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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

Waseem Alam, West Champaran vs. ITO, National E Assessment Centre, Delhi

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

ITA 17/PAT/2025[2018-19]Status: DisposedITAT Patna22 Jul 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.17/Pat/2025 Assessment Year: 2018-19 Waseem Alam…...………………….....…..…………………....Appellant Bhawanipur Kursi Barawa, Sikta, West Champaran, Bihar-845307. [Pan: Alopa0369B] Vs. Ito, Nfac, Delhi…………..……….…............................…..…..... Respondent Appearances By: Shri Sanjeev Kr. Anwar, Advocate, Appeared On Behalf Of The Appellant. Shri Ashwani Kumar, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 17, 2025 Date Of Pronouncing The Order : July 22, 2025 आदेश / Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 08.11.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For The Assessment Year 2018-19 Declaring Total Income Of Rs.9,68,550. The Return Was Processed Under Section 143(1) Of The Act. Subsequently, The Case Was Selected For Limited Scrutiny Under The E- Assessment Scheme, With The Specific Issue Of Verification Of Large Deduction Claimed Under Section 57 Of The Act. Notice Under Section 143(2) & Subsequently Under Section 142(1) Was Issued To The Assessee. Although The Assessee Uploaded Certain Documents Electronically In Response, The Details Were Found To Be Incomplete. The

Section 142(1)Section 143(1)Section 143(2)Section 250Section 57

expenses of Rs.58,83,717 under Section 57 of the Act and offered the net income of Rs.5,84,517 under the head "Income from Other Sources." The assessee also prepared a Profit and Loss Account in respect of the auto fuel business, wherein it had shown business income

Amballur Service Co Operative Bank Limited No 503, Mannampetta, Thrissur vs. Income Tax Officer, Thrissur

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

ITA 79/COCH/2025[2020-2021]Status: DisposedITAT Cochin22 Jul 2025AY 2020-2021

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm Assessment Year: 2020-21 Amballur Service Co-Op. Bank Ltd. .......... Appellant 6/325, Varakkara, Mannampetta, Trissur 680325 [Pan: Aacaa2779B] Vs. The Income Tax Officer, Ward-2(1) Thrissur .......... Respondent Appellant By: Shri M. Ramdas, Ca Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 10.06.2025 Date Of Pronouncement: 22.07.2025 O R D E R Per: Inturi Rama Rao, Am This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 29.11.2024 For Assessment Year (Ay) 2020-21. 2. Brief Facts Of The Case Are That The Appellant Is A Co-Operative Society Registered Under The Kerala State Co-Operative Societies Act, 1969. It Is Classified As A Primary Agricultural Credit Co-Operative Society. It Is Engaged In The Business Of Accepting Deposits From Members & Lending Money To Members For Agricultural & Allied Activities. The Appellant Filed Return Of Income For Ay 2020-21

For Appellant: Shri M. Ramdas, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)

Bank/State Co-operative Bank, in the facts and circumstances of the case, do come within Section 80P(2)(d). Therefore, the income constitutes income from other sources and the only eligible deduction is covered by Section 80P(2)(d) viz. Interest or dividend derived by the assessee from its investments

Patteppadam Rural Cooperative Society Ltd, Thrissur vs. ITO, Ward-2, Thrissur

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

ITA 392/COCH/2025[2020-21]Status: DisposedITAT Cochin22 Jul 2025AY 2020-21

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm Assessment Year: 2020-21 Patteppadam Rural Cooperative Society Ltd. .......... Appellant Kottanellur P.O., Thrissur 680662 [Pan: Aaaap3007B] Vs. The Income Tax Officer, Ward 2(1), Thrissur .......... Respondent Appellant By: Shri C.A. Jojo, Advocate Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 05.06.2025 Date Of Pronouncement: 22.07.2025 O R D E R Per: Inturi Rama Rao, Am This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 17.12.2023 For Assessment Year (Ay) 2020-21. 2. Brief Facts Of The Case Are That That Appellant Is A Co-Operative Society Registered Under The Kerala State Co-Operative Societies Act, 1969. It Is Classified As A Primary Agricultural Credit Co-Operative Society. The Return Of Income For Ay 2020-21 Was Filed On 13.02.2021 Disclosing Total Income Of Rs. 85,810/- After Claiming

For Appellant: Shri C.A. Jojo, AdvocateFor Respondent: Smt. Leena Lal, Sr. D.R
Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(i)

available. Accordingly, denied deduction of interest income of Rs. 3,47,17,257/- by holding that such income is assessable under the head ‘income from other sources’. 3. Being aggrieved, an appeal was filed before the CIT(A), who vide the impugned order directed the AO to allow deduction

