“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

Nisha Data Com Limited, Rourkela vs. Income Tax Officer Ward-3 Rourkela, Rourkela

In the result, both the appeals filed for AY 2011-12 and AY 2012-

ITA 174/CTK/2025[2012-13]Status: DisposedITAT Cuttack25 Jul 2025AY 2012-13

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 133BSection 144Section 250Section 40

deleted. 3. For that the addition of Rs.90,20,461.00 by rejecting the Assessee's explanation and making the addition as income from other sources as interest income, is totally unjustified and illegal and is liable to be annulled. 4. For that the disallowance of expenditure of Rs.5 ... loss on sale of investment and ₹90,20,461/- as interest as income from other sources were added and the total income was computed at ₹3,33,86,590/-. Aggrieved with the assessment order, the assessee filed an appeal before the Ld. CIT(A) who issued several notices of hearing

Nisha Data Com Limited, Rourkela vs. Income Tax Officer Ward-3 Rourkela, Rourkela

In the result, both the appeals filed for AY 2011-12 and AY 2012-

ITA 173/CTK/2025[2011-12]Status: DisposedITAT Cuttack25 Jul 2025AY 2011-12

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 133BSection 144Section 250Section 40

Nanesh Finance Corporation, Hyderabad vs. DCIT, Central Circle-1(2), Hyderabad

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

ITA 86/HYD/2025[2019-20]Status: DisposedITAT Hyderabad25 Jul 2025AY 2019-20

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: CA Maheswar ReddyFor Respondent: Shri Gurpreet Singh, Sr. AR

Section 133ASection 142(1)Section 143(2)Section 143(3)Section 271ASection 69A

assessee, made addition of Rs.1,73,40,790/- as unexplained money u/sec.69A r.w.s.115BBE of the Act by treating the amount under the Head ‘Income from other sources” instead of ‘Business 5 ITA.No.86/Hyd./2025 Income’ offered by the assessee. The Assessing Officer accordingly, determined the total income of the assessee ... Rs.1,80,60,350/- by making addition of Rs.1,73,40,790/- under the Head ‘Income from other sources’ and also initiated penalty proceedings u/sec.271AAB of the Income Tax Act, 1961 vide order dated 21.04.2021 passed u/sec.143(3) of the Income Tax Act, 1961. On being aggrieved by the assessment

Syed Zahed Ali, Hyderabad vs. ITO., Ward-14(1), Hyderabad

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

ITA 474/HYD/2025[2017-18]Status: DisposedITAT Hyderabad25 Jul 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.474/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2017-18) Shri Syed Zahed Ali, Income Tax Officer, Vs. Ward-14(1), Hyderabad. Hyderabad. Pan: Aifpa6433J (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri Y.V. Bhanu Narayan Rao, C.A. रधजस् व द्वधरध/Revenue By: Sumitha Parmata, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 22/07/2025 घोर्णध की तधरीख/Pronouncement: 25/07/2025 आदेश/Order Per Madhusudan Sawdia, A.M. : This Appeal Is Filed By Shri Syed Zahed Ali (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”), Dated 05.02.2025 For The A.Y. 2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal :

For Appellant: Shri Y.V. Bhanu Narayan RaoFor Respondent: Sumitha Parmata, SR-DR

Section 115BSection 133(6)Section 142(1)Section 143(2)Section 144Section 234Section 234BSection 250Section 69A

from the said business ITA No.474/Hyd/2025 3 receipts is already disclosed in the ROI filed for the AY 2017-18 under the head Income from Other Sources. 6. On the facts and in the circumstances of the case, the learned CIT (A), NFAC, Delhi erred in upholding the erroneous demand ... filed his return of income for the Assessment Year 2017–18 on 01.12.2017, declaring total income of Rs.6,50,000/- under the head “income from other sources”. The case of the assessee was selected for limited scrutiny under CASS for the purpose of examining the sources of cash deposits, services

Nishant Chennadi, Hyderabad vs. ACIT., Central Circle-2(3), Hyderabad

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

ITA 470/HYD/2025[2020-21]Status: DisposedITAT Hyderabad25 Jul 2025AY 2020-21

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: CA, C. Maheswar ReddyFor Respondent: Shri Gurpreet Singh, Sr. AR

Section 115BSection 132Section 139(1)Section 143(2)Section 143(3)Section 153ASection 69A

assessment year 2020-2021. 2. Brief facts of the case are that, the assessee is an individual and derives income from salary and income from other sources. The assessee had filed his original return of income u/sec.139(1) of the Income Tax Act, 1961 [in short ... assessee filed his return of income on 19.11.2021 declaring total income of Rs.33,46,130/- which comprises of income from salary and income from other sources. During the course of assessment proceedings, the Assessing Officer issued notices u/sec.143(2) and 142(1) of the Act and duly served upon

