From Reopening to Relief:
Defending a Cryptocurrency Trader
Against a Rs.1.57 Crore Section 69 Addition
A detailed account of how a salaried taxpayer's crypto arbitrage activity — spanning three continents, two defunct exchanges, and nearly eight years — was successfully defended through meticulous documentation, sound legal principles, and strategic representation before the Faceless Assessment Unit.
Introduction
Setting the Stage: The Cryptocurrency Landscape of 2017-18
The financial year 2017-18 was, to put it mildly, the wild west of Indian cryptocurrency trading. Bitcoin touched Rs.14 lakh per coin. Exchanges like Coinsecure, Zebpay, and Unocoin were processing hundreds of crores in daily volume. The concept of OTC (over-the-counter) crypto arbitrage — buying coins from overseas sellers and liquidating them on Indian platforms — was a genuine income-generating activity pursued by tech-savvy professionals. And crucially, there was no specific statutory framework governing the taxation of Virtual Digital Assets (VDAs) in India at the time.
Fast forward to 2024. The Income Tax Department, armed with its Risk Management System (RMS) and the ITBA software infrastructure, began systematically revisiting cases where taxpayers had made foreign remittances or engaged in crypto transactions without offering corresponding income in their returns. Many such taxpayers received notices under Section 148A of the Income Tax Act, 1961 — the new two-step reassessment gateway introduced by the Finance Act, 2021.
One such case landed on our desk — a salaried professional employed with a leading e-commerce company, who had engaged in crypto arbitrage trading on the side during F.Y. 2017-18. What appeared, on its face, to be a simple omission of a small profit from a tax return unravelled into a year-long battle over whether gross crypto purchases of Rs.1,57,96,765 should be taxed as "unexplained investment" under Section 69 read with Section 115BBE — potentially attracting tax at an effective rate exceeding 78%.
This blog chronicles the journey from the first statutory notice to the final assessment order — a journey that tested our ability to present old legal principles in the context of a brand-new asset class.
Stage 1 · August 2024
The First Knock: Notice Under Section 148A(b)
In August 2024, our client received a notice under Section 148A(b) of the Income Tax Act, 1961. The notice, bearing a proper Document Identification Number (DIN) in compliance with CBDT Circular No. 19/2019, was the first formal communication from the Department regarding Assessment Year 2018-19.
What is Section 148A?
Introduced by the Finance Act, 2021 (effective from 01.04.2021) to address constitutional concerns, Section 148A mandates a mandatory pre-notice inquiry before reassessment can be initiated. The two-step process is:
- 148A(b): The Assessing Officer issues a show cause notice asking the taxpayer to explain why reassessment should not be opened — with the information and basis for belief enclosed.
- 148A(d): After considering the reply, the AO passes a speaking order recording reasons and deciding whether to issue the Section 148 notice.
The Information Flagged by the Risk Management System
The Department had received specific information flagged through the ITBA software under the head "RMS Non-filing of Return Cases." The CBDT's Risk Management Strategy had identified the assessee as having carried out transactions during F.Y. 2017-18 that were potentially taxable but appeared to have escaped reporting in the original return.
The specific trigger: foreign outward remittances made through Indian banking channels for the purchase of cryptocurrency. These remittances, visible in the banking system and cross-referenced with the assessee's PAN, indicated significant financial activity that had not been fully reflected in the filed return of income.
From a purely compliance-monitoring standpoint, the data trail was clear — significant sums had left the country from the assessee's disclosed bank accounts, and corresponding income had not been offered. The Section 148A notice was, therefore, procedurally sound and well-founded in the data available to the Department.
The Initial Challenge: A Tight Deadline
The first 148A(b) notice was issued on 02.08.2024, requiring a response by 16.08.2024 — barely two weeks. A second notice under Section 148A(b) was issued on 13.08.2024, reiterating the opportunity and providing a final date of 16.08.2024, as the assessee had not responded to the first notice.
The Stage 1 proceedings concluded with the Department passing an Order under Section 148A(d) on 23.08.2024, deciding that it had "reason to believe" that income had escaped assessment. On the same date, the Department issued the actual notice under Section 148, formally reopening the assessment for A.Y. 2018-19.
Stage 2 · August 2024 – June 2025
The Reopening: Notice Under Section 148 and the Missed Deadline
The notice under Section 148 dated 23.08.2024 was duly served through the assessee's registered account on the e-filing portal and also delivered to the registered email address. The notice required the assessee to furnish a return of income within three months from the end of the month in which the notice was issued — i.e., on or before 30.11.2024.
