Sec. 45 & 54 of Income Tax Act, 1961 – Income from other sources – The appeal of the assessee against the order of Tribunal involved the substantial question of law "substantial question of law covers the controversy in question that "whether on the facts and in the circumstances of the case and in law, Tribunal was justified in confirming the addition of Rs. 50 lakhs to the taxable income of the assessee under the head "Income from other sources" for the Assessment Year under consideration?" High Court allowed the appeal of the assessee holding that:– The assessee had disclosed the amount of Rs. 50 lakhs received from M/s. Carlton Coats Pvt. Ltd. for settlement of its claim to the property and had further disclosed that the said amount was invested in capital bonds. Thus the said amount was received by the assessee as long term capital gains in view of surrender of rights by the assessee vis-a-vis the property in question. In the circumstances, merely on the basis of suspicion, the revenue authorities ought not to have rejected the claim of the assessee that the said amount was received as long term capital gains but to treat the said amount as "income from other sources" – AMOL C. SHAH (HUF) Vs. ITO [2020] 423 ITR 408 (BOM)