2026 (4) TMI 193

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....The assessee is dissatisfied with the decision and has filed an appeal on several grounds that (1) the learned CIT(A) incorrectly classified a genuine investment as unexplained under section 69 of the Act; (2) documentary evidence substantiating the loss was overlooked; (3) capital loss was erroneously characterized as income; (4) section 115BBD was misapplied; and (5) there was a violation of the principles of natural justice. 2. The brief facts of the case indicate that the assessee filed his income tax return on 22 July 2018, declaring a total income of Rs.2,846,830 after claiming deductions of Rs.150,000 and other permissible deductions. The assessee reported a salary income of Rs.3,196,83....

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....f Rs.1,850,795. Upon review, the Assessing Officer rejected the assessee's contention and concluded that investments in bitcoin totaled Rs.18,50,795 according to available information, while bank statements reflected only Rs.1,250,000. Therefore, the balance sum of Rs.600,795 was added under Section 69 of the Income Tax Act, as per the assessment order passed under Section 147 read with Section 144B on 30 January 2020, resulting in the determination of the assessee's total income at Rs.3,447,625 compared to the returned income of Rs.2,846,813. 8. Dissatisfied with the above addition, the assessee challenged the inclusion of Rs.600,795 before the learned CIT(A). The assessee submitted its response to the learned CIT(A); however, the l....