Statutory confidentiality of tax returns bars disclosure to a co-owner unless an express exception permits supply.

Returns, accounts, documents and assessment records under the Agricultural Income-tax Act are treated as confidential, and section 54 bars disclosure except where an express statutory exception applies. A co-owner who was not the assessee could not invoke section 54(3) to obtain certified copies of the returns, because the requested disclosure did not fall within the permitted exceptions. The statutory confidentiality bar was therefore applied according to its plain language, and the refusal to supply the returns was upheld as consistent with the scheme governing confidential tax records.

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Issues: Whether certified copies of returns filed under the Agricultural Income-tax Act could be directed to be furnished to a co-owner who was not the assessee, in view of the confidentiality bar under section 54.

Analysis: Section 54(1) treats particulars contained in returns, accounts, documents, and assessment records as confidential and bars a court from requiring their production except as provided in the Act. The exception in section 54(3) did not cover the petitioner's request. On the plain language of the provision, the restriction on disclosure was absolute and was not displaced by the petitioner's status as a co-owner. The earlier refusal orders were therefore consistent with the statutory scheme governing confidential tax records.

Conclusion: The request for certified copies was not maintainable, and the refusal to supply the returns was upheld.

Ratio Decidendi: Where tax-return information is declared confidential by statute and the requested disclosure does not fall within an express exception, neither a court nor the assessing authority can compel production or supply of the return.

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