Third-party intervention in reassessment proceedings is not permissible absent statutory authority, preserving confidentiality and assessee-specific jurisdiction.

Assessment and reassessment proceedings under the Income-tax Act are confined to the revenue and the concerned assessee, and a third party has no participatory right unless the statute expressly permits it, such as by way of witness participation. Findings recorded in one assessee's assessment do not bind proceedings against another assessee, and assessment material remains confidential except where disclosure is authorised by law. Because the dispute concerned only the statutory authority's jurisdiction to initiate reassessment, a stranger could not seek impleadment or intervention, and the application was rejected as not maintainable.

---

---

Issues: Whether a third party could be impleaded in, or permitted to intervene in, proceedings concerning initiation of reassessment under the Income-tax Act.

Analysis: The assessment and reassessment process is confined to the revenue and the concerned assessee, and third parties have no role in such proceedings except where the statute permits their participation as witnesses. Findings recorded in one assessee's assessment are not binding in proceedings against another assessee, and the material remains confidential except to the extent disclosure is authorised by law. Since the dispute concerned only the jurisdiction of the statutory authority to initiate proceedings, no stranger could claim a participatory role.

Conclusion: The application for impleadment or intervention was not maintainable and was rejected.

---