Capital vs revenue lines are fraying in India’s digital economy. SaaS subscriptions, cloud infrastructure, and data-driven intangibles create enduring benefits without durable assets, forcing doctrine to chase new facts
A tax opinion in 2026 survives less on elegant citation than on facts, disclosure and process. As scrutiny gets more data-rich, defensibility now begins long before the notice arrives.
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
