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.

E-invoice and e-way bill cancellation after completion of goods movement is raised where the vehicle had reached its destination before cancellation. The e-invoice and e-way bill were cancelled within 24 hours, and a new invoice was generated without a fresh e-way bill because transport had concluded. The concern is whether this sequence may create future GST compliance implications.

Section 78 of the Information Technology Act, 2000 assigns investigation of every offence under that Act to a police officer not below the rank of Deputy Superintendent of Police. The requirement operates notwithstanding anything contained in the Code of Criminal Procedure, 1973, and prescribes the minimum police rank competent to investigate offences under the Act.

Penalty or confiscation under the Information Technology Act, 2000 does not bar any other punishment to which the affected person remains liable under any other law in force.

Computers, computer systems, storage media, tape drives, and related accessories may be confiscated where connected with a contravention of the Information Technology Act, 2000, or subordinate rules, orders, or regulations. If the adjudicating court finds that the person possessing or controlling the equipment was not responsible for the contravention, it may decline confiscation and make another authorised order against the responsible contravener.

Section 75 applies the Information Technology Act, 2000 to offences and contraventions committed outside India irrespective of nationality. Its extra-territorial operation requires that the act or conduct constituting the offence or contravention involve a computer, computer system, or computer network located in India.

Fraudulent or unlawful handling of Digital Signature Certificates is criminalised when a person knowingly creates, publishes, or otherwise makes a certificate available for that purpose. The offence encompasses each specified mode of certificate dissemination and requires knowledge of the fraudulent or unlawful purpose. Punishment may include imprisonment for up to two years, a fine up to one lakh rupees, or both.

Section 73 prohibits publishing or otherwise making an electronic signature certificate available with knowledge that the listed Certifying Authority did not issue it, the named subscriber did not accept it, or the certificate has been revoked or suspended. Publication solely to verify an electronic signature created before suspension or revocation is permitted. Contravention is punishable with imprisonment, fine, or both.

Confidentiality and privacy protection imposes a monetary penalty of up to five lakh rupees where a person, while exercising powers under the Information Technology Act, 2000, or its rules or regulations, obtains access to electronic records, information, documents, or other material and discloses it to another person without the concerned person's consent.

Section 71 criminalises misrepresentation and suppression of material facts made to the Controller or Certifying Authority for obtaining a licence or Digital Signature Certificate. The offence is punishable by imprisonment for up to two years, a fine up to one lakh rupees, or both.

Section 70 permits the appropriate Government to declare a computer, computer system or computer network a protected system through notification in the Official Gazette. Persons may access a notified protected system only when authorised by a written order. Securing or attempting to secure access in contravention of these requirements is punishable with imprisonment for up to ten years and a fine.

Controller-authorised interception may be directed to a Government agency where necessary or expedient for sovereignty or integrity, State security, friendly relations with foreign States, public order, or prevention of incitement to a cognizable offence. Subscribers and persons in charge of computer resources must provide facilities and technical assistance to decrypt information when called upon by the directed agency. Failure to provide decryption assistance is punishable with imprisonment extending to seven years.

Section 68 empowers the Controller to direct a Certifying Authority or its employee to take specified measures or stop specified activities when necessary to secure compliance with the Act, rules, or regulations. Failure to comply constitutes an offence punishable on conviction by imprisonment up to three years, a fine up to two lakh rupees, or both.

Section 67 of the Information Technology Act, 2000 criminalises publishing, transmitting, or causing the publication or transmission of obscene material in electronic form. The prohibition applies to material that is lascivious, appeals to prurient interest, or tends to deprave and corrupt likely readers, viewers, or listeners. It prescribes imprisonment and fine for a first conviction, with enhanced penalties for repeat convictions.

Section 66 criminalises dishonest or fraudulent performance of an act covered by section 43. The offence is punishable by imprisonment extending to three years, a fine extending to five lakh rupees, or both. The terms "dishonestly" and "fraudulently" have the meanings assigned under the Indian Penal Code.

Knowingly or intentionally concealing, destroying, altering, or causing alteration of computer source code required by law to be maintained constitutes an offence. The prohibition covers source code used for a computer, computer programme, computer system, or computer network. Computer source code includes programme listings, computer commands, design and layout, and programme analysis of a computer resource. The offence is punishable with imprisonment, fine, or both.