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Microlesson · 5-min read

Definition of Income [Section 2(24)]

# Definition of Income [Section 2(24)]

Key feature: The definition is inclusive, not exhaustive. The word "includes" means the list is illustrative — items not listed can still be income if they bear the character of income.

## Items specifically included

1. Profits and gains of business or profession.

2. Dividends from shares in companies.

3. Perquisites / profit in lieu of salary taxable under Sections 17(2) and 17(3).

4. Personal-expense allowances — to meet personal expenses at the place of employment/residence or to compensate for increased cost of living.

5. Director's / substantial-interest remuneration — benefits/perquisites from a company to a director or person with substantial interest, including company payments discharging that person's obligations.

6. Representative assessee benefits — value of benefits to a representative assessee/beneficiary.

7. Business/profession profits chargeable under specified sections (e.g. 28(ii), 28(iii)).

8. Deemed profits under Section 41 or 59.

9. Perquisites from business/profession taxable under Section 28(iv).

10. Capital gains chargeable under Section 45.

11. Winnings — from lotteries, crossword puzzles, races (incl. horse races), card games, gambling or betting. Includes lottery (any scheme of chance) and card games/game shows.

12. Employee contributions received by employer to PF, superannuation, ESI or other welfare funds.

13. Keyman insurance policy sums, including bonuses on such policies.

14. FMV of inventory converted into a capital asset.

15. Forfeited advances on failed negotiation for transfer of a capital asset [Section 56(2)(ix)].

16. Inadequate/without consideration money or property [Section 56(2)(x)].

17. Employment-termination payments / modification of employment terms [Section 56(2)(xi)].

18. Life-insurance policy receipts (other than ULIPs and keyman policies) exceeding total premiums paid, not claimed elsewhere [Section 56(2)(xiii)].

19. Government assistance — subsidies, grants, cash incentives, duty drawbacks, waivers, reimbursements (cash or kind). Exclusion: subsidies/grants that are taken into account in determining the actual cost of a depreciable asset are not treated as income here.

> Exam angle: the inclusive nature plus the exclusion in item 19 (subsidy adjusted against actual cost of an asset) are frequent question points.

Worked example

### Example 1

Government subsidy: A ₹10 lakh subsidy received specifically to acquire a machine is reduced from the machine's actual cost (for depreciation) and is therefore NOT income under Section 2(24). But a general cash incentive for setting up a business in a backward area is income.

### Example 2

Inventory to capital asset: A builder converts a flat held as stock-in-trade (FMV ₹40 lakh) into a personal capital asset — the ₹40 lakh FMV is treated as income under Section 2(24) item 14.

⚠️ Common exam mistakes

  • Treating the definition as exhaustive — it is inclusive, so unlisted receipts of an income nature can still be taxable.
  • Taxing a subsidy as income even when it has already been reduced from the actual cost of a depreciable asset — that subsidy is excluded.
  • Assuming all life-insurance receipts are income — only those (other than ULIPs/keyman) exceeding premiums paid and not deducted elsewhere are covered.
Reference: Section 2(24)
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