Albert Joseph Rozario, Mumbai vs. ITO, Int. Tax, Circle 4(1)(1), Mumbai

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

ITA 1168/MUM/2025[2018-19]Status: DisposedITAT Mumbai22 Jul 2025AY 2018-19

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2018-19 Albert Joseph Rozario, Ito, (Int. Tax), Circle-4(1)(1), B-311, 5Th Wing, Room No. 629, 6Th Floor, Inlaks Park, Vs. Kautilya Bhavan, Yari Road, Versova, C-41 To C-43, G Block, Andheri West, Bandra Kurla Complex, Mumbai-400058 Bandra East, Pan : Afvpr6139P Mumbai-400051 (Appellant) (Respondent) For Assessee : Shri Dharan Gandhi For Revenue : Shri Sridhar G. Menon, Sr.Dr Date Of Hearing : 01-05-2025 Date Of Pronouncement : 22-07-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Final Assessment Order Passed By The Assessing Officer U/S 147 R/W 144C(13) Of The Act Dt. 30-12-2024, Consequent To The Directions Given By The Ld. Drp-1, Mumbai-3, U/S 144C(5) Of The Act, Dated 30-11-2024 Pertaining To Assessment Year (Ay.) 2018-19. 2. Briefly The Facts Of The Case Are That Basis Information Available Through The Insight Portal That The Assessee Had Purchased Immoveable Properties Amounting To Rs. 8,31,45,549/- & Has Received Interest

For Appellant: Shri Dharan GandhiFor Respondent: Shri Sridhar G. Menon, Sr.DR
Section 144C(1)Section 144C(5)Section 147Section 148Section 148ASection 56(2)(x)Section 69

being the difference between stamp duty value and the purchase consideration and treated as income of the assessee under the head „income from other sources‟ u/s. 56(2)(x) of the Act. 5. Against the draft order passed u/s. 144C(1) of the Act, dt. 21-03- 2024, the assessee ... wherein the unexplained investment of Rs 4,47,74,410/- was brought to tax on protective basis u/s. 69 of the Act and income from other sources of Rs 1,03,53,786/- was also brought to tax as originally done in the draft assessment order as so confirmed

Shri Jivico Karmachari Co-Operative Credit Society Limited, Rajkot, Gujarat vs. Income Tax Officer, Ward 2(1)(1), Rajkot, Gujarat

In the result, appeal filed by the assessee is allowed

ITA 48/RJT/2025[2017-18]Status: DisposedITAT Rajkot21 Jul 2025AY 2017-18

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos.48/Rjt/2025 ("नधा"रण वष" /Assessment Year: (2017-18) Shri Jivico Karmachari Co- Income Tax Officer, Operative Credit Society Ltd. Ward-2(1)(1), Rajkot, Aayakar Vs. Bhawan, Race Course Ring Road, Jivan Prakash, Mahila College Rajkot-360 001 Chowk, Tagore Marg, Rajkot-360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaoas 6270 K (अपीलाथ" /Appellant) (""यथ" /Respondent) "नधा"रती क" ओर से /Assessee By : Shri Krutarth Desai, Ar राज"व क" ओर से /Revenue By :Shri Abhimanyu Singh Yadav, Sr-Dr सुनवाई क" तार"ख/ Date Of Hearing : 03/07/2025 घोषणा क" तार"ख/Date Of Pronouncement : 21/07/2025 आदेश / O R D E R Per Dr. A.L. Saini, A.M:

For Appellant: Shri Krutarth Desai, ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr-DR
Section 142(1)Section 143(3)Section 250Section 56Section 80P(2)(a)Section 80P(2)(d)

booked out of the excess/surplus fund the assessee the interest income on FDs is required to be treated under the head "Income from Other Source" u/s 56 of the Act and not eligible for deduction u/s 80P(2)(a)(i) of the Act.” 3. Considering the above facts, Ld. Counsel ... paper book),and the amount of Rs.18,41,436/- is show by the assessee, in the computation of total income, under the head income from other sources, and claimed the deduction u/s 80P(2)(d) of the Act, at Rs.18,41,436/-. The assessee has also shown, under the head

ITO, Statue Circle, Jaipur vs. Sangeeta Gangwal, Kirti Nagar, Tonk Road

Appeal is hereby dismissed

ITA 304/JPR/2025[2012]Status: DisposedITAT Jaipur21 Jul 2025

Bench: SHRIGAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR, JM आयकर अपीलसं. / ITA No. 304/JPR/2025 निर्धारण वर्ष / AssessmentYear : 2012-13 Income Tax Officer War-6(4), Jaipur. बनाम Sangeeta Gangwal Vs. B-159, Kirti Nagar, Tonk Road, Jaipur. प्रत्यर्थी / Respondent स्थायीलेखा सं. / जीआईआरसं./PAN/GIR No.:AIAPG9939J अपीलार्थी / Appellant निर्धारिती की ओर से / Assessee by : Shri Tarun Mittal, C.A. राजस्व की ओर से / Revenue by: Mrs. Anita Rinesh, JCIT, Sr. DR सुनवाई की तारीख / Date of Hearing :21

For Appellant: Shri Tarun Mittal, C.AFor Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR
Section 133(6)Section 143(2)Section 148Section 250Section 68

total income, annexed to ITR for the said assessment year, the assessee 7 Sangeeta Ganwal, Jaipur reflected in para 1.5 under the head “income from other sources” a sum of Rs. 1,50,375/- towards F & O profit . As per computation of total income, under the head “income from other ... statement of all the bank accounts which are being maintained by you in the current year. 3. Please submit the details of income from other sources of Rs 2,61,566/- submitting the relevant documents/evidences for verification of the same.” 8 Sangeeta Ganwal, Jaipur 13. In her response dated