Confidentiality bar under omitted tax provision was not preserved by the general savings clause for assessment records.

Omission of section 137 of the Income-tax Act, 1961, did not preserve a confidentiality bar over assessment records through section 6(c) of the General Clauses Act, 1897. The provision was treated as a public-policy restriction on disclosure and production, not as an accrued right, privilege, or incurred obligation belonging to any identifiable person. Because the omitted section was not re-enacted in equivalent form and section 138, as substituted, did not show an intention to preserve such protection, the savings clause could not be used to resist summons of the records on that basis.

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Issues: Whether the omission of section 137 of the Income-tax Act, 1961, by the Finance Act, 1964, extinguished the confidentiality bar and court-process restriction in respect of assessment records filed under the earlier law, and whether section 6(c) of the General Clauses Act, 1897, preserved any right, privilege or obligation so as to prevent summons of those records.

Analysis: Section 54 of the Income-tax Act, 1922 and section 137 of the Income-tax Act, 1961 were treated as provisions declaring certain particulars confidential and imposing a bar on disclosure and production. The omission of section 137 was not followed by any re-enactment of that provision in equivalent form, and section 138 as substituted did not disclose an intention to destroy rights preserved by the general savings clause. However, the Court held that section 137 did not create any right, privilege or obligation within the meaning of section 6(c) of the General Clauses Act, 1897, because the confidentiality declaration and prohibition on disclosure were matters of public policy and were not rights or obligations attached to any ascertainable person in the sense required by the savings provision.

Conclusion: Section 6(c) of the General Clauses Act, 1897, did not apply to preserve the omitted section 137 of the Income-tax Act, 1961, and the records could not be withheld on that basis.

Ratio Decidendi: A general confidentiality or disclosure bar in a repealed fiscal provision does not, by itself, amount to an accrued right, privilege or incurred obligation protected by section 6(c) of the General Clauses Act, 1897, unless the statute creates a specific enforceable entitlement in favour of an identifiable person.

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