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    <title>2025 (1) TMI 1640 - ITAT SURAT</title>
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    <description>ITAT upheld that unexplained DKD cryptocurrency investments are limited to 193,123 coins and must be valued at USD 2 per coin (Rs.130), rejecting a higher valuation; bonus, referral and lending benefits not realized cannot be taxed. Additions treating separate lending/non-lending accounts as distinct were disallowed as presumptive. ATC investment was restricted to 98,560 coins with duplicate additions deleted; one ATC addition was sustained where the assessee failed to prove third-party ownership. No addition for alleged sale of bonus ATC coins or alleged undisclosed business income for want of corroborative evidence. Renovation expenditure additions were substantially reduced by allowing a 25% adhoc disallowance.</description>
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    <pubDate>Thu, 23 Jan 2025 00:00:00 +0530</pubDate>
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      <title>2025 (1) TMI 1640 - ITAT SURAT</title>
      <link>https://www.taxtmi.com/caselaws?id=464525</link>
      <description>ITAT upheld that unexplained DKD cryptocurrency investments are limited to 193,123 coins and must be valued at USD 2 per coin (Rs.130), rejecting a higher valuation; bonus, referral and lending benefits not realized cannot be taxed. Additions treating separate lending/non-lending accounts as distinct were disallowed as presumptive. ATC investment was restricted to 98,560 coins with duplicate additions deleted; one ATC addition was sustained where the assessee failed to prove third-party ownership. No addition for alleged sale of bonus ATC coins or alleged undisclosed business income for want of corroborative evidence. Renovation expenditure additions were substantially reduced by allowing a 25% adhoc disallowance.</description>
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      <pubDate>Thu, 23 Jan 2025 00:00:00 +0530</pubDate>
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