Data Fiduciaries must obtain verifiable consent from a child's parent or lawful guardian before processing a child's personal data and must not undertake processing likely to harm the child's well-being. Tracking, behavioural monitoring and targeted advertising directed at children are prohibited. Prescribed exemptions may apply to specified Data Fiduciaries, purposes and conditions. Where processing is verifiably safe, an age-based exemption may apply to specified consent and child-protection obligations.

Data Fiduciaries remain responsible for compliant personal-data processing undertaken by them or by Data Processors, who may be engaged only under valid contracts. They must maintain data quality for consequential decisions or disclosures, implement technical and organisational compliance measures, maintain reasonable security safeguards, and notify the Board and affected Data Principals of breaches. Personal data must be erased on consent withdrawal or when its purpose ends, unless legal retention is required, including erasure by Data Processors. They must also publish appropriate contact information and provide effective grievance redressal.

A Data Fiduciary may process personal data for the specified purpose for which a Data Principal voluntarily supplies it, provided the Data Principal has not indicated non-consent, and must cease processing when requested assistance is no longer required. Processing is also permitted for prescribed State benefits and functions, legally required disclosures, compliance with judgments or orders, medical emergencies, public-health threats, disasters, public-order breakdowns, and employment purposes. Employment-related processing includes protection against loss or liability, prevention of corporate espionage, confidentiality of trade secrets, intellectual property or classified information, and provision of employee-requested services or benefits.

Consent-based personal data processing requires free, specific, informed, unconditional and unambiguous affirmative consent, limited to data necessary for a specified purpose. Consent requests must use clear language, permit access in English or a listed constitutional language, and provide rights-related contact details. Consent may be withdrawn as easily as it is given; the Data Fiduciary and its Data Processors must then cease processing within a reasonable time unless otherwise authorised by law. The Data Fiduciary must prove compliant notice and consent where disputed.

Data Fiduciaries must provide notice before or with a consent request, identifying the personal data proposed for processing, its purpose, the means to exercise statutory rights, and the complaint mechanism. For consent obtained before commencement, notice must be provided as soon as reasonably practicable, and processing may continue until consent is withdrawn. Notices must be accessible in English or an Eighth Schedule language.

Personal data processing is permitted only in accordance with the Act and for a lawful purpose. Processing a Data Principal's personal data may proceed where the Data Principal has given consent or where it falls within certain legitimate uses. A lawful purpose is one not expressly forbidden by law.

Digital Personal Data Protection Act, 2023 applies to processing of digital personal data within India when collected digitally or subsequently digitised, and to certain processing outside India connected with offering goods or services to Data Principals in India. Coverage excludes personal data processed for personal or domestic purposes and data publicly made available by the Data Principal or by a person legally obliged to disclose it.

Processing comprises wholly or partly automated operations on digital personal data, including collection, storage, use, sharing, restriction, erasure and destruction. A personal data breach includes unauthorised processing or accidental disclosure, acquisition, sharing, use, alteration, destruction or loss of access that compromises confidentiality, integrity or availability. A Data Fiduciary determines the purpose and means of processing, while a Data Processor acts on its behalf. Consent Managers enable Data Principals to give, manage, review and withdraw consent through an accessible, transparent and interoperable platform.

Digital Personal Data Protection Act, 2023 establishes a framework for processing digital personal data that recognises individuals' interest in protecting personal data while permitting processing for lawful purposes. Commencement is not fixed automatically by enactment: provisions take effect on dates appointed by the Central Government through notification in the Official Gazette, with different provisions capable of entering into force on different dates.

Fees collected for investment advisory services provided without required registration cannot be retained merely because no investor responds to a refund invitation. Such amounts must be deposited with the regulator, which must invite and verify investor claims. Any balance remaining unclaimed after that process must be transferred to the Investor Protection Fund. The absence of refund claims does not legitimise retention of fees earned through unregistered investment advisory activity.

Digital personal data may be processed only for a lawful purpose based on valid consent or specified legitimate uses. Consent must be free, specific, informed, unconditional and unambiguous, supported by clear notice, and withdrawable with comparable ease. Data Fiduciaries remain responsible for processing undertaken by themselves or their processors, must maintain security safeguards, notify personal data breaches, erase data when no longer needed unless legal retention is required, and provide grievance redressal. Children's data requires verifiable parental or guardian consent, with restrictions on harmful processing, tracking, behavioural monitoring and targeted advertising.