The Missed Deadline: A Consequential Lapse
Here is one of the most important — and cautionary — aspects of this case. The assessee did not file the return in compliance with the Section 148 notice by 30.11.2024. The return was eventually filed only on 01.06.2025, more than six months after the deadline.
When the assessee eventually filed the return on 01.06.2025 — after receiving the Section 142(1) notice discussed in the next stage — it declared a total income of Rs.24,98,150/-, comprising:
| Head of Income | Amount (Rs.) | Remarks |
|---|---|---|
| Salary Income | 23,44,466 | Employment with a leading e-commerce company |
| Interest Income | 1,40,837 | Bank deposits |
| Short Term Capital Gain — Crypto | 42,650 | Net profit from crypto arbitrage trading |
| Total Income | 24,98,150 |
In the original return filed on 29.12.2018, the assessee had declared income of Rs.24,33,880/- — comprising salary and other source income only. The short term capital gain of Rs.42,650/- from crypto transactions had been inadvertently omitted. While the quantum was small, the omission would later become a formal trigger for penalty proceedings under Section 270A.
Stage 3 · May–June 2025
The Inquiry Deepens: Notice Under Section 142(1)
On 22.04.2025, the assessee received an intimation letter that the assessment would be conducted in faceless manner under Section 144B. This was followed on 16.05.2025 by a comprehensive notice under Section 142(1), requiring the assessee to furnish accounts, documents, and information on or before 02.06.2025.
What the 142(1) Notice Demanded
The annexure to the Section 142(1) notice was a ten-point questionnaire that effectively required the assessee to reconstruct and substantiate his entire financial position for F.Y. 2017-18:
- Filing of return in compliance with the Section 148 notice (or copy of acknowledgment if already filed)
- Detailed note on business activities, profession, or other sources of income for F.Y. 2017-18
- Computation of income from all sources with nature of income
- Complete financial statements, Balance Sheet, and P&L Account
- Copy of Form 26AS with justification of amounts under various heads
- Details of all bank accounts maintained during the year
- Copy of all bank account statements (Savings, Current, FD, RD, etc.) and cash book
- Details of source of cash deposits, if any, with documentary evidence
- GST returns with annexures; copy of sale and purchase register if applicable
- Details of any deduction or exemption claimed with documentary evidence
Our Response: Building the Case from the Ground Up
The assessee filed his reply on 31.05.2025 — one day before the deadline. The response was built around a clear and coherent narrative: the assessee was a salaried professional who had engaged in cryptocurrency arbitrage trading during F.Y. 2017-18. This activity involved:
- Remitting funds abroad through legitimate banking channels (HDFC Bank and SBI)
- Purchasing cryptocurrency from overseas counterparties in the UK and Germany
- Selling the cryptocurrency on Indian exchanges (Coinsecure, Zebpay, Unocoin)
- Receiving sale proceeds into disclosed Indian bank accounts
- Generating a modest net profit of Rs.42,650 on a total purchase value of Rs.1,57,96,765
The evidence submitted comprised:
- Form 16 from the employer confirming salary income
- Bank account statements from HDFC Bank and SBI with annotated narrations identifying crypto-related outflows and inflows
- Transaction summary reconstructed from bank records (since Coinsecure was defunct)
- Sworn and notarised affidavit describing the nature of the arbitrage activity and use of remittances
- Passport copy of one of the overseas counterparties
- Outward remittance details from the bank confirming the purpose of transfers
- Google chat records and Excel workings corroborating transactions with the UK-based counterparty
The Foreign Remittance Breakdown
| Recipient | Country | Currency | Amount (Rs.) | Bank |
|---|---|---|---|---|
| Overseas Counterparty A | United Kingdom | GBP | 1,11,92,445 | HDFC Bank |
| Overseas Counterparty A | United Kingdom | GBP | 9,22,857 | SBI Bank |
| Overseas Counterparty B | Germany | EUR | 14,98,960 | HDFC Bank |
| Total | 1,36,14,262 | |||
Stage 4 · February 2026
The Storm: Show Cause Notice Proposing Rs.1,57,96,765 as Unexplained Investment u/s 69
On 20.02.2026, the Assessment Unit issued a formal Show Cause Notice proposing a variation prejudicial to the assessee's interest. The compliance date was 25.02.2026 — just five days away.