Shri Mahaveer Co-Operative Credit Society Ltd, Alagur vs. Income Tax Officer, Alagur

ITA 6/BANG/2025[2016-17]Status: DisposedITAT Bangalore25 Jul 2025AY 2016-17

Bench: Shri Prashant Maharishi

Section 143(2)Section 143(3)Section 18Section 40Section 80PSection 80P(2)(a)Section 80P(2)(d)

business and Profession" and or under section 80 P (2)(d) if it is investments income chargeable to tax under the head ' income from Other sources

Bollera Uthappa Muddappa, Bengaluru vs. Income Tax Officer, Ward-4(1)(3), Bengaluru

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

ITA 368/BANG/2025[2020-21]Status: DisposedITAT Bangalore25 Jul 2025AY 2020-21

Bench: Shri Prashant Maharishiassessment Year : 2020-21

For Appellant: Ms. Sunaina Bhatia, CAFor Respondent: Shri Ganesh R. Ghale, Advocate, Standing Counsel for Dept

Section 143(2)Section 143(3)

individual who is an agriculturist growing raw coffee seeds and black pepper. He is also earning income from letting out of property and income from other sources. Assessee filed return of income on 19.8.2021 at a total income of Rs.4,25,960 and showing net agricultural income of Rs.31 ... income of Rs.57,03,340 amounting to Rs.14,25,835 was disallowed and added to the total income of assessee under the head ‘income from other sources’. Accordingly assessment order was Page 3 of 5 passed on 10.9.2022 determining total income of assessee at Rs.18,51,795. 5. Assessee aggrieved

Income Tax Officer Ward-28(5), Delhi vs. Rajender, Delhi

In the result, appeal of the revenue is dismissed

ITA 3477/DEL/2024[2018-19]Status: DisposedITAT Delhi25 Jul 2025AY 2018-19

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Assessment Year: 2018-19] Income Tax Officer, Shri Rajender, Ward 28(5), Room No. 1202, 448, Chauhan Mohalla, Block E, Civic Centre, Vs Madanpura Khadar, Sarita Delhi 110002 Vihar, Delhi - 110076 Pan- Avqpr9368B Revenue Assessee Revenue By Shri Rajesh Kumar Dhanesta, Sr. Dr Assessee By Shri Om Prakash Tiwari, Ca Date Of Hearing 22.07.2025 Date Of Pronouncement 25.07.2025 Order Per Manish Agarwal, Am, This Appeal By The Revenue Is Directed Against The Order Of The Commissioner Of Income Tax, National Faceless Appeal Centre, Delhi [Cit(A), In Short], Dated 30.04.2024 In Appeal No. Nfac/2017-18/10229136 For Assessment Year 2018-19, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) Arising Out Of The Assessment Order Dt. 20.03.2023 Passed U/S 147/144 Of The Act.

Section 115BSection 147Section 148Section 148ASection 250Section 69

provision of section 115BBE of the Act are invoked; 3. Interest received of Rs.1,93,496/- from Punjab and Sindh Bank taxed as income from other sources. 3. Against this order, assessee preferred an appeal before the ld. CIT(A) and filed additional evidence in support of the claim alongwith

Manoj Chadha, Delhi vs. ACIT Cir 31(1), Civic Centre

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

ITA 3563/DEL/2023[AY 2014-15]Status: DisposedITAT Delhi25 Jul 2025

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshmanoj Chadha, Vs. Acit, W-16/19, Western Avenue, Circle-31(1), Sainik Farms, New Delhi New Delhi (Appellant) (Respondent) Pan:

For Appellant: Shri Manoj Kumar, CAFor Respondent: Sh. Dheeraj Kumar Jain, Sr. DR

Section 133(6)Section 143(3)Section 41(1)Section 68

filed by the assessee on 21.11.2014 declaring total income of Rs. 21,82,210/-. The assessee had declared business income and income from other sources. During the year under consideration, the assessee has shown Rs. 3,12,66,909/- as sundry creditors in its balance sheet. The ld AO asked

Income Tax Officer, Sikar vs. Bhaskar Chauhan, Jaipur

In the result the appeal of the revenue in ITA no

ITA 868/JPR/2024[2017-18]Status: DisposedITAT Jaipur24 Jul 2025AY 2017-18

Bench: Him.

