Unexplained cryptocurrency expenditure addition fails where revenue lacks transaction-specific details and earlier presumptive income was accepted.

General information about cryptocurrency transactions without transaction-level particulars such as the specific coin, broker, dates, quantity, or trail was insufficient to sustain an addition as unexplained expenditure under section 69C. The same assessing unit had accepted presumptive income from the assessee's identical crypto activity in the preceding year, yet adopted a different approach for the purchase side in the year under review without a cogent factual basis. On those facts, the addition was held unjustified and deleted.

---

---

Issues: Whether the addition made under section 69C of the Income-tax Act, 1961 on account of alleged unexplained expenditure for purchase of cryptocurrency was sustainable when the same assessing unit had accepted presumptive income from the same crypto transactions in the preceding assessment year and the material relied upon lacked transaction-level particulars.

Analysis: The assessment was reopened on information regarding crypto currency transactions, but the information did not contain specific particulars such as the name of the cryptocurrency, broker details, dates, quantity, or transaction-wise trail. In the assessee's own case for the earlier year, the same assessment unit had accepted the returned income on presumptive basis from the sale of cryptocurrency and had not made any addition for the purchase side. For the year under appeal, the same unit adopted a different approach and treated the purchase value as unexplained expenditure under section 69C. The record did not disclose any cogent basis for such inconsistent treatment, and the assessee's disclosure of presumptive income was accepted for the preceding year on the same set of general information.

Conclusion: The addition under section 69C was not sustainable and was deleted in favour of the assessee.

Ratio Decidendi: Where the revenue relies on general crypto transaction information without transaction-specific particulars, and the same assessing unit has accepted presumptive income from the identical activity in an earlier year, a later addition of the purchase value as unexplained expenditure under section 69C without a consistent factual basis is unjustified.

---