“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

Gauri Sagar Shivale, Pune vs. ITO Ward 8(3), Pune

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

ITA 101/PUN/2025[2014-15]Status: DisposedITAT Pune21 Jul 2025AY 2014-15

Bench: Shri Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.101/Pun/2025 धििाारण वर्ा / Assessment Year : 2014-15 Gauri Sagar Shivale, Income Tax Officer, S. No. 32/4, Nimbalkar Nagar, Ward – 8(3), Pune Brt Road, Near Rajiv Gandhi Vs. College, Tathawade, Mulshi, Pune-411033 Pan : Bjipp4685G अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Nikhil S. Pathak Department By : Shri Ramnath P. Murkunde Date Of Hearing : 15-05-2025 Date Of 21-07-2025 Pronouncement :

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Ramnath P. Murkunde

Section 142(1)Section 144BSection 147Section 148Section 156Section 2(47)Section 249Section 249(4)Section 249(4)(b)Section 80T

relevant AY 2014-15, the assessee filed her return of income on 30.03.2016 declaring total income of Rs.2,98,672/-comprising of income from other sources. The Ld. Assessing Officer (“AO”) was in receipt of certain information in respect of receipt of security deposit of Rs. 59,96,966/- pursuant ... furnished a belated return of 2 ITA No.101/PUN/2025, A.Y. 2014-15 income on 03.02.2023 declaring gross total income of Rs.3,28,120/-. As income from other sources after claiming deduction u/s 80TTA of Rs.10,000/-. 2.1 During the course of the reassessment proceedings, the Ld. AO made enquiry about

ACIT, Central Circle-2(3), Pune vs. Subhash Jivraj Jain, Pune

In the result, the appeal filed by the Revenue is dismissed and the CO filed by the assessee is allowed

ITA 1690/PUN/2024[2017-18]Status: DisposedITAT Pune21 Jul 2025AY 2017-18

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2017-18

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Akhilesh Srivastva, Addl.CIT

Section 131Section 132Section 143(2)Section 153C

assessment year 2017-18. The Assessing Officer made substantive addition of Rs.1,05,50,000/- in the hands of assessee as ‘income from other sources’ and also another addition of Rs.1,05,50,000/- on protective basis by observing as under: “09. To sum up the things, the seized documents ... Substantive addition of Rs.1,05,50,000/- is hereby made in the hands of Shri. Subhash Jivraj Jain as income from other sources. However, if the appellate 6 CO No.29/PUN/2025 authorities decide that, the interest received in cash by Shri. Ramesh Ghanshyam Shah from the Yuvraj Dhamale group on behalf

Indian National Congress All India Congress Committee, New Delhi vs. DCIT, Central Circle-19, New Delhi

ITA 1609/DEL/2023[2018-19]Status: DisposedITAT Delhi21 Jul 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri M. Balaganesh

Section 139Section 139(1)Section 139(4)Section 13ASection 143(3)

these provisions: - Any income of a political party which is chargeable under the head "Income from house property" or "Income from other sources" or "Capital gains" or any income by way of voluntary contributions received by a political party from any person shall not be included in the total income ... reason that contributions/donation received by a political party in violation of provisions of section 13A of the Act is taxable as income from other source and therefore expenses incurred by the political party in achievement of its objective are not allowable as deduction. Similar view was taken

Danda Nagendra Kumar, Guntur vs. Income Tax Officer, Ward-2(3), Guntur

In the result, appeal filed by the assessee is allowed for statistical purposes as indicated herein above

ITA 306/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam18 Jul 2025AY 2017-18

Bench: the Tribunal. In respect of belated filing of the appeal, the assessee filed an affidavit dated 08/07/2025 seeking condonation of delay wherein the assessee had explained the reasons that prevented him in filing the appeal within the prescribed time limit. For the sake of ready reference, the relevant paras from the said affidavit are extracted as under:

Section 133(6)Section 142(1)Section 143(2)Section 143(3)

accept the submission of the assessee and made an addition of Rs. 63,53,788/- towards unexplained money under the head “income from other sources”. Thus, the Ld. AO determined the total income of the assessee at Rs. 71,31,300/- and passed the order

Mandir Shri Falodi Mata Ji Maharaj Samiti, Kota vs. Income Tax Officer Exemption Ward, Kota

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

ITA 421/JPR/2025[2014-15]Status: DisposedITAT Jaipur18 Jul 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Shrawan Kumar Gupta, AdvocateFor Respondent: Shri Ajey Malik, CIT-DR (Thru’ V.C.)

