The assessee owned a property and received a security deposit for leasing the premises. The property had been sold in the year 2013-14, hence no income from rentals had been offered to tax. However, the assessee continued to hold the security deposit. The Assessing Officer brought to tax the interest deemed to have derived from the security deposit under the head Income from other sources. The Commissioner (Appeals) confirmed this. On appeal  the Tribunal held that the addition was based on the sole premise, that the assessee had the security deposit must have earned the interest. In order to tax any amount, the Revenue had to prove that the amount had indeed been earned by the assessee. Only the incomes falling under the deemed provisions which had been explicitly mentioned in the Act could be brought to tax. Accordingly the additions made by the Assessing Officer were to be deleted. (AY.2017-18)