Unexplained asset rules now include virtual digital assets, expanding deeming powers where explanations are unsatisfactory.
Where an asset is unrecorded or its recorded amount is less than actual value and the assessee fails to provide a satisfactory explanation, Clause 104 and Section 69B treat the unexplained excess as deemed income for the year of discovery; Clause 104 expressly adds virtual digital assets, while both provisions vest the Assessing Officer with discretion to accept or reject explanations, creating valuation and verification challenges.

Unexplained assets treated as deemed income: inclusion of virtual digital assets broadens taxable asset coverage and disclosure obligations.
Clause 104 deemsthe value of assets not recorded, or under recorded, in an assessee's books to be taxable income where the assessee fails to provide a satisfactory explanation; it expressly includes virtual digital assets and places onus on the assessee to prove the nature and source, leaving determination of adequacy to the Assessing Officer.