Section 147Section 148Section 234A

account of alleged fund transfer and Rs.12,00,000/- on account of alleged FDRS totaling to Rs.60,71,129/- as income from other sources as protective addition in the hands of the assessee made by the Id. AO, also erred in not considering the material available on record in their ... been received by the assessee without any consideration is treated and considered as income of the assessee chargeable to tax under the head income from other sources and accordingly added to the total income of the assessee for the year under consideration. However, as per information provided by the Investigation

Bimal Kumar Drolia, Howrah vs. ITO, Ward-43(2), Kolkata

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

ITA 347/KOL/2024[2009-10]Status: DisposedITAT Kolkata18 Jul 2025AY 2009-10

Bench: Sri Pradip Kumar Choubey & Sri Rakesh Mishra

Section 143(2)Section 147Section 147(6)Section 148Section 250Section 34

confirmed Page 9 of 19 I.T.A. No.: 347/KOL/2024 Assessment Year: 2009-10 Bimal Kumar Drolia. by Commissioner (Appeals) under section 68 as 'income from other sources' and under section 68 the unexplained credit in books is treated as income. [Para 20] ■ Although it was the case of the respondent-assessee

Ganapathi Seetharam Hegde, Karnataka vs. Addl/JCIT (A)-1, Chennai

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

ITA 1446/CHNY/2025[2017-18]Status: DisposedITAT Chennai18 Jul 2025AY 2017-18

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1446/Chny/2025 Assessment Years: 2017-18

For Appellant: Mr.Bhragu.K.R, C.AFor Respondent: Ms.R.Anitha, Addl.CIT

through its grounds of appeal is regarding the addition of Rs.15,82,851/- made by the Ld.AO by treating its agricultural income as income from other sources and its corresponding confirmation by the Ld.CIT(A). The Ld.AR submitted that admittedly the assessee could not make compliance to the notices

Kalpana Ravikumar, Chennai vs. ITO, Ncw-8(40, Chennai

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

ITA 1320/CHNY/2025[2012-13]Status: DisposedITAT Chennai18 Jul 2025AY 2012-13

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.1320/Chny/2025 िनधा"रण वष"/Assessment Year: 2012-13 Kalpana Ravikumar, Vs. The Income Tax Officer, No. 78, Block 2, 2Nd Floor, Non Corporate Ward 8(4), Bbc City Paark, No. 76, Anna Salai, Chennai. Chinna Porur, Chennai 600 116. [Pan:Aiupr6455L] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Raghav Rajeev Menon, Advocate ""थ" की ओर से/Respondent By : Ms. V. Supraja, Addl.Cit सुनवाई की तारीख/ Date Of Hearing : 16.07.2025 घोषणा की तारीख /Date Of Pronouncement : 18.07.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 20.02.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2012-13. 2. We Find That This Appeal Is Filed With A Delay Of 372 Days. The Assessee Filed An Affidavit For Condonation Of Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said Affidavit As 2

For Appellant: Shri Raghav Rajeev Menon, AdvocateFor Respondent: Ms. V. Supraja, Addl.CIT

Section 148Section 250Section 54

confirmed the addition made on account of long term capital gains at ₹.1,33,74,455/-. With regard to the addition towards income from other sources, considering the submissions of the assessee, the ld. CIT(A) directed the Assessing Officer to verify the interest income as per 26AS and adopt

Marathwada Nagari Sahakari Path Sanstha Maryadit, Kalyan vs. Assessing Officer, Ward 1(1), Kalyan

In the result, appeal of the assessee is allowed

ITA 3346/MUM/2025[2020-21]Status: DisposedITAT Mumbai18 Jul 2025AY 2020-21

Bench: Ms. Kavitha Rajagopal & Shri Prabhash Shankarmarathwada Nagari Sahakari V/S. Assessing Officer, Ward – Path Sanstha Maryadit, बनाम 1(1), Mohan Plaza, Wayle Shop No. 06, 1St Floor, Nagar, Khadakpada, Kalyan Dhamnikar Plaza, Bhiwandi, – 421301, Maharashtra Thane – 421302, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaaam9150E Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Sushant Alme, ARFor Respondent: Shri Vivek Perampurna, (CIT- DR)

