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Issues: Whether certified copies of an income-tax return and a statement made in income-tax proceedings, when produced by the assessee or his representative-in-interest, are barred from evidence by section 54 of the Indian Income-tax Act, 1922.
Analysis: Section 54 creates a bar against disclosure by income-tax officials and forbids compulsion of production of confidential records by the department, but the prohibition does not extend to a document obtained and produced by the assessee himself or by a person claiming through him. The authorities on assessment orders and returns recognise that such documents may be produced by the maker or representative-in-interest, and once admissible in evidence they may also be used for cross-examination. The earlier decision relied upon was distinguished because it concerned a direction to compel the income-tax authorities to produce records, not production by the assessee himself.
Conclusion: The objection under section 54 was not sustainable, and the certified copies were admissible in evidence and usable for cross-examination.