The proposed variation was staggering in its scope: the entire purchase value of crypto transactions aggregating to Rs.1,57,96,765/- was proposed to be treated as unexplained investment under Section 69 read with Section 115BBE.
The Department's Reasoning: Point by Point
Grounds for Proposed Addition of Rs.1,57,96,765
- Absence of exchange records: No complete transaction statements or trade ledgers from Coinsecure, Zebpay, or Unocoin were submitted confirming the purchases and sales, including KYC verification documents. The claim was rendered "unverifiable and unsupported."
- No corroborative evidence for foreign routing: While the assessee submitted that crypto was purchased from overseas counterparties through banking channels, no affidavits, agreements, or independent confirmations were filed to establish the genuineness of such routing arrangements.
- Role of foreign parties unsubstantiated: The AO noted that the assessee failed to substantiate the exact role of the overseas counterparties (whether agent, intermediary, etc.) and whether any commission or fee was paid/received.
- No invoices or receipts: No invoices or receipts for cryptocurrency purchases from overseas vendors were furnished.
Why This Addition Would Have Been Devastating
Section 115BBE mandates that income assessed under Sections 68, 69, 69A, 69B, 69C, and 69D be taxed at 60% flat plus a surcharge of 25% on the tax — effectively an aggregate tax rate of approximately 78%, before adding interest under Sections 234A, 234B, and 234C.
| Component | Amount (Rs.) |
|---|---|
| Proposed Addition | 1,57,96,765 |
| Tax @ 60% (Section 115BBE) | 94,78,059 |
| Surcharge @ 25% on tax | 23,69,515 |
| Effective Tax (before interest and cess) | ~1,18,47,574 |
In other words, an amount greater than the original investment itself would have been payable as tax — a result that was not only commercially absurd but legally unjustifiable. This is precisely why mounting a comprehensive defence to the SCN was non-negotiable.
Stage 5 · February–March 2026
The Defence: Dismantling the Section 69 Case
On receiving the SCN on 20.02.2026, we immediately sought an adjournment to 02.03.2026 (which was granted, with a partial reply filed on 25.02.2026). The additional time was used to construct a comprehensive, layered defence addressing the Department's objections on both legal and factual grounds. Our response was filed on 02.03.2026 along with a detailed bundle of documents. The defence rested on seven distinct pillars.
Pillar 1: Section 69 Is Legally Not Attracted
We began by dissecting the statute itself. Section 69 provides:
We pointed out the cumulative conditions that must co-exist for Section 69 to apply:
- The assessee has made an investment;
- Such investment is not recorded in books of account (if books are maintained);
- The assessee fails to explain the nature and source of the investment;
- The explanation offered is found unsatisfactory;
- Even then, the deeming provision is discretionary — not automatic.
In our client's case, the assessee was a salaried individual not statutorily required to maintain books of account; the investments were fully traceable in disclosed bank statements; the nature of the transactions had been clearly explained; the source of funds (salary income and disclosed bank balances) was identifiable and uncontested; and no cash component or undisclosed asset was ever alleged. Not a single element required for Section 69's invocation was present.
Section 69 addresses source of investment — not identity of counterparty
The SCN's objections — lack of invoices, no confirmation from foreign parties, no agency agreements — are requirements relevant to Section 68 (cash credit cases), where the three-limb test of identity, creditworthiness, and genuineness applies. Section 69's sole focus is whether the source of funds used for the investment is unexplained. Here, the source was indisputably salary income flowing through disclosed bank accounts. The Department had not recorded any finding that the bank balances themselves were unexplained — making Section 69 legally inapplicable.
Pillar 2: Banking Channel Transactions Cannot Be Unexplained
Every rupee that went abroad was traceable to disclosed HDFC Bank and SBI accounts. The bank statements, annotated with narrations, clearly showed the outflow of funds for crypto procurement. Crucially, the Department's own case relied on these very bank records to identify the transactions — which simultaneously established that the source of investment was known and verifiable.
CIT v. Rohini Builders — Banking channel transactions
Where transactions are routed through banking channels, additions cannot be sustained merely for want of further confirmations. The judicial principle is that once transactions are reflected in disclosed bank accounts with proper narrations, the burden of proof does not extend to producing every underlying commercial document.
CIT v. Rohini Builders — 256 ITR 360 (Gujarat High Court)CIT v. Kulwant Rai — Disclosed bank account investments
Investment routed through a disclosed bank account cannot be treated as unexplained unless the source of the bank funds themselves is disproved by the Department. In this case, the Department made no allegation whatsoever against the salary income or the bank balances — the very foundation of any Section 69 addition was therefore absent.
