee submitted that the interest earned was from surplus funds which were deposited to meet the objectives of the society

Bhavesh K Shah, Akota vs. Income Tax Officer Ward 1(2)(1), Alkapuri

In the result, the appeal of the assessee is allowed

ITA 1188/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad25 Aug 2025AY 2014-15

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Manish J Shah & Shri Rushin Patel, ARsFor Respondent: Shri Rajenkumar M Vasavda, Sr. DR
Section 142(1)Section 148Section 249Section 249(3)Section 44A

amount in his return of income, the Bhavesh K Shah vs. ITO Asst. Year –2014-15 - 3– Assessing Officer treated this amount as “income from other sources” and added the same to the total income of the assessee. 4. In appeal, Ld. CIT(A) dismissed the appeal of the assessee ... value of ₹30,14,000/- as undisclosed income (being undisclosed sale consideration) of the assessee and added the same under the head “income from other sources,” on the basis that the sale value of such flat Bhavesh K Shah vs. ITO Asst. Year –2014-15 - 4– was not reflected

Mahavir Inductomelt Pvt. Ltd., Ahmedabad vs. The Dy. CIT, Circle-2(1)(1), Ahmedabad

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

ITA 1068/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad25 Aug 2025AY 2016-17

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri Aseem L Thakkar, ARFor Respondent: Shri Abhijit , Sr DR
Section 115BSection 145Section 147Section 148Section 68Section 80G

Profit and loss account of the appellant as alleged unexplained cash credits u/s.68 of the I.T.Act, 1961 as deemed income under the head Income from other sources by treating it as beneficiary of accommodation entries as against business income offered by assessee company. 6. The learned Commissioner of Income

Mahavir Inductomelt Pvt. Ltd., Ahmedabad vs. The Dy. CIT, Circle-2(1)(1), Ahmedabad

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

ITA 1067/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad25 Aug 2025AY 2015-16

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri Aseem L Thakkar, ARFor Respondent: Shri Abhijit , Sr DR
Section 115BSection 145Section 147Section 148Section 68Section 80G

Profit and loss account of the appellant as alleged unexplained cash credits u/s.68 of the I.T.Act, 1961 as deemed income under the head Income from other sources by treating it as beneficiary of accommodation entries as against business income offered by assessee company. 6. The learned Commissioner of Income

Metso Oyj, Finland vs. Assistant Commissioner of Income Tax, (International Taxation), Circle-1(2), Kolkata

In the result, the appeal filed by the assessee is dismissed and the order of the Ld

ITA 616/KOL/2025[2022-23]Status: DisposedITAT Kolkata25 Aug 2025AY 2022-23

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 143(3)Section 144C(13)Section 144C(5)Section 234BSection 270ASection 56Section 9

proposed on account of guarantee fee from Metso India Pvt. Ltd./Metso Outotec India Pvt. Ltd. (merged entity), as income from other sources. I.T.A. No.: 616/KOL/2025 Assessment Year: 2022-23 Metso OYJ. 5.1 On the 2nd issue of income of bank guarantee fees being business income and not taxable ... evidence provided by the assessee and referred to earlier observations for AY 2013-14 wherein the income from corporate guarantees was categorised as “income from other sources” rather than business income. The Ld. Panel upheld the view that the guarantee provision was not a routine business activity but rather

Vijay Kumar Agarwal (HUF), Kolkata vs. I.T.O., Ward 28(4), Kolkata

In the result, all the seven appeals of the assessee are allowed for statistical purposes

ITA 44/KOL/2025[2015-16]Status: DisposedITAT Kolkata25 Aug 2025AY 2015-16

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 115BSection 142Section 142(1)Section 142(3)Section 143(2)Section 143(3)Section 68

condoned. 3. Brief facts of the case of the assessee are that the assessee derives income from sale of shares and commodities and income from other sources. The assessee filed his return. The case was selected for scrutiny, accordingly, notices u/s 143(2) and u/s 142(1) were issued

Ravi Prabhakar, Chennai vs. ACIT, Ncc-15(1), Chennai

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

ITA 1418/CHNY/2025[2012-13]Status: DisposedITAT Chennai25 Aug 2025AY 2012-13

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.R. Subramanian, CAFor Respondent: Ms. Anitha, Addl.CIT
Section 142(1)Section 143(1)Section 143(3)

Ld.AR, Shri K. Raghavan, CA, filed the details called for. According to the AO, he noticed that the assessee had shown income from other sources to the tune of Ravi Prabhakar :: 4 :: ₹12,15,280/- and claimed expenses like general expenses, salary, travelling & conveyance, and repairs & maintenance

