The petitioner submitted that all relevant documents, including e-way bills, invoices, payment slips, and bank details, had been furnished to establish the genuineness of the transactions

It stated that the Revenue must examine the reasons for the difference and establish that the amount is indeed consideration for services, ruling out presumptions.

“There can be no doubt that ‘crypto currency’ is a property. It is not a tangible property nor is it a currency. However, it is a property, which is capable of being enjoyed and possessed (in a beneficial form). It is capable of being held in trust."