Where a taxpayer persistently fails to disclose income or assets despite statutory opportunities, the Income Tax Department may, as a measure of last resort, resort to search and seizure proceedings, including access to digital records.

The Supreme Court noted that the appellant suppressed the fact that it had already filed an NCLAT appeal when it approached the High Court, terming this conduct “clandestine” and an abuse of process.

The Supreme Court noted that the appellant suppressed the fact that it had already filed an NCLAT appeal when it approached the High Court, terming this conduct “clandestine” and an abuse of process.