CIT v. Kulwant Rai — 291 ITR 36 (Delhi High Court)Pillar 3: Burden Shifts Once Primary Evidence Is Furnished
The assessee had submitted bank statements, a detailed transaction summary, an affidavit, and computation of income. In response to the SCN, further documents were added — outward remittance details from the bank, Google chat communications with the UK counterparty, and detailed Excel workings of the transaction profit computation.
CIT v. Orissa Corporation Pvt. Ltd. — Burden shift
Once the assessee furnishes primary evidence explaining the nature and source of an investment, the burden shifts to the Department to disprove that explanation through independent inquiry. Failure to conduct further verification makes the addition unsustainable. Importantly, the Assessment Unit had not issued any summons under Section 131 or conducted any inquiry under Section 133(6) to independently verify the claims.
CIT v. Orissa Corporation Pvt. Ltd. — 159 ITR 78 (Supreme Court)Pillar 4: Suspicion Cannot Substitute Proof
Umacharan Shaw & Bros. v. CIT — Suspicion vs. proof
Suspicion, however strong, cannot substitute proof. A show cause notice that proceeds on suspicion arising from the absence of third-party documents — without any affirmative material showing circular routing, accommodation entries, fictitious transactions, or cash layering — cannot form the legal foundation for a Section 69 addition. The SCN contained no positive evidence of any of these; only the negative inference from missing documents.
Umacharan Shaw & Bros. v. CIT — 37 ITR 271 (Supreme Court)Pillar 5: Only Profit Can Be Taxed — Not Gross Investment
Even conceding, purely for argument's sake, that some portion of the transactions required scrutiny, it would be legally impermissible to treat the entire purchase value of Rs.1,57,96,765 as income. The Income Tax Act taxes income — not capital turnover. The profit was Rs.42,650. The Department was, in effect, attempting to tax the purchase cost of a trading activity as if it were income — a fundamental category error.
CIT v. President Industries — Only profit element taxable
The entire turnover cannot be added as income; only the profit element can be subjected to tax. This principle, established by the jurisdictional Gujarat High Court, was squarely applicable. The profit from crypto trading was Rs.42,650 — already offered to tax. Addition of Rs.1,57,96,765 was therefore contrary to binding precedent from the assessee's own jurisdictional High Court.
CIT v. President Industries — 258 ITR 654 (Gujarat High Court)Pillar 6: The Uncontroverted Affidavit
Mehta Parikh & Co. v. CIT — Affidavit evidence
A sworn affidavit explaining the nature of the arbitrage trading activity and identifying the counterparties had been filed at the 142(1) stage and again in response to the SCN. Since the Department had not offered any opportunity for cross-examination and had not conducted any independent inquiry to rebut the affidavit, the affidavit was legally required to be accepted as evidence.
Mehta Parikh & Co. v. CIT — 30 ITR 181 (Supreme Court)Pillar 7: The Doctrine of Impossibility — Lex Non Cogit Ad Impossibilia
This was perhaps our most creative and compelling argument. The transactions dated back to F.Y. 2017-18 — nearly eight years from the date of the SCN. The primary exchange platform, Coinsecure, had ceased operations. The overseas counterparty's trading portal was inaccessible. Statutory records preservation obligations for commercial entities did not extend to this timeframe.
Demanding trade reports from a defunct exchange was demanding the impossible. The assessee had made every reasonable effort — annotating bank statements, preserving chat records, obtaining outward remittance certificates — to corroborate the transactions with whatever evidence remained available. To convert the unavailability of records from a now-defunct third-party platform into an adverse inference would be to punish the assessee for circumstances entirely beyond his control.
We further argued: the inability to produce historical third-party exchange records after an extended lapse of time does not render a transaction non-genuine when the primary evidence (bank statements) is available, the source of funds is traceable, the nature of the transaction is explained, and no contrary material has been brought on record by the Department.
Section 115BBE: A Consequential Collapse
Finally, we addressed Section 115BBE head-on: since the foundational requirement for its application is a valid addition under Sections 68/69/69A/69B/69C/69D, and since Section 69 itself was not attracted in this case, Section 115BBE's draconian 78% tax rate could not apply. The penal provision was consequential upon the main addition — if the main addition fell, the 115BBE charge fell with it automatically.