Section 153D prior approval for search assessments requires the approving authority to independently examine draft assessment orders, assessment records and relevant search material for each assessment year. A composite approval issued without evidence of record movement, separate year-wise consideration, reasons or verification indicates a routine and mechanical exercise rather than informed statutory approval. Approval granted in this manner is invalid for want of application of mind, and assessment orders founded on it are vitiated and liable to be quashed.

In an unabated assessment under Section 153A, additions require incriminating material found during the search and a link between that material and the proposed addition. An unsecured-loan addition lacking that nexus is unsustainable. Alleged unexplained-expense additions are likewise unsustainable where seized entries are reconciled with agreements and books, verification reveals no adverse discrepancy, and the transactions represent genuine accounted business dealings. These principles support deletion of additions founded on recorded expenses or loans unconnected with incriminating search material.

Transfer-pricing benchmarking under the Transactional Net Margin Method requires a disclosed, reasoned functional, asset and risk analysis to support comparable-company exclusions and selections across distribution, software-development and technical-support segments. Absent that analysis, comparability determinations require fresh, transparent evaluation with an opportunity to submit evidence. Deferred payment or receivables exceeding the agreed credit period constitute a separate international transaction, because only credit within that period is embedded in the sale price. Foreign-currency delayed receivables require separate interest benchmarking at LIBOR plus a 200-basis-point spread.

Brand-development outlays incurred in an existing business are revenue expenditure where they support the profit-earning process and create no capital asset; commercial expediency cannot be displaced without evidence of non-business purpose. Additional deduction claims may be considered in appellate proceedings, and accrued redemption premium on transferable zero-coupon debentures is deductible where no identifiable payee gives rise to withholding obligations. Corporate guarantees require a service charge but are not benchmarked as bank guarantees; a 0.2% fee reflected limited benefit. Aircraft treated as aeroplanes qualify for 40% depreciation. Investment shares consistently held as investments and sold through limited delivery-based transactions generate capital gains, supported by consistency of past treatment.

Freight income from operating ships in international traffic qualifies for exemption under Article 8 of the India-Singapore tax treaty where eligibility is undisputed. Where such income was offered under section 44B because the return form did not permit a direct treaty-exemption claim, relief under section 90 must be granted. An incorrect treaty-country code in the original return cannot justify denial when a revised return corrected the code to Singapore but was not processed. Relief is to be granted for eligible income after an opportunity of hearing.

Penalty for failure to obtain an audit under Section 44AB cannot be sustained where the assessee proves reasonable cause under Section 273B. Dependence on a person responsible for business and regulatory compliance, that person's death, and the assessee's disability and resulting inability to manage the business showed that the default was neither deliberate nor lacking in bona fides. These circumstances constituted reasonable cause, making the penalty for audit non-compliance unsustainable.

Charitable exemption may not be denied in return processing solely because Form No. 10B was filed after the prescribed date where the audit report was available before the intimation. The filing deadline for the audit report is treated as procedural and directory in those circumstances, with timely availability before processing constituting substantial compliance. The condonation route for delayed filing operates as an additional remedy and does not exclude appellate review of an adjustment to the exemption claim. Consequently, refusal to condone delay need not prevent appellate consideration or acceptance of the exemption claim.

Jurisdictional objections to reassessment may be raised collaterally in an appeal against revision under section 263 because revision presupposes a legally valid assessment order. A defect in the authority to initiate reassessment cannot be cured by waiver, acquiescence, participation, or failure to challenge the reassessment directly. Where more than three years have elapsed, section 151(ii) requires sanction from the Principal Chief Commissioner or Chief Commissioner; approval by the Principal Commissioner under section 151(i) does not meet that condition. Reassessment without competent sanction is void ab initio and cannot support revisionary jurisdiction under section 263.

Reassessment notices issued in a deceased assessee's name lack jurisdiction where death preceded their issuance. Failure by legal representatives to inform tax authorities of the death does not validate proceedings against a non-existent person. Section 159 permits continuation only of proceedings validly initiated during the assessee's lifetime against legal representatives. This defect is jurisdictional, not procedural, and cannot be cured under Section 292B; the notice, order under Section 148A(d), and consequential reassessment proceedings are void ab initio.