Confidentiality of income-tax assessment records survives repeal where the statement was made under the earlier regime.

Confidentiality attached to an income-tax statement recorded under the repealed earlier Act continued to protect it from disclosure in civil proceedings. The court held that the earlier provision imposed an absolute bar on disclosure by tax authorities and compelled production by courts, and that the later Act's narrower confidentiality clause did not apply to statements made under the former regime. Applying the General Clauses Act, the accrued confidentiality obligation was preserved on repeal because no contrary intention appeared. The statement therefore remained protected, the civil court could not compel its production, and the orders directing summoning and limited disclosure of the assessment records were quashed.

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Issues: Whether the protection of confidentiality attached to income-tax assessment records under the repealed provision continued to bar disclosure and production of the assessee's statement in civil court after the enactment of the later Act and the omission of the successor confidentiality provision.

Analysis: The statement was made when the earlier income-tax regime was in force, and the confidentiality provision then operating imposed an absolute obligation on the income-tax authorities not to disclose assessment records and on courts not to compel their production. The later confidentiality provision was confined to proceedings under the later Act and did not govern a statement recorded under the earlier Act. The repeal of the earlier Act by the later Act did not evince an intention to destroy the protection already attached to the statement. Under the saving rule in the General Clauses Act, a repealed enactment continues to preserve accrued rights, privileges and obligations unless a contrary intention appears. The confidentiality obligation under the earlier provision was held to have accrued when the statement was recorded and remained unaffected by the later omission of the successor provision.

Conclusion: The statement retained its protected character, and the court could not compel its production. The challenge to the Munsif's orders succeeded.

Final Conclusion: The impugned orders directing summoning and limited disclosure of the assessment records were quashed, and the suit was directed to proceed according to law.

Ratio Decidendi: A confidentiality obligation created by a repealed income-tax provision, once accrued in respect of a statement recorded during the currency of that provision, is preserved by the general saving clause unless the repealing legislation clearly manifests a contrary intention.

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