Documentary Bundle Filed with SCN Reply
- Adjournment Letter dated 25.02.2026
- HDFC and SBI bank statements (PDF copies and Excel workings with narration)
- Sworn and notarised Affidavit
- Income tax computation for A.Y. 2018-19
- Form 16 from employer
- Google chat records with overseas counterparty and Excel transaction workings
- Outward remittance details from Bank
Stage 6 · March 2026
The Verdict: Assessment Order Under Section 147
The Assessment Unit passed the final order on 28.03.2026 under Section 147 read with Section 144 read with Section 144B of the Income Tax Act, 1961.
The Assessment Unit's Own Findings
The Assessment Unit's order recorded the following conclusions under "Reasons for inference drawn that no variation is required on this issue":
The assessee filed his return of income for A.Y. 2018-19 declaring total income of Rs.24,33,880. The case was reopened on the reason that the assessee had transacted in cryptocurrency, however no income had been offered in the original ROI.
In response to the notice u/s 148, the assessee filed a return of income declaring total income of Rs.24,98,150, including short term capital gain of Rs.42,650 from crypto currency trading. The assessee furnished a summary of crypto transactions, bank statements with narration, and an Affidavit.
A show cause notice was issued proposing to treat the entire investment in crypto aggregating to Rs.1,57,96,765 as unexplained investment. In response, the assessee filed copies of HDFC and SBI bank statements, Affidavit, computation, Form 16, Google chat records, Excel workings, and outward remittance details from the bank.
"The details furnished by the assessee and all the details available on record with reference to the reason for selection of the case have been perused and placed on record. The explanation of the assessee on the issue is found to be in order. In view of the above, the returned income filed in response to notice u/s 148 is accepted."
The One Remaining Cloud: Section 270A Penalty
While the substantive battle was won comprehensively, the matter was not entirely over. The Assessment Order noted that the income now offered (Rs.24,98,150) was higher than the original return (Rs.24,33,880), representing "under-reported income" within the meaning of Section 270A. Accordingly, penalty proceedings under Section 270A were initiated separately.
Analysis
What Made This Case Complex — and What Made the Difference
Looking back at the full arc of this case, several factors combined to create genuine legal complexity, and an equal number of strategic choices made the difference between a catastrophic addition and a clean outcome.
The Sources of Complexity
- Temporal distance: We were reconstructing F.Y. 2017-18 transactions in 2025 and 2026 — nearly eight years later. Documentary trails had gone cold, platforms had shut down, and counterparties were overseas and not easily reachable.
- Novel asset class: Cryptocurrency was unregulated in 2017-18. There were no standard procedures for maintaining records, no exchange-issued statements, no standardised tax treatment. The evidentiary framework had to be built from first principles.
- Cross-border elements: Foreign remittances in GBP and EUR, overseas counterparties in the UK and Germany, and OTC arrangements — none of which had a typical paper trail seen in domestic transactions.
- Gross vs. net confusion: The Department's instinct was to treat the entire gross investment as unexplained income — a category error that is surprisingly common in cases where the taxpayer is a "net profit" earner on a large-volume trading activity.
- Confluence of harsh provisions: The combination of Section 69 and Section 115BBE is among the most punitive in the Income Tax Act. The 78% effective tax rate on gross investment — with no deduction for purchase cost — would have been economically ruinous.
- Short compliance timelines: A five-day window from the SCN to the compliance date required rapid mobilisation of legal arguments and document assembly under pressure.
What Made the Difference
Banking channel anchoring
Every transaction was anchored in disclosed, verified bank accounts. This was the bedrock of the entire defence — Section 69 cannot apply when the source of funds is traceable to disclosed salary income in known accounts.
Distinguishing 68 from 69
We identified that the Department was importing Section 68 requirements into a Section 69 inquiry. Precise statutory analysis was the key to exposing this category error and framing the correct legal battleground.
The impossibility doctrine
Invoking lex non cogit ad impossibilia in the context of a defunct exchange was not a gambit — it was a genuine legal principle that resonated with the Assessment Unit and addressed the core documentary gap.
Profit vs. turnover argument
Arguing binding Gujarat High Court precedent that only the profit element (Rs.42,650) — already offered to tax — could be the subject of any addition was a decisive blow to the 115BBE mechanism.
Evidence reconstruction
The painstaking work of reconstructing an eight-year-old crypto trading history from bank statements, annotated narrations, chat records, and remittance certificates gave the Assessment Unit a complete, coherent, and credible picture.
Prompt full engagement
Despite missing the original Section 148 deadline, full and complete engagement once the 142(1) notice was received, and a well-structured comprehensive response to the SCN, gave the assessee the procedural standing needed for a favourable outcome.