Sevugan Pethaperumal, Madurai vs. PCIT, Madurai-1, Madurai

In the result, the appeal of the assessee is allowed

ITA 1196/CHNY/2025[2020-21]Status: DisposedITAT Chennai25 Aug 2025AY 2020-21

Bench: Shri George George K & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1196/Chny/2025 Assessment Years: 2020-21 Sevugan Pethaperumal, Principal Commissioner Of Income No.41, First Main Street, Tax, Narayanapuram West, Madurai-1, Madurai, Madurai. Tamil Nadu-625 014. [Pan: Afjpp5984J] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Shri G.Tarun, Advocate प्रत्यर्थी की ओर से /Revenue By : Shri Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing : 06.08.2025 घोषणा की तारीख /Date Of Pronouncement : 25.08.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Shri G.Tarun, AdvocateFor Respondent: Shri Bipin C.N, CIT
Section 143(3)Section 263

owner of a property viz PY Mahal situated in Coimbatore and the rent received therefrom have been disclosed under the head income from other sources. The Ld.AO noted that the impugned property was rented out by the assessee to one M/s.Orient Hospital Pvt Ltd and had shown income of Rs.88 ... lakhs as income from other sources. As evident from page 3 of the assessment order, the Ld.AO conducted detailed enquiries between the period 08.12.2021 to 29.08.2022 before concluding that “keeping in view of the above facts and documents filed during the course of assessment proceedings, no adverse inference is drawn

M V Subramanian Family Trust, Chennai vs. ITO, Ncw-1(1), Chennai

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

ITA 1087/CHNY/2025[2021-22]Status: DisposedITAT Chennai25 Aug 2025AY 2021-22

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 1087/Chny/2025 िनधा"रण वष"/Assessment Year:2021-22 M/S. M V Subramanian Family The Income Tax Officer, Trust, Non-Corporate Ward 1(1), 10, Valliammai Achi Road, Vs. Chennai. Kotturpuram, Chennai – 600 085. Pan: Aaetm 9151C (""यथ"/Respondent) (अपीलाथ"/Appellant) अपीलाथ" क" ओर से/Appellant By : Shri Ashwin, Ca ""यथ" क" ओर से/Respondent By : Ms. Anitha, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 24.07.2025 घोषणा क" तारीख/Date Of Pronouncement : 25.08.2025

For Appellant: Shri Ashwin, CAFor Respondent: Ms. Anitha, Addl.CIT
Section 111ASection 112ASection 143(1)Section 154Section 2Section 234BSection 234C

that the assessee is a private discretionary trust and is an India Tax resident. The assessee trust has income from capital gains and income from other sources. The assessee trust has filed its return of income for the relevant ITA. No:1087/Chny/2025 assessment year on 18.11.2021 declaring an income

Kalyanasundaravalli Premanandhan, Chennai vs. ITO, Non Corp. Ward 8(2) Che, Chennai

Appeal of the assessee is allowed

ITA 1051/CHNY/2025[2017 - 2018]Status: DisposedITAT Chennai25 Aug 2025

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.1051/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 V. Kalyanasundaravalli Premanandhan, The Ito, 52/A1, Amaravathy Nagar, Non-Corporate Ward-8(2), Chennai-600 106. Chennai.

For Appellant: Mr.J. Saravanan, AdvocateFor Respondent: Ms.Anitha, Addl.CIT
Section 139(1)Section 143(2)Section 69A

income for the AY 2017-18 on 25.07.2017, declaring a total income of Rs.3,82,610/- which comprised of income from salary' and 'income from other sources' (interest income). 2. During the financial year 2015-16 (AY 2016-17), the appellant was trying to purchase an agricultural land and hence

Mr. Dilip Marutirao Kalyankar, Mumbai vs. Income Tax Officer International Taxation Ward 3(1)(1), Mumbai

In the result, the appeal is allowed as indicated above

ITA 983/MUM/2025[2016-17]Status: DisposedITAT Mumbai25 Aug 2025AY 2016-17

Bench: Shri Saktijit Dey, Vp & Shri Girish Agrawal, Am Dilip Marutirao Kalyankar Ito, International Taxation – C/O. Umesh Kalyankar, 2F-1501, 3(1)(1) Room No. 608, 6Th Floor, Sapphire Lakeside Chs, Vs. Off Jvlr, Next To Union Of India Kautilya Bhavan, C-41 To C-43, Bldg., Powai, Mumbai-400 072 G Block, Bandra Kurla Complex, Bandra (E), Mumbai-400 051 Pan/Gir No. Ahopk 3818 M (Appellant) : (Respondent)

