VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawConcepts › What counts as a VDA, and where you report it

What counts as a VDA, and where you report it

Are my loyalty points or my gift voucher a virtual digital asset, and where do I report crypto in my return?

Are my loyalty points or my gift voucher a virtual digital asset, and where do I report crypto in my return?

No. Section 2(47A) defines a virtual digital asset broadly as information, code, number or token generated through cryptographic means, plus notified NFTs and other notified digital assets — but CBDT has expressly excluded gift cards and vouchers, mileage and reward points, and subscriptions to websites, platforms or applications, and Indian currency, foreign currency and CBDCs are outside the definition to begin with. Crypto income is reported in Schedule VDA, which appears in ITR-2 and ITR-3 but not ITR-1 or ITR-4.

This is an explainer, not a judgment. It states the law in our own words, which is exactly why it needs checking. Everything below was written from the sources listed at the foot of this page, and no chartered accountant has yet signed it off. Read the source before you rely on it in a reply or an appeal.

Section 2(47A) was inserted by the Finance Act 2022. In substance it covers three things: any information, code, number or token, not being Indian currency or foreign currency, generated through cryptographic or other means and providing a digital representation of value that is exchanged with or without consideration or functions as a store of value or unit of account; a non-fungible token or other token of a similar nature as notified; and any other digital asset the Central Government notifies. The Finance Act 2025 widened it further to take in a crypto-asset that is a digital representation of value relying on a cryptographically secured distributed ledger.

What is out. Indian currency and foreign currency are excluded by the definition itself, and so are central bank digital currencies. Beyond that, CBDT used its notification power. Notification 74/2022 dated 30 June 2022 excludes three categories: gift cards and vouchers, meaning a record usable to obtain goods or services or a discount on them; mileage points, reward points and loyalty cards given without direct monetary consideration under an award, benefit, loyalty, incentive, rebate or promotional programme, and redeemable only for goods, services or a discount; and a subscription to a website, platform or application.

NFTs were narrowed by Notification 75/2022 of the same date. A token whose transfer results in the transfer of ownership of an underlying tangible asset, and where that transfer of ownership is legally enforceable, is excluded — so a genuinely asset-backed token is not a VDA, while a purely digital collectible is.

The department's own material puts these exclusions together plainly: crypto assets, NFTs and other digital assets are in; Indian currency, CBDCs, foreign currency, physical asset-backed NFTs, gift cards and vouchers, reward points and loyalty cards, and website or application subscriptions are out.

Reporting runs through Schedule VDA. It is a dedicated schedule in ITR-2 and ITR-3; ITR-1 and ITR-4 cannot be used at all by someone with VDA income. ITR-2 is the form for a holder treating VDAs as investments with no business income; ITR-3 is for someone with crypto business income such as mining or trading treated as a business.

Schedule VDA is transaction-level, not a summary. For each transaction you enter the date of acquisition, the date of transfer, the cost of acquisition and the sale consideration, and the portal computes the gain or loss. That is deliberate — because section 115BBH allows no set-off, the return has to see each disposal separately rather than a netted figure. Foreign-held VDAs also need to be considered for Schedule FA, where non-disclosure carries Black Money Act exposure.

The reporting net is tightening on the other side too. The Finance Act 2025 inserted section 285BAA, requiring prescribed reporting entities — exchanges and other intermediaries — to furnish information on crypto-asset transactions, with effect from 1 April 2026. The same Act brought VDAs within the definition of undisclosed income for block assessment under section 158B, so unreported crypto found in a search is taxed under the block assessment regime rather than as ordinary income.

The practical instruction for a return being filed now is to reconcile Schedule VDA against the AIS. The 1% deducted under section 194S by exchanges already reports your transactions to the department, so what you file has to match what the exchange filed.

Why it matters

The definition decides whether the flat 30% and the 1% withholding apply at all, and the exclusions are wide enough that a lot of digital value — vouchers, loyalty programmes, subscriptions — is simply outside the regime. Getting the form wrong is a separate risk: ITR-1 and ITR-4 cannot carry VDA income, so filing one is defective. And once section 285BAA reporting starts, the department has an independent feed against which Schedule VDA gets matched.

What to do

Where people go wrong

Unsettled, or not pinned down. I did not fetch the bare text of section 2(47A) itself; the definition here is assembled from the department's own VDA publication and from professional summaries, so the exact sub-clause wording is not verified. The Schedule VDA column list comes from a commercial tax guide rather than the ITR instructions, and the department's Schedule VDA page would not load for me. Section 285BAA's prescribed entities, forms and timelines were not available from any page I fetched beyond the fact that the obligation applies from 1 April 2026. The Income-tax Act, 2025 came into force on 1 April 2026 and renumbers these provisions for tax year 2026-27 onwards, while the 1961 Act continues to govern earlier years including AY 2026-27.

Authorities on these sections

Judgments in this library that turn on the same provisions.

Where this came from

Every page in this library links to what it was written from, so you can check it rather than take our word for it.