VIJAY BAHADUR,NAYA GAON, MOHALI, PUNJAB vs. INCOME TAX OFFICER, WARD-2(1), CHANDIGARH , CHANDIGARH

IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, CHANDIGARH PHYSICAL HEARING HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM आयकरअपीलसं./ ITA No.112/CHANDI/2026 (िनधा�रणवष� / Assessment Year: 2018-19) Shri Vijay Bahadur ITO Ward – 2(1) C/oSh. Tejmohan Singh (Advocate) Chandigarh बनाम/ Vs. 527, Sector 10 – D Chandigarh – 160011 �ायीलेखासं./जीआइआरसं./PAN/GIR No. CBVPB-5989-F (अपीलाथ�/Appellant) : (��थ� / Respondent) अपीलाथ�कीओरसे/ Appellant by : Sh. Tejmohan Singh (Advocate) – Ld. AR ��थ�कीओरसे/Respondent by : Dr. Ranjit Kaur (Addl. CIT) - Ld. Sr. DR सुनवाईकीतारीख/Date of Hearing : 30-06-2026 घोषणाकीतारीख /Date of Pronouncement 06-07-2026 : आदेश / O R D E R 1. Aforesaid appeal by assessee for Assessment Year (AY) 2018- 19 arises out of an order of learned Commissioner of Income Tax (Appeals), NFAC [CIT(A)] dated 24.11.2025 in the matter of an assessment framed by Ld. Assessing Officer [AO] u/s 147 r.w.s. 144B of the Act on 26.12.2023. The Ld. AR argued on merits only whereas Ld. Sr. DR pleaded for dismissal of the appeal. Having heard rival submissions, the appeal is disposed-off as under. 2. The assessee did not file return of income. It transpired that the assessee traded in bitcoins for Rs.25.07 Lacs. Accordingly, the case was reopened. The assessee stated that it was engaged in referral

network of bitcoin investment / trading and arranged prospective investors for bitcoin investment. The assessee received referral service incentives in the form of bitcoins which were encashed and credited in his bank account. However, the assessee could not substantiate the same. The assessee offered presumptive income u/s 44AD on receipt of Rs.30.35 Lacs which stood rejected by Ld. AO. Finally, the whole of the receipts was brought to tax. The Ld. CIT(A) confirmed the assessment for want of any representation from the assessee. Aggrieved, the assessee is in further appeal before Tribunal. 2. From the facts, it emerges that the assessee has provided business support services and earned referral commission income in the shape of bitcoins which were later on encashed and credited in his bank account. On these facts, the assessee’s income could be determined on presumptive basis u/s 44ADA @50% of gross receipts since the assessee has not maintained relevant records as well as regular books of accounts. The income so earned by the assessee is in the nature of service income. Accordingly, I direct Ld. AO to estimate the assessee’s income @50% of gross receipts and re- compute the income of the assessee. No other ground has been urged in the appeal. No infirmity could be shown in reassessment proceedings as initiated by Ld. AO.

-Sd- (MANOJ KUMAR AGGARWAL) ACCOUNTANT MEMBER AS Dated: 06-07-2026 आदेश की �ितिलिप अ�ेिषत /Copy of the Order forwarded to : 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकरआयु�/CIT 4. िवभागीय�ितिनिध/DR 5. गाड�फाईल/GF

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