2018 (8) TMI 1360

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....in deleting the addition made under the head income from other sources relying on Circular No. 447 dated 22.01.1986 which is not in existence w.e.f 01.04.2005 as per clarification on Taxability of Awards for Sportmen (Circular No. 2/2014 [F. No. 199/01/2014-ITA-1]) and ignoring the fact that there is nothing on record to show that the Central Government has approved such awards and tax exemption has been granted to the assessee in respect of awards or rewards covered by such approval." 3. During the course of scrutiny assessment proceedings, the Assessing Officer found that the assessee has received awards from the following authorities: S. No. Particulars of the Authority Amount 1. District Sport council Jalandher 81,8....

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....ular is applicable, in view of the fact that section 10 refers :: incomes that are not includable in total income and the Circular No. 447 of 1986 takes - - receipt out of the purview of the income. It is also held that section 56 falls under the "income from other sources" and only covers such income which is not chargeable to tax under the heads specified in section 14, Item No. A to E. However for the applicability of section 56, the receipt should be in the nature of the income. Since the receipt as per Circular No. 447 has been held not to be in the nature of income, section 5f * have application. Accordingly, the Hon'ble ITAT has held that the entire receipts in the form of awards/rewards received by the assessee are non-taxable o....