For Appellant: Shri Madhur Agrawal &For Respondent: Shri Krishna Kumar (Sr. DR)
Section 139(1)Section 147Section 148Section 69

under: (ii) New evidence submitted in respect of addition proposed to be made of Rs. 1,56,16,214/-under the head Income from Other sources: The assessee purchased a flat from Neptune Developers for an amount of Rs. 1,46,18,514/- The assessee has paid consideration

Kamalnayan Investment and Trading Private Limited., Mumbai vs. Deputy Commissioner of Income Tax, Circle 3(2)(1), Mumbai

ITA 3593/MUM/2025[2015-16]Status: DisposedITAT Mumbai25 Aug 2025AY 2015-16

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Ms. Vasanti Patel & Shri M.A.GohelFor Respondent: Shri Bhagirath Ramawat
Section 14ASection 250Section 263

INR.86,04,222/- [INR.16,862 + INR.83,85,100 + INR.2,02,260/-] was claimed by the Assessee to be taxable under the head Income from Other Sources. After disallowing INR.3,333/- under Section 14A of the Act from the aforesaid income, the Assessee claimed that the balance amount of INR.86

Jigar Nemichand Sanghavi, Mumbai vs. Assistant Commissioner of Income Tax, Circle -19(1), Mumbai

In the result the appeal filed by the assessee allowed

ITA 3857/MUM/2024[2019-20]Status: DisposedITAT Mumbai25 Aug 2025AY 2019-20

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 10Section 143(2)Section 37Section 56Section 57Section 80CSection 80D

allowable. 7.3.4 The case laws relied upon by the appellant are in regard to the interest expenditure incurred towards earning the Income from other sources, however in the instant case the facts are entirely different as the borrowed loan(to whom Interest payment claimed as Interest Expenditure) are wholly ... expense under section 57 of the Act and the same was set off against interest income of Rs.28,77,987/-under the head income from other sources. 5. The Ld.AR submitted breakup of parties to whom interest was paid. 6 ITA 3857/Mum/2024; A.Y. 2019-20 Jigar Nemichand Sanghavi Name

Subir Mandal, Jamshedpur vs. ITO Ward 3(4), Chaibasa, Jamshedpur

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

ITA 188/RAN/2025[2017-18]Status: DisposedITAT Ranchi22 Aug 2025AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Ratnesh Nandan Sahayi.T.A. No. 188/Ran/2025 Assessment Year: 2017-2018 Subir Mandal,….…………………………………..Appellant 61, Parsudih, Pramathanagar, Jamshedpur-831001, Jharkhand [Pan:Anfpm1717N] -Vs.- Income Tax Officer,……………………………...Respondent Ward-3(4), Chaibasa, 47, Ch Area, Jamshedpur-831001, Jharkhand Appearances By: Shri Akshay Ringasia, A.R., Appeared On Behalf Of The Assessee Shri Khubchand T. Pandya, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: July 21, 2025 Date Of Pronouncing The Order: August 25, 2025 O R D E R

Section 142(1)Section 143(1)Section 148Section 56(2)(vii)

Rs.3,48,260/- on 27.07.2017 for AY 2017-18, which has been processed under section 143(1) on 19.10.2017. The assessee has shown income from other sources at Rs.42,587/-. The case of the assessee was selected for reassessment proceeding under section 148. However, notice u/s 148 and subsequent notices

Harpreet Kaur, Bhopal vs. Income-Tax Officer, 5(2), Bhopal

ITA 730/IND/2024[2009-10]Status: DisposedITAT Indore22 Aug 2025AY 2009-10

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

Section 131Section 133(6)Section 142(1)Section 143(2)Section 147Section 148Section 54Section 69A

आयकरअपीलीयअधिकरण,इंदौर न्यायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT MEMBER AND

S.G.& Co., Solapur vs. ACIT, Central Circle 2(2), Pune

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

ITA 1611/PUN/2024[2018-19]Status: DisposedITAT Pune22 Aug 2025AY 2018-19
For Appellant: Shri Pratik SandbhorFor Respondent: Shri Akhilesh Srivastva
Section 115BSection 133ASection 139Section 143(3)Section 154Section 69A

clearly held the investment in excess stock has to be brought to tax under the head “business income” but not under the head “income from other sources”. The Mumbai Benches of the Tribunal in the case of Govind Godomal Lulla (supra) held undisclosed investment in the case of excess stock