Section 143(3)Section 263Section 56Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

claimed by the Appellant Society u/s 80P(2) of the Act and tax the same u/s 56 of the Act under the head “Income from Other Sources”. P a g e | 3 A.Y. 2020-21 Marathwada Nagari Sahakari Path Sanstha Maryadit 3. Brief facts of the case are that ... Finance Act, 2015 w.e.f. 01.06.2015 excluding the co-operative banks from the genus categories of cooperative societies and making it liable to deduct Income tax at source on the interest paid by it to other persons, further indicates that the legislative intent is to exclude co-operative banks from

Veej Company Sevakanchi Sahakari Path Sanstha Ltd., Kalyan vs. Assessing Officer, Ward 3(1), Kalyan

In the result, appeal of the assessee is allowed

ITA 3341/MUM/2025[2020-21]Status: DisposedITAT Mumbai18 Jul 2025AY 2020-21

Bench: Ms. Kavitha Rajagopal & Shri Prabhash Shankarveej Company Sevakanchi V/S. Assessing Officer, Ward – Sahakari Path Sanstha बनाम 3(1), Rani Mansion, 2Nd Ltd.,Shramik Sahakar, Usha Floor, Kalyan Murbad Road, Sankul Valiper Road, Oak Thane - 421 301, Baug, Thane - 421301, Maharashtra Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaaam2266M Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Sushant Alme,ARFor Respondent: Shri Vivek Perampurna (CIT - DR)

Section 143(3)Section 263Section 56Section 80PSection 80P(2)Section 80P(2)(a)

claimed by the Appellant Society u/s 80P(2) of the Act and tax the same u/s 56 of the Act under the head “Income from Other Sources”. 3. Brief facts of the case are that the assessee, a Cooperative Society filed its return of income for the declaring income ... Finance Act, 2015 w.e.f. 01.06.2015 excluding the co-operative banks from the genus categories of cooperative societies and making it liable to deduct Income tax at source on the interest paid by it to other persons, further indicates that the legislative intent is to exclude co-operative banks from

Neha Haresh Bohra, Mumbai vs. ITO Ward 19(2)(4), Mumbai

In the result, appeal of the assessee is allowed

ITA 111/MUM/2025[2018-19]Status: DisposedITAT Mumbai18 Jul 2025AY 2018-19

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2018-19 Neha Haresh Bohra Income Tax Officer, 52/52A Nanubhai Desai Road, Ward- 19(2)(4), Islampura Street, Mumbai Vs. Mumbai – 400004 Maharashtra (Pan: Aadpk6695C) (Appellant) (Respondent) Present For:

For Appellant: Shri Vimal Sethiya, CAFor Respondent: Shri. Abhishek Tharwal, Sr. DR

Section 143(3)Section 69C

This amount includes Rs.2,75,000/- towards non specified profession without books of accounts and Rs.1,50,491/- towards speculation business profits. Income from other sources including interest on fixed deposits of Rs.26,814/-and bank interest of Rs.20,759/- totals up to Rs.45,573/-. Thus, assessee reported gross total

ITO-19(2)(4), Mumbai vs. Patdiam Jewels, Mumbai

In the result, the appeal filed by the Revenue Department stands dismissed

ITA 1/MUM/2025[2018-19]Status: DisposedITAT Mumbai18 Jul 2025AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarassessment Year: 2018-19

For Appellant: Shri Vimal Punmiya, Ld. A.RFor Respondent: Shri Mahesh Pamnani, Ld. D.R

Section 10ASection 142(1)Section 250

Addition made on account of enhanced N.P. as discussed above Rs.35,69,997 Rs.1,64,26,322 Rs.2,39,96,319 B. Income from Other Sources as per Computation of Income Rs.27,058 Gross Total Income Rs.2,40,23,377 Less: Deduction u/s 10AA of the Act Rs.1

Co-Operative Cane Development Union Pvt. Ltd, Modi Nagar, Uttar Pradesh vs. Income Tax Officer, Ward 2 1 (2), Ghaziabad

Appeal is allowed in above terms

ITA 5830/DEL/2024[2017-2018]Status: DisposedITAT Delhi18 Jul 2025AY 2017-2018

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanassessment Year: 2017-18 Vs. Income Tax Officer, M/S. Co-Operative Cane Development Union Pvt. Ltd., Ward-2(1)(2), Modi Nagar, Ghaziabad Uttar Pradesh Pan: Aaajc0168M (Appellant) (Respondent) Assessee By Sh. Ibad Mushtaq, Adv. Department By Sh. Rajesh Kumar Dhanesta, Sr. Dr

