Statutory tax confidentiality bar limits both disclosure by officials and compulsory production before court, save narrow exceptions.

Section 57(1) of the Madras General Sales Tax Act, 1959 treats particulars in returns, accounts, registers, records and related documents as confidential and bars their disclosure. The statutory prohibition is not limited to the assessing officer; where disclosure is forbidden by the Act, the court also cannot compel production or admit the material in evidence. Disclosure is permitted only within the narrow exception in section 57(2)(iv), namely a civil suit to which the Government is a party and which concerns a matter arising out of proceedings under the Act. A prior contrary view was distinguished for not fully addressing the express confidentiality bar.

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Issues: Whether documents and assessment files falling within the confidentiality protection under section 57 of the Madras General Sales Tax Act, 1959 could be summoned, produced, and admitted in evidence by the court, and whether the statutory prohibition applied only to the assessing officer or also restricted the court.

Analysis: Section 57(1) declares particulars contained in statements, returns, accounts, registers, records, and other documents produced under the Act to be confidential and not to be disclosed. The prohibition is qualified only by the limited exception in section 57(2)(iv), which permits disclosure to a civil court in a suit to which the Government is a party and which relates to a matter arising out of proceedings under the Act. The court held that the statutory bar is not confined to the officer alone: where disclosure is prohibited by the Act, the officer cannot disclose the material and the court cannot compel production or admit such material in evidence. A prior decision permitting summons of records was distinguished on the ground that it did not fully consider the express prohibition on disclosure contained in section 57(1).

Conclusion: Documents covered by section 57(1) cannot be summoned or received in evidence, except to the extent permitted by the statutory exception.

Final Conclusion: The petition succeeded only in part, with protection preserved for confidential sales tax material falling within the statutory bar and the remainder left undisturbed.

Ratio Decidendi: Where a taxing statute expressly makes specified particulars confidential and prohibits their disclosure, the prohibition restrains both the custodian of the records and the court from compelling production, save within the statute's stated exception.

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