Broader Lessons
Key Takeaways for Cryptocurrency Taxpayers and Their Advisors
This case is, in many respects, a preview of a wave of disputes that is only beginning. As the Income Tax Department intensifies scrutiny of cryptocurrency transactions from the pre-VDA-framework era (pre-April 2022), several categories of taxpayers may find themselves in similar situations.
For Taxpayers Who Traded Crypto in 2017-18 to 2021-22
Do not assume the matter is closed. The six-year window for reopening assessments (Section 149) means that A.Y. 2018-19 remains within the Department's reach. If you have undisclosed crypto income, getting ahead of the Department — through voluntary disclosure or filing revised returns where possible — is far preferable to waiting for a notice.
Preserve every scrap of evidence. Bank statements, exchange screenshots, email communications with counterparties, wallet addresses, and any other contemporary record must be preserved. Courts are sympathetic to impossibility of performance — but only when the taxpayer has genuinely done everything possible within their control.
Understand the distinction between turnover and profit. The Department's default approach in crypto cases is to treat gross purchase value as unexplained investment. This is legally incorrect. The Gujarat High Court's decision in CIT v. President Industries is a strong precedent in this regard, particularly for taxpayers in the Gujarat jurisdiction.
For Chartered Accountants and Tax Practitioners
Section 68 vs. Section 69 — know your battlefield. The Department routinely conflates the requirements of Sections 68 and 69. Section 68 requires the assessee to establish identity, creditworthiness, and genuineness of the creditor. Section 69 requires only an explanation of the source of investment. These are fundamentally different standards — and the difference can be decisive in framing your entire response strategy.
The affidavit is a powerful tool. When contemporaneous documentary evidence is unavailable, a sworn affidavit — properly drafted, notarised, and filed before the Assessment Unit — shifts the burden and creates an evidentiary record that the Department must actively rebut through Section 131 summons or Section 133(6) inquiries rather than dismiss passively.
Never ignore a 148A notice. The two-stage 148A process is a genuine opportunity to prevent reassessment before it begins. A well-argued reply at the 148A(b) stage can sometimes result in the AO declining to issue the Section 148 notice altogether — saving the assessee from the entire subsequent proceeding.
Section 270A is not the end. Even where reassessment is accepted, the consequential Section 270A penalty notice offers another opportunity. The penalty for "under-reporting" (50% of tax on under-reported income) is substantially lower than the 200% that applies to "misreporting." The characterisation of the non-disclosure is therefore critical and worth fighting for.
Chronology
Complete Case Timeline at a Glance
| Date | Event | Section | Status |
|---|---|---|---|
| 29.12.2018 | Original ITR for A.Y. 2018-19 filed; income Rs.24,33,880; crypto gain omitted | 139(4) | Filed (belatedly) |
| 02.08.2024 | First 148A(b) notice — Show Cause for proposed reopening | 148A(b) | Issued |
| 13.08.2024 | Second 148A(b) notice — final opportunity, given non-compliance with first notice | 148A(b) | Issued |
| 23.08.2024 | Order u/s 148A(d) passed; notice u/s 148 issued on the same date | 148A(d) / 148 | Reopening ordered |
| 30.11.2024 | Deadline for return u/s 148 — not met | 148 | Missed |
| 22.04.2025 | Intimation — assessment to be conducted in faceless manner u/s 144B | 144B | Intimated |
| 16.05.2025 | Notice u/s 142(1) — 10-point questionnaire; compliance by 02.06.2025 | 142(1) | Issued |
| 31.05.2025 | Reply to 142(1) filed with supporting documents | 142(1) | Complied (partial) |
| 01.06.2025 | Return of income filed u/s 148; total income Rs.24,98,150 including crypto gain Rs.42,650 | 148 | Filed |
| 20.02.2026 | Show Cause Notice — proposed addition of Rs.1,57,96,765 u/s 69 r.w.s. 115BBE; compliance 25.02.2026 | 147 SCN | Issued |
| 25.02.2026 | Adjournment sought and granted; partial reply filed | — | Adjourned |
| 02.03.2026 | Comprehensive final reply to SCN filed with full documentary bundle (bank statements, affidavit, remittance details, chat records, Excel workings) | — | Complied |
| 28.03.2026 | Final Assessment Order — addition dropped; returned income of Rs.24,98,150 accepted; penalty u/s 270A initiated separately | 147/144/144B | Favourable |
0 Comments