Section 144Section 80Section 80PSection 80P(2)Section 80P(2)(a)

members does not quality for exemption u/s.80P. It is an admitted position that the interest so earned should be taxed as 'income from other sources' There is a cleavage of judicial opinion among several High Courts on the issue of eligibility of this kind of income for exemption

ACIT Central Circle, Ghaziabad vs. Arihant Textiles, Ghaziabad

In the result, the appeal of the Revenue is dismissed

ITA 2257/DEL/2023[2018-19]Status: DisposedITAT Delhi18 Jul 2025AY 2018-19

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishra

Section 115BSection 127Section 133ASection 142(1)Section 143(2)Section 15B

surrendered amount on normal rate without appreciating the fact that the assessee disclosed the surrendered amount in its ITR under the head "Income From Other Sources" and the same was set off by the assessee firm against its business losses and further since the assessee firm failed to disclose ... surrender Rs.2,00,00,000/- as income in ITR. However, the assessee offered Rs.1,30,00,000/- as income under the head ‘Income from Other Sources’ in ITR of the relevant year. The Assessing Officer (‘AO’) worked out business income @ 2.24% of gross receipts. Further, the AO taxed surrendered income

Navnitbhai Jerambhai Desai, Surat vs. ITO, Ward- 3(2)(1), Surat

In the result, appeal of the assessee is allowed

ITA 136/SRT/2025[2017-18]Status: DisposedITAT Surat17 Jul 2025AY 2017-18

Bench: Shri Tr Senthil Kumar & Shri Bijayananda Prusethआयकर अपील सं./Ita No.136/Srt/2025 Assessment Year: (2017-18) (Hybrid Hearing) Navnitbhai Jerambhai Desai Income Tax Officer 44, Vaikunthdham Society, Vs. Ward No.3(2)(1), Surat, Laxmikant Aashram Road, Aayakar Bhavan, Majura Katargam, Surat-395 004 Gate, Surat-395 001 स्थायीलेखासं./जीआइआरसं./Pan/Gir No: Afzpp 3076 P (अपीलाथ"/Appellant) (प्र"थ" /Respondent) िनधा"रती की ओर से /Appellant By Shri Mehul Shah, Ca राज" की ओर से /Respondent By Shri Ajay Uke, Sr-Dr सुनवाई की तारीख/Date Of Hearing 02/07/2025 उद्घोषणा की तारीख/Date Of Pronouncement 17/07/2025 आदेश / O R D E R Per Bijayananda Pruseth, Am: This Appeal By The Assessee Emanates From The Order Passed Under Section 250 Of The Income-Tax Act, 1961 (In Short, ‘The Act’) Dated 13.12.2024 By The National Faceless Appeal Centre (Nfac), Delhi/Commissioner Of Income-Tax (Appeals) [In Short, ‘Cit(A)’] For The Assessment Year (Ay) 2017-18, Which In Turn Arises Out Of Assessment Order Passed By Assessing Officer (In Short, ‘Ao’) U/S 144 Of The Act Dated 26.11.2019. Grounds Of Appeal Raised By The Assessee Are As Under: “1. On The Facts & Circumstances Of The Case, The Learned Cit(A) Has Erred In Confirming The Action Of Assessing Officer In Making Addition Of Rs.13,68,000/- On Account Of Unexplained Income U/S 69A R.W.S. 115Bbe.

Section 115BSection 143(2)Section 144Section 250Section 69A

brief are that assessee filed his return of income for AY 2017-18 on 01.08.2017 declaring total income of Rs.1,42,170/- including income from other sources of Rs.1,28,441/-. The case was selected for scrutiny under CASS for the reason that assessee had deposited substantial cash

Santosh Kanwar, Jaipur vs. ITO 6(4 ) Jaipur, Jaipur

ITA 937/JPR/2024[2015-2016]Status: DisposedITAT Jaipur17 Jul 2025AY 2015-2016

Bench: BEFORE: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: NoneFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR

Section 10(38)Section 115BSection 142(1)Section 143(3)Section 234ASection 274Section 288Section 68Section 69C

computed as below:- Business income (para 6.2) Rs. 10,92,414/- Capital gain (LTCG & STCG) para6) (considered under Rs. Nil/- head business & profession) Income from other sources as declared Rs. 10,11,828/- Additions Bogus LTCGclaimed u/s 10(38) held to be income from Rs.19,10,972/- other sources