For Appellant: Shri S.L.Poddar, AdvFor Respondent: Mrs Alka Gautam, CIT-DR a

Section 143(3)Section 144Section 153CSection 251Section 69Section 69ASection 69C

comments/explanation regarding the amount received from entry provider namely Divyanshi Coroporation & Shiv Trading Company. Therefore, Rs.1,57,50,000/- was treated as income from undisclosed sources u/s 69A of the Act on substantive basis. The ld. AO also noted that a commission of Rs.2.5% has been paid to obtain ... assessee, the commission on accommodation entries is worked out at Rs.3,93,750/- (1,57,50,000 x 2.5%) and treated as income from undisclosed sources u/s 69C of the Act. As noted by the ld. AO that the transactions of the bank account (Bank account No.916020049304891 Axis Bank

Bhaskar Chouhan, Jaipur vs. Income Tax Officer, Sikar

ITA 533/JPR/2024[2017-18]Status: DisposedITAT Jaipur24 Jul 2025AY 2017-18

For Appellant: Shri S.L.Poddar, AdvFor Respondent: Mrs Alka Gautam, CIT-DR

Section 143(3)Section 144Section 153CSection 251Section 69Section 69ASection 69C

comments/explanation regarding the amount received from entry provider namely Divyanshi Coroporation & Shiv Trading Company. Therefore, Rs.1,57,50,000/- was treated as income from undisclosed sources u/s 69A of the Act on substantive basis. The Id. AO also noted that a commission of Rs.2.5% has been paid to obtain ... assessee, the commission on accommodation entries is worked out at Rs.3,93,750/- (1,57,50,000 x 2.5%) and treated as income from undisclosed sources u/s 69C of the Act. As noted by the Id. AO that the transactions of the bank account (Bank account No.916020049304891 Axis Bank

Omprakash Daruka, Raniganj vs. ITO, Ward 3(1), Asansol

In the result, appeal of the assessee is allowed

ITA 685/KOL/2025[2013-2014]Status: DisposedITAT Kolkata24 Jul 2025AY 2013-2014

Bench: Shri George Mathanआयकर अपील सं/Ita No.685/Kol/2025 (नििाारण वर्ा / Assessment Year :2013-2014) Omprakash Daruka, Vs Ito, Ward-3(1), Asansol C/O S.N.Ghosh & Associates, Advocates, 2, Garstin Place, 2Nd Floor, Suite No.203, Off Hare Street Kolkata-700001 Pan No. : Acqpd 1122 L (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) : Shri Somnath Ghosh, Ar नििााररती की ओर से /Assessee By राजस्व की ओर से /Revenue By : Shri Shankar Naskar, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 24/07/2025 घोषणा की तारीख/Date Of Pronouncement : 24/07/2025 आदेश / O R D E R

For Respondent: Shri Shankar Naskar, Sr. DR

Section 147Section 148Section 148(2)Section 149Section 151

Income filed by the assessee, it is found that the assessee has disclosed income from business & profession amount to Rs.2,55,874/- and income from other sources amount to Rs.58,578/-in its return of income for the A.Y.2013-14. It is evident from the records that the assessee had claimed

Satbichar Distributors Private Limited, Kanpur vs. ITO, Ward 3(1), Kolkata

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

ITA 448/KOL/2025[2013-14]Status: DisposedITAT Kolkata24 Jul 2025AY 2013-14

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 147Section 250

NFAC has erred in law and on the facts of the ease by making addition of Rs. 80,00,000/- under the head income from other sources. 2.1) That the Ld. CIT(A) has erred in law and on facts in sustaining the impugned assessment order ignoring the fact that ... amount received was filed, therefore, the I.T.A. No.: 448/KOL/2025 Assessment Year: 2013-14 Satbichar Distributors Private Limited. same was treated as income from other sources and added to the income of the assessee. Aggrieved with the assessment order, the assessee filed an appeal before the Ld. CIT(A) who vide

Aa520 Veerampalayam Pacs Ltd., Erode vs. ITO, Ward-2(1), Erode

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

ITA 593/CHNY/2025[2020-21]Status: DisposedITAT Chennai24 Jul 2025AY 2020-21

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:593/Chny/2025 िनधा"रण वष" / Assessment Year: 2020-21 Aa520 Veerappampalayam Ito, Primary Agricultural Co-Operative Vs. Ward -2 (1), Society Ltd., Erode. 1, Aa520, Veerappampalayam, Veerappampalayam Bo, Attavanai Hanumanpalli, Erode – 638 101. [Pan:Aadaa-8893-M] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Appellant By : Ms. G. Vardini Karthik, Advocate ""थ" की ओर से/Respondent By : Shri. Kumar Chandan, Jcit (Virtual)

For Appellant: Ms. G. Vardini Karthik, AdvocateFor Respondent: Shri. Kumar Chandan, JCIT (Virtual)

Section 119(2)(b)Section 139(1)Section 139(4)Section 2(6)Section 80PSection 80P(2)(a)Section 80P(2)(d)

operational income’ of assessee- society from providing credit facilities to its members only. Consequently, the interest income has to be treated as ‘income from other sources’ and also the assessee is not eligible for deduction u/s.80P of the Act. Respectfully following all of the aforesaid legal precedents. I hold that ... claimed under chapter- VI-A of the act is disallowed to the extent of Rs.42,23,180/- and the same is considered as income from ‘other source’ u/s.56 of the Act 1956. 4. Aggrieved by the order passed by the AO, the assessee preferred an appeal before the ld.CIT

