Confidentiality of income-tax records does not bar an assessee from producing his own assessment order in evidence.

Section 54 of the Income-tax Act, 1922 imposed confidentiality on income-tax records and barred courts from compelling public servants to produce such material, but that bar did not prevent an assessee or a representative-in-interest from voluntarily producing the assessee's own assessment order in evidence. The distinction turned on production by the department versus production by the person entitled to the document. On that basis, assessment orders were admissible when tendered by the assessee or his representative-in-interest, and the confidentiality objection failed.

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Issues: Whether an assessment order under section 54 of the Income-tax Act, 1922, could be received in evidence when produced by the assessee or his representative-in-interest despite the confidentiality bar in the statute.

Analysis: Section 54 imposed a confidentiality obligation on income-tax records and barred courts from requiring public servants to produce such material. The question was whether that prohibition extended to an assessment order voluntarily produced by the assessee himself or by a person claiming through him. The decision distinguished cases where production was sought from the department and accepted the line of authority holding that the statutory bar did not prevent the assessee or his representative-in-interest from producing his own assessment order in evidence.

Conclusion: The assessment orders were admissible in evidence when produced by the assessee or his representative-in-interest, and the objection based on section 54 failed.

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