AI-generated invoices may be legally recognisable in India, but scrutiny turns on something harder than neat drafting: provenance, system control, metadata, and whether the transaction trail still holds under challenge.
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 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 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.
