New Delhi, March 30 -- When taxpayers complain that the income tax department is adversarial, the issue is often framed as interpersonal and behavioural. Are officers too aggressive? Are notices too intrusive? Is the department predisposed to distrust the taxpayer?

These questions matter, but they misstate the problem. The real difficulty is institutional. It lies in the structure of enforcement, the design of adjudication and the failure to correct excesses quickly enough once they occur.

This distinction matters because the problem should not be overstated. India's direct tax administration has moved significantly towards automated, risk-based processing. Returns are centrally processed, refunds issued without interface and most taxpa...