Registered crypto-asset service providers and related platforms must capture and report user- and transaction-level VDA data under Section 285BAA of the Income-tax Act, 1961 (Section 509 of the Income-tax Act, 2025) — filed as Form 167 under Rule 243 of the Income-tax Rules, 2026. PJRJ helps exchanges, P2P/OTC desks, brokers, and Web3 intermediaries design reporting packs, validate nil filings, and keep books aligned with Schedule VDA and §194S / §393(1) TDS. We do not act as an FIU-IND registration agent.
Who this engagement is for
- Indian crypto exchanges and VDA trading platforms with reporting obligations
- OTC desks, brokers, and intermediaries facilitating VDA transfers
- P2P platforms that may qualify as crypto-asset service providers
- Fintechs adding VDA settlement rails that need tax-reporting controls
- Founders preparing for FIU registration who need books and Form 167 readiness first
What we deliver
Reporting-scope diagnostic
Map whether your activity triggers §509 / Form 167 duties, what data fields you must retain, and where nil filings still apply.
Transaction & KYC data pack
Reconcile user, trade, transfer, and settlement logs into a year-end statement pack that matches books and TDS returns.
Form 167 drafting support
Prepare and review Form 167 workings under Rule 243, including mandatory nil positions where there is no reportable activity.
§194S / §393(1) coordination
Align VDA withholding, challans, and quarterly returns with what Form 167 will report — so AIS mismatches do not surprise users or the platform.
Controls & process memo
Written checklist for ongoing logging from the compliance start date through the annual filing deadline.
Counsel handoff for FIU
Tax and books pack ready for specialist counsel if you pursue FIU-IND / VASP registration — PJRJ stays on the CA side of the fence.
Scope boundary: This desk is tax reporting, books, and TDS alignment for crypto-asset activity. Investment advice, exchange operation, and FIU registration agency work are out of scope.
How an engagement runs
- 1Share platform model, sample trade/settlement exports, and current TDS process
- 2We confirm reporting scope and gap-list data fields against Form 167 requirements
- 3Build the first-year pack (or remediation of incomplete logs)
- 4Partner review of Form 167 workings and related TDS/Schedule VDA consistency
- 5Handoff of controls memo for the next reporting cycle
Form 167 / CASP Reporting FAQs
No. Schedule VDA is the taxpayer’s ITR disclosure of VDA transfers. Form 167 is a service-provider reporting statement under the crypto-asset information framework (§509 / Rules 241–244). Platforms and users have different duties.
Often yes — nil filings can be mandatory where you are a reporting person. We confirm whether a nil statement applies to your facts before you assume “no activity = no form.”
No. We prepare tax, books, and reporting readiness. FIU / VASP registration is handled by specialist counsel; we coordinate the evidence pack.
Discuss your form 167 / casp reporting requirements
Speak directly with a PJRJ income tax specialist — we respond within one business day.