ITAT Jabalpur Judgments — November 2025

The Tribunal held that the CIT(A) erred in dismissing the appeal without considering the merits of the case and by solely relying on the AO's actions being dictated by the PCIT's directions. It was also noted that the CIT(A) denied the assessee natural justice by passing the order before the opportunity for video conferencing could be availed.

The Tribunal observed that crypto transactions must occur through bank accounts and the Department had not identified accounts supporting the higher alleged transactions. It ruled that the Department's evidence from Koinex must be provided to the assessee for confrontation and rebuttal. Therefore, the matter was restored to the AO to pass a fresh order after furnishing all details to the assessee and considering their response.

The Tribunal noted that the same investment was already assessed in the hands of Sh. Amarnath Pyasi for both AY 2012-13 and AY 2013-14, and an appeal against this was pending. It ruled that the investment could not be assessed in both the benamidar's and the alleged beneficial owner's hands simultaneously. The matter was restored to the CIT(A) to consider both assessment orders together and make a final decision, thus allowing the assessee's appeal for statistical purposes.