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Digital Search Power Under The Income Tax Act, 2025: From Physical Seizure To Virtual Intrusion




Khushbu Choudhary, Advocate, Rajasthan High Court, Jodhpur


ABSTRACT


The proposed Income Tax Act, 2025, seeks to significantly expand the investigative powers of tax authorities by introducing the concept of “virtual digital space,” granting them extensive access to an individual’s digital life. This comment examines the constitutionality of these proposed powers, tracing the evolution of search and seizure jurisprudence in India from a state centric interpretation to a robust, individual-centric fundamental right to privacy. It critically analyses the Act’s provisions against the backdrop of landmark Supreme Court decisions, particularly Justice K.S. Puttaswamy v. Union of India. The central thesis argues that while modernizing tax enforcement is necessary, the Act, in its current form, lacks essential procedural safeguards, such as a judicial warrant requirement and the principle of data minimalization. This transforms a legitimate investigative tool into a mechanism for unconstitutional surveillance, posing a great threat to informational privacy, the right against self-incrimination under Article 20(3), and the very fabric of a free and democratic society. The comment concludes by recommending a framework of robust constitutional and statutory safeguards to balance the state’s fiscal interests with the citizen’s fundamental rights.



Indian Journal of Law and Legal Research

Abbreviation: IJLLR

ISSN: 2582-8878

Website: www.ijllr.com

Accessibility: Open Access

License: Creative Commons 4.0

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All research articles published in The Indian Journal of Law and Legal Research are fully open access. i.e. immediately freely available to read, download and share. Articles are published under the terms of a Creative Commons license which permits use, distribution and reproduction in any medium, provided the original work is properly cited.

 

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The opinions expressed in this publication are those of the authors. They do not purport to reflect the opinions or views of the IJLLR or its members. The designations employed in this publication and the presentation of material therein do not imply the expression of any opinion whatsoever on the part of the IJLLR.

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