Tax confidentiality does not bar certified income tax records when an entitled person waives inspection rights; such copies are admissible.

Section 54's confidentiality mandate is a direction to tax officials and does not automatically render Income tax records inadmissible where the person entitled to inspect waives confidentiality; certified copies obtained from the tax records constitute admissible secondary evidence of public documents under the Evidence Act principles. A representative of the deceased estate (the widow) is entitled to obtain and produce certified copies. Late production of official records, by itself, is insufficient to exclude them where authenticity is undoubted and admission does not unfairly prejudice the opposing party.

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Issues: Whether certified copies of statements and orders of Income-tax officers (produced late in trial) are admissible in evidence despite Section 54 of the Income-tax Act, and whether the widow of the deceased or the University (as administrator) could validly produce such certified copies.

Analysis: The Court examined Section 54 of the Income-tax Act which directs confidentiality of particulars in income-tax proceedings and prohibits courts from requiring public servants to produce such documents, and compared it with the Evidence Act provisions on public documents and certified copies (Sections 74, 65 and 76 of the Indian Evidence Act). The Court held that Section 54 operates as a direction to Income-tax officials and does not itself render such documents inadmissible if the assessee (or a person entitled to inspect the record) waives confidentiality. The Court accepted authorities recognising an assessee's right to inspect statements or orders in his case and noted that certified copies obtained from the Income-tax Department are admissible as secondary evidence of public documents. The Court further held that the deceased's widow was a representative of his estate entitled to obtain the certified copies. Although the documents were produced at a late stage, late production alone was not a sufficient ground for rejection where the documents were official records of undoubted authenticity and their admission would not unfairly prejudice the defendant.

Conclusion: The certified copies of the Income-tax statements and orders are admissible in evidence; the widow was entitled to obtain and produce those certified copies; late production did not alone justify their rejection.

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