Pooja Swami Vs Assessment Unit (ITAT Agra)
Bitcoin Transactions, ₹29.34 Crore Additions—A Blanket Confirmation Will Not Do
The background: Cryptocurrency trading attracts reassessment
The Department initiated reassessment proceedings after receiving information that the assessee had undertaken high-value trading in cryptocurrency, particularly Bitcoin, during FY 2017-18, relevant to AY 2018-19.
A notice under section 148 dated 29 August 2024 was issued and served. In response, the assessee filed a return declaring total income of ₹13,850.
The Assessing Officer subsequently issued statutory notices under sections 143(2) and 142(1), along with show-cause notices, seeking explanations regarding the transactions. The assessee responded only partly. After considering the available material and those responses, the Assessing Officer completed the reassessment on 10 March 2026 under section 147 read with section 144B. viewOrder-11
Two substantial additions followed
The Assessing Officer made an addition of ₹1,61,95,842 as undisclosed capital gains from Bitcoin trading. He separately added ₹27,72,41,266 as unexplained bank credits or cash deposits.
The aggregate additions therefore amounted to ₹29,34,37,108.
These were two distinct components: one concerned the alleged gains arising from cryptocurrency trading, while the other concerned credits and deposits in bank accounts. The order does not reproduce the detailed computations or transaction-level analysis underlying either addition.
