India has regulated virtual digital assets for five years without ever legislating a framework for them. This paper maps that architecture and asks whether the developments of 2026, a private member’s tokenisation bill, a parliamentary committee report favouring an interim self-regulatory model, and open conflict between the Reserve Bank of India and the Securities and Exchange Board of India, amount to the beginning of a real supervisory regime or another layer of ad hoc improvisation. The paper begins with the Supreme Court’s decision in Internet and Mobile Association of India v. Reserve Bank of India, which struck down the Reserve Bank’s 2018 banking ban on proportionality grounds while leaving its underlying regulatory authority intact, a ruling this paper argues created the permissive vacuum everything since has worked around. It examines how the Finance Act, 2022 filled that vacuum through taxation rather than regulation, defining virtual digital assets for the first time in Indian law solely to impose a flat thirty per cent tax and a one per cent deduction at source, a regime the Income-tax Act, 2025 has carried forward unchanged, and how the March 2023 notification under the Prevention of Money Laundering Act added a second, overlapping layer of control. It examines the WazirX hack of 2024, where the Supreme Court dismissed the victims’, petition as raising a question of policy and recourse came eventually through a scheme of arrangement sanctioned in Singapore rather than through Indian law, as a concrete illustration of what this approach fails to deliver. Turning to 2026, the paper studies the Asset Tokenisation Regulation Bill, SEBI’s proposed multi-regulator model, and the Standing Committee’s thirty sixth report, against the Reserve Bank’s preference for the Digital Rupee over legalisation. The paper argues that taxing and surveilling an asset class without defining it in regulatory terms has produced revenue and compliance data but little investor protection, and that the proposed multi-regulator model’s coordination costs deserve scrutiny before Parliament settles on it. It closes with recommendations drawing on comparative regimes in the United States, the United Kingdom, the European Union, and Singapore.