• India is issuing Section 148A notices that can reopen past crypto filings for review.
• Systems may flag estimated income that does not reflect actual profits, increasing exposure.
• Data mismatches across exchanges and tax filings can escalate scrutiny and potential penalties.

Indian tax authorities are stepping up enforcement efforts targeting cryptocurrency transactions, especially those from earlier financial years now under review. Section 148A notices are reportedly being issued to taxpayers where discrepancies in reported income are flagged through advanced data-matching systems. These notices act as preliminary reassessment triggers, giving individuals an opportunity to justify potential undisclosed income before formal proceedings begin. Much of the current scrutiny centers on financial year 2021–22 and suspected gaps in tax reporting compliance.

Crypto tax platform Koinx shared on April 6 insights about these developments. The company stated on social media platform X:

“148A notices are now being issued to crypto investors in India.”

“Many relate to FY 2021–22 transactions,” the crypto tax platform affirmed, clarifying: “This number is often NOT your actual profit. It’s just what the system thinks is income … Until you prove otherwise.”

The firm explained that such notices are triggered when authorities detect inconsistencies in financial data. The flagged amounts often reflect system-derived estimates rather than confirmed taxable profits.

Koinx detailed how India’s Income Tax Department evaluates crypto activity using internal surveillance systems and risk engines. The Insight Portal and CRIU infrastructure analyze financial activity across multiple datasets. These systems compare PAN-linked KYC details, exchange trading activity, bank transfers, and filed income tax returns. Any mismatch across these sources can trigger a notice under Section 148A for further review. The company emphasized that the taxpayer’s response determines whether reassessment proceeds, stating:

“A 148A notice is not a tax demand yet. It’s a show-cause notice. Meaning the department is asking: ‘Explain why we should not reopen your assessment.’
Your response determines what happens next.”

The firm also highlighted structural issues when traders use multiple exchanges and wallets across different platforms. For example, the firm outlined a common transaction path where assets move across Coinswitch, Binance, private wallets, and Wazirx. In such scenarios, the tax system may capture only one segment of the transaction chain rather than the complete flow. This limited visibility can lead to mismatched records and inflated income assumptions. As a result, fragmented tracking may misrepresent actual trading activity and overstate income levels. Authorities often interpret gross turnover as income rather than net profit.

In one example, a trader may have executed transactions totaling ₹1.6 crore (approximately $172K) in volume during the year. The actual profit from those trades could be only ₹4–5 lakh (approximately $4,300–$5,400) after accounting for costs and losses. However, the system may initially flag the entire ₹1.6 crore (approximately $190,000) as deemed income until the taxpayer provides clarification.

Koinx urged that recipients should remain calm and act promptly to address the notice with accurate data. The tax firm stated: “If you receive this notice, do NOT panic.” The platform advised reconstructing complete transaction histories, calculating actual gains or losses, preparing accurate tax computations, and submitting supporting evidence. Noting that proper documentation and timely responses remain critical as enforcement systems continue expanding, the company concluded:

“Most notices can be resolved if your data is correct.”

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