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31 See The Indian Supreme Court decision in Charu
Chandra Kundu v. Gurupada Ghosh [1961] 43 ITR 83 in the context to section 54 of the
Income-tax Act of 1922 corresponding to section 150 of the Income Tax Ordinance, 1979. It
provided, inter alia, that all particulars contained in any statement made, return
furnished or accounts or documents produced etc., shall be treated as confidential and no
court shall require any public servant to produce before it such statement, return,
accounts or documents. Thus, section 54 statutorily recognised and declared the
confidential nature of the assessment proceedings and prohibited production of the
documents, etc., before the court or disclosure of information to any other. The Indian
Supreme Court held: "It is manifest that the disclosure of information given to
public servants in the course of income-tax proceedings has by a comprehensive provision
been prohibited. The income-tax authorities are directed by the provision to treat the
information disclosed, evidence given or documents produced as confidential."
