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The High Court of Delhi allowed the petition filed by the Commissioner of Income-tax challenging the rejection of the claim for production of records for the years 1962-63 and 1963-64. The Full Bench decision upheld the claim of privilege by the Income-tax Department in all situations. The Supreme Court reversed the Full Bench decision only in relation to documents filed after April 1964 for assessment years 1964-65 onwards. The impugned order was set aside, and the claim of privilege by the Commissioner of Income-tax was sustained.
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