Confidentiality privilege in tax assessment records survives repeal where saving provisions do not clearly displace accrued protection.

A confidentiality privilege attached to tax assessment records filed under the earlier income-tax law was preserved after repeal because the ordinary saving rule protected accrued rights and privileges unless a contrary intention appeared. The later enactment, including its saving provisions and disclosure mechanism, did not clearly show an intent to extinguish that pre-existing protection for returns already filed. The non-disclosure privilege therefore continued to apply, and production of the records was rightly refused.

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Issues: Whether the income-tax authorities could refuse production of returns filed before the commencement of the later enactment on the ground that the confidentiality privilege under the earlier law survived the repeal and continued to protect those records.

Analysis: The earlier confidentiality provision attached to the assessment records when the returns were filed. On repeal of the earlier Act, the ordinary saving rule preserved accrued rights, privileges, and obligations unless a contrary intention appeared. The later enactment and its saving provisions did not show any intention to destroy that protection in respect of returns already filed. The omission of the intermediate confidentiality provision and the substitution of the later disclosure mechanism did not, on the facts of the case, displace the privilege already accrued under the earlier law.

Conclusion: The privilege of non-disclosure under the earlier provision remained available, and the request for production was rightly refused.

Final Conclusion: The revision failed because the assessment records continued to enjoy statutory protection, so the order refusing production was sustained.

Ratio Decidendi: A confidentiality privilege attached to tax assessment records under the repealed law survives repeal where the saving provisions apply and the later legislation does not clearly evince a contrary intention to extinguish that accrued protection.

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