MUHAMMED ARIF SHAIKH,VEJALPUR vs. ASST. UNIT. INCOME TAX DEPT. (PRESENT JURI. - ITO, WARD 3(3)(2) AHMEDABAD), VEJALPUR

ITA 1806/AHD/2025Status: DisposedITAT Ahmedabad25 February 2026AY 2018-19Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)11 pages
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What did the Tribunal hold?

The Tribunal held that the addition made under Section 69C as unexplained expenditure was unjustifiable and illegal, especially when the same assessment unit accepted a similar offer for the prior assessment year. The inconsistent stand by the revenue was deemed improper.

What were the facts?

The assessee engaged in cryptocurrency trading and income from business, remuneration, and interest. Information received indicated significant cryptocurrency transactions for which the assessee initially did not respond to summons. The assessee later offered a presumptive profit of 8% on sales for the assessment year.

What were the issues?

Whether the addition of cryptocurrency purchase as unexplained expenditure under Section 69C was justified when the assessee offered presumptive income, and if the revenue's inconsistent treatment across assessment years was permissible.

Which sections of the Income-tax Act were involved?

Section 147,Section 144B,Section 131,Section 148A,Section 148,Section 143(2),Section 69C,Section 115BBE

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Income Tax Appellate Tribunal, AHMEDABAD “SMC” BENCH

Before: DR. BRR Kumar & Shri T. R. Senthil Kumar

PER : T.R. SENTHIL KUMAR, JUDICIAL MEMBER:-

This appeal is filed by the Assessee as against appellate order dated 29-07-2025 passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, (in short referred to as “CIT(A)”), arising out of the reassessment order passed under section 147 r.w.s. 144B of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Year 2018-19. 2. Brief facts of the case that the assessee is an individual and Partner in a firm deriving income from business, remuneration,

I.T.A No. 1806/Ahd/2025 A.Y. 2018-19 Page No 2 Mu

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