Tag: Tax Litigation
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Digital evidence in search cases: why metadata risk is becoming the real battleground
Digital evidence in search cases is changing how tax disputes are built and defended. Metadata, audit trails and system history now shape the burden of explanation far more than many taxpayers realise
Section 148 vs revision vs search: which battlefield is the Department choosing now?
Section 148 still dominates tax conversations, but reopening is no longer the Department’s only preferred battlefield. In 2025–26, revision is increasingly the cleaner weapon against weak assessments, while search has been pushed into a separate, evidence-heavy block-assessment track.
Section 263 in the new regime: cleaner drafting, same legal gate
Section 263 has moved to section 377 under the Income-tax Act, 2025, but the real story is not the renumbering. It is the cleaner limitation machinery, tighter transition rules, and the continuing risk from weak assessment records.
DIN validity after Circular 4/2026: when a missing trail is fatal and a quoting slip is not
CBDT Circular 4/2026 and the Finance Act, 2026 have changed the DIN debate. A missing audit trail can still be fatal, but a mere quoting defect is now harder to weaponise.
Block assessment’s return: efficient anti-evasion design or a new constitutional battleground?
Block assessment is back in India’s search-tax architecture, promising faster anti-evasion action but reopening a harder question: can speed, abatement and compressed procedure coexist with taxpayer safeguards?