Assistant Commissioner of Income Tax, Central Circle - 2(4), Bengaluru, Bangalore vs. M/S Mrk Gold LLP, Bangalore

ITA 1026/BANG/2025[2020-21]Status: DisposedITAT Bangalore24 Jul 2025AY 2020-21

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan Kassessment Year : 2020-21

For Appellant: Shri. Narendra Kumar J Jain, AdvocateFor Respondent: Shri. R. Rajamanohar, JCIT(DR)(ITAT), Bangalore

Section 115BSection 133ASection 143(1)Section 69B

conducted on 04/01/2018 and the excess stocks were found of Rs. 2,50,51,072/- . During the assessment AO treated the same as Income from other source and applied sec. 69 of the Act. The CIT(A) has allowed the appeal of the assessee by observing that ... Therefore, the investment in the excess stock has to be brought to tax under the head "Business Income" and not under the head "Income from Other Sources" and provisions of Section 69/115BBE would accordingly be not applicable. 14.2 Even in the statement recorded u/s 133A on 04.01.2018 from the appellant

Mr Chetnarayan Sitaram Singh, Mumbai vs. Income Tax Officer-Ward-41(4)(1), Mumbai

In the result, the appeal is allowed for statistical purposes

ITA 317/MUM/2025[2018-2019]Status: DisposedITAT Mumbai24 Jul 2025AY 2018-2019

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Ms. Dinkle Hariya,ARFor Respondent: Mr. Virabhadra S. Mahajan (Sr. DR)

Section 144Section 56(2)Section 56(2)(x)

Chetnarayan Sitaram Singh value of the document executed by the Appellant and the consideration as mentioned therein as ‘Income from Other Sources’. 4.2 While doing so, the Ld. CIT (A) erred in confirming the action of the A.O. in: (i)The case of the Appellant did not fall within ... treating the difference between the stamp duty value of the document executed by the assessee and the consideration as mentioned therein as ‘Income from Other Sources’. In the subsequent appeal, the ld.CIT(A) observed that the appellant did not submit any details in the appellate

Dosti Realty Limited, Mumbai vs. DCIT, Circle-1(1)(1), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 6130/MUM/2024[2014-15]Status: DisposedITAT Mumbai24 Jul 2025AY 2014-15

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawalassessment Year: 2014-15

For Appellant: Shri Vijay Mehta, CAFor Respondent: Shri Bhangepatil Pushkaraj, Sr. DR

Section 143(3)Section 14A

already been claimed as deduction while computing the income under the head ‘profits and gain from business or profession’ or under the head ‘income from other sources’ which forms part of its books of accounts. In this respect, according to the ld. Assessing Officer, investments made by the assessee

Shailendra Gala Navneet Trust, Mumbai vs. Deputy Diretor of Income Tax Ward 22(2)(1), Mumbai

In the result, the appeal of the assessee in assessment year

ITA 4355/MUM/2024[2022-23]Status: DisposedITAT Mumbai24 Jul 2025AY 2022-23

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary ()

For Appellant: Mr. Pravin Salunkhe, Sr. DRFor Respondent: Mr. Sanjay Parikh

Section 143(1)

consisting primarily of interest income taxable , consisting primarily of interest income taxable , consisting primarily of interest income taxable under the head "Income from Other Sources." The said return was under the head "Income from Other Sources." The said return was under the head "Income from Other Sources." The said return

Shailendra Gala Navneet Trust, Mumbai vs. Deputy Director of Income Tax Ward 22(2)(1), Mumbai

In the result, the appeal of the assessee in assessment year

ITA 4354/MUM/2024[2023-24]Status: DisposedITAT Mumbai24 Jul 2025AY 2023-24

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary ()

For Appellant: Mr. Pravin Salunkhe, Sr. DRFor Respondent: Mr. Sanjay Parikh

Section 143(1)

Kamlesh Khanna, New Delhi vs. ACIT, Circle-40(1), New Delhi

In the result, the appeal of the assessee in ITA No

ITA 7841/DEL/2019[2015-16]Status: DisposedITAT Delhi24 Jul 2025AY 2015-16

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Salil Kapoor, Adv &For Respondent: Ms. Harpreet Kaur Hansra, Sr. DR

Section 143(1)Section 143(3)Section 54

Briefly stated, the facts of the case are that the assessee derived income from capital gains and income from other sources. The assessee e-filed his return of income for the A.Y under consideration declaring income of Rs. 24,51,630/- on 30.03.2016 which was processed