Bona fide public-interest foundation is required before seeking a court direction for further income-tax enquiry.

Judicial intervention to compel income-tax enquiry requires a bona fide public-interest foundation and concrete supporting material; unsupported allegations about undisclosed income and assets, especially where the department has already examined the complaints and the assessees' returns and sources of funds were scrutinised, do not warrant further revenue action. The court found no credible factual basis for the petition, treated it as an attempt to pursue a private grievance, and declined the relief on maintainability grounds.

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Issues: Whether the original petition seeking a direction to the income-tax authorities to enquire into the fifth respondent's assets and take action for alleged undisclosed income disclosed any merit warranting judicial interference.

Analysis: The material before the Court showed that the income-tax authorities had already examined the petitioner's complaints and found them unsubstantial. It was also noticed that the fifth respondent and his family were regular assessees, their returns were being scrutinised, their sources of funds had been verified, and they had availed of the voluntary disclosure scheme by declaring income and paying tax. The Court found that no concrete material had been produced to support the allegations and that the petition did not disclose bona fides or a genuine public interest basis for invoking judicial intervention. A petition of this nature cannot be used to pursue private grievance or to compel revenue action absent credible factual foundation.

Conclusion: The petition was not maintainable on the facts and the relief sought was declined.

Final Conclusion: The proceeding failed as an unsupported and bona fide-deficient attempt to compel further revenue action, and was dismissed.

Ratio Decidendi: Judicial intervention in revenue matters on a public-interest footing requires a bona fide foundation and concrete supporting material; allegations unsupported by credible facts and already examined by the department do not justify a direction for further enquiry or action.

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