Arm's-length commission paid to an Indian dependent agent exhausts the profits attributable to the agency permanent establishment under Article 7 of the India-Singapore tax treaty. Where the agent's commission is accepted as arm's length, no additional profits may be attributed to the Indian permanent establishment absent new material facts or a change in law. Applying the approach followed for identical preceding years, the additional attribution of profit was deleted.

Section 68 requires the assessee to establish the identity, creditworthiness and genuineness of credited receipts. Recorded sales supported by ledgers, invoices, inventory and sales records, tax-paid invoices, and banking-channel payments establish their nature and source; unverified third-party statements or unserved purchaser notices alone do not displace such evidence. Share application receipts supported by investor confirmations, PAN details, corporate records, tax returns and audited financial statements similarly establish the investors and the genuineness of investments. An adverse inference based on a later inspection, without further verification or rebuttal of the documentary record, is insufficient for an unexplained-cash-credit addition.

Employees' ESIC contributions paid after the prescribed due date are not deductible merely because payment occurs before the return-filing date. Depreciation at 60% is allowable. Interest on capital funds connected with proposed business expansion is not capitalisable absent an established basis for capitalisation. Commission expenditure remains disallowed where recipient responses do not rebut the disallowance or supporting details are missing. Cash-credit additions for deposits in a minor's bank account are not sustainable when the deposits have been explained. Taxable income is modified by allowing depreciation and deleting the interest-capitalisation and cash-credit additions.

Reassessment notices issued more than three years after the relevant assessment year required prior approval from the senior authorities specified under Section 151(ii) in the reassessment framework effective from 1 April 2021. Approval by a Principal Commissioner was insufficient for a notice issued after that period. The later proviso excluding time allowed under Section 148A(b), effective from 1 April 2023, did not retrospectively cure the applicable approval requirement. Absence of approval from the competent specified authority created a jurisdictional defect, rendering the reassessment void.

Reassessment notices issued more than three years after the relevant assessment year require prior approval from the senior authorities specified in Section 151(ii); approval by a Principal Commissioner is insufficient and deprives the proceedings of jurisdiction. The period for responding under Section 148A(b) cannot be retrospectively excluded from the three-year calculation under a later proviso without express legislative intent. Jurisdictional objections may be admitted as additional grounds where they arise on the existing record and require no new facts. Business disruption, illness and financial hardship can establish sufficient cause for delay.

Post-delivery cancellation of an e-way bill and issuance of a replacement invoice without a fresh e-way bill may create a GST compliance concern, even where no further vehicle movement occurs. Where the original e-way bill was valid during actual movement and the e-invoice or IRN was cancelled within the prescribed period for a genuine correction, complete cancellation, invoice, e-way bill, delivery, and correction records should be retained.

Section 78 assigns investigation of offences under the Information Technology Act, 2000 to a police officer not below the rank of Inspector, notwithstanding anything contained in the Code of Criminal Procedure, 1973. The investigating-officer threshold was changed from Deputy Superintendent of Police to Inspector through the Information Technology (Amendment) Act, 2008, with effect from 27 October 2009.

Section 77 preserves other legal consequences where compensation is awarded, a penalty imposed, or confiscation made under the Information Technology Act, 2000. Such measures do not bar compensation, penalties, or punishment available under another law in force. The substituted formulation expands the earlier scope by adding compensation and other penalties to the consequences that may coexist with sanctions under other applicable law.

Computer equipment and related accessories are liable to confiscation when connected with a contravention of applicable statutory provisions, rules, orders, or regulations. An adjudicating court may decline confiscation where the person possessing, controlling, or having power over the property was not responsible, and may make another authorised order against the responsible contravener.

Extra-territorial application of the Information Technology Act, 2000 covers offences and contraventions committed outside India by any person, irrespective of nationality. Coverage depends on whether the conduct constituting the offence or contravention involves a computer, computer system or computer network located in India, making the location of relevant digital infrastructure the connecting factor.

Knowingly creating, publishing, or otherwise making an electronic signature certificate available for a fraudulent or unlawful purpose is an offence. It is punishable with imprisonment up to two years, a fine up to one lakh rupees, or both. The terminology replaces "digital signature" with "electronic signature".

Section 73 prohibits publication or availability of an electronic signature certificate where the publisher knows that it was not issued by the named Certifying Authority, was not accepted by the named subscriber, or has been revoked or suspended. Publication to verify an electronic signature created before suspension or revocation remains permitted. Contravention is punishable by imprisonment, fine, or both.

Section 72 imposes liability where a person exercising statutory powers obtains access without consent to electronic records, correspondence, information, documents or other material and discloses it to another person. The provision operates subject to contrary permission under applicable law. Unauthorised disclosure attracts a monetary penalty that may extend to five lakh rupees, replacing the earlier consequence of imprisonment, a fine, or both.

Section 71 criminalises misrepresentation or suppression of material facts before the Controller or a Certifying Authority for obtaining a licence or an electronic signature Certificate. The offence may result in imprisonment, fine, or both. The expression "electronic signature" replaced the earlier expression "digital signature" through the 2008 amendment.

Section 70 establishes a protected-system regime for computer resources affecting Critical Information Infrastructure. The appropriate Government may notify such resources as protected and authorise access only through written orders. Unauthorised access or attempted access to a protected system is punishable with imprisonment and fine. The Central Government must prescribe information-security practices and procedures for protected systems.

Section 69 permits specially authorised Government officers to issue written orders for interception, monitoring or decryption of information in a computer resource on specified security, public-order, anti-incitement, or investigation grounds. Reasons must be recorded in writing and prescribed procedures and safeguards apply. Subscribers, intermediaries and persons in charge must provide access, technical assistance, interception, monitoring, decryption, or stored information when required. Failure to comply is punishable by imprisonment and fine.

Controller's power to issue binding directions enables an order requiring a Certifying Authority or its employee to undertake specified measures or discontinue specified activities where necessary to secure compliance with applicable statutory provisions, rules, or regulations. Intentional or knowing non-compliance with a Controller's direction constitutes an offence and attracts a monetary penalty.

Section 67 criminalises publishing, transmitting, or causing publication or transmission in electronic form of material that is lascivious, appeals to prurient interest, or tends to deprave and corrupt persons likely to encounter it. Liability depends on the material's character and likely effect in the relevant circumstances. Punishment escalates for repeat convictions, and the substituted provision modified the scope of causative transmission and the maximum punishments under the earlier version.

Section 66 imposes criminal liability on any person who dishonestly or fraudulently commits an act covered by section 43. The offence is punishable with imprisonment for up to three years, a fine up to five lakh rupees, or both. The expressions "dishonestly" and "fraudulently" take their meanings from the Penal Code.

Knowingly or intentionally concealing, destroying, altering, or causing another person to do so with computer source code constitutes an offence where the code must be kept or maintained by law. Computer source code includes programme listings, commands, design and layout, and programme analysis in any form. Punishment may include imprisonment, fine, or both.