The Right To Information

For BCAJ August, 2006

Narayan Varma

Citizens make use of the Right available under the RTI Act for various purposes seeking information on various issues, both public and private. It appears that citizens have also started using the RTI Act in connection with tax matters. I have with me more than 10 Orders of Central Information Commission (CIC) which is the highest and final authority under the RTI Act, dealing with matters related to various provisions of the Income-tax Act. I briefly deal with two of them in this article. I have extensively covered the famous case of Mrs. Farida Hoosenalli in earlier issue. Hereunder are two other recent decisions :

·        One is the decision given on 4th May 2006, in the case of Mr. Rakesh Agarwal. He sought the following information :

o       A copy of the tax returns filed by Shri Ramesh Chandra, A-2/178, Janakpuri, New Delhi.

o       A copy of the investigation report of Tax Evasion Petition (TEP) submitted by Mr. P. P. Sharan against Mr. Ramesh Chandra.

The CPIOs of both the Public Authorities, CIT for (i) and DIT — Investigation for (ii), have denied information to him u/s.8(1)(j) and u/s.8(1)(h).

The CIC held that the Appellate Authority has correctly applied S. 8(1)(j) and S. 8(1)(h) for exemption from disclosure and the appeal is accordingly dismissed.

It may be noted that Mr. Ramesh Chandra was the landlord of the applicant, Mr. Rakesh Agarwal. There was a landlord-tenant dispute and it was held that the information was sought for personal reasons, not involving any public interest. As the matter relating to the investigation of tax evasion was in progress, the disclosure was held to be exempt u/s.8(1)(h).

·        Arun Verma v. DG of IT (systems) : Order dated 3-3-2006.

            The applicant had asked the CPIO, CBDT

o       PAN and dates of allotment

o       TAN and dates of allotment

of 26 companies which all appear to be mainly engaged in sea food and marine product business.

The CPIO (Central Public Information Officer) had held that PAN and TAN of taxpayers are personal information that is subjected to confidentiality u/s.138 of the Income-tax Act.   U/s.8(1)(j) of the RTI Act, such personal information cannot be disclosed.

In the first appeal, the applicant referred to the proviso to S. 8(1)(j) [Clause exempts certain personal information (see July issue of BCAJ)], which reads as under :

Provided that the information which cannot be denied to the Parliament or a State Legislature shall not be denied to any person.

Based on above, he pleaded that he is entitled to the information sought by him.

Commission’s Decision :

PAN is a statutory number, which functions as a unique identification for each taxpayer. Making PAN public can result in misuse of this information by other persons to quote wrong PAN while entering into financial transactions and also could compromise the privacy of the personal financial transactions linked with PAN. This also holds true for TAN. Information relating to PAN and TAN including the dates of issue of these numbers are composite and confidential in nature u/s.138 of Income-tax Act. The appellant has not made a case of bona fide public interest for disclosure of PAN/TAN.

The appeal was therefore dismissed.

The RTI Act :

To continue the study . . . .

Ss.(1) of S. 10 provides that when the information sought is partly exempt and partly not and such parts can reasonably be severed from each other, the part which is not exempt has to be provided.

In the second case covered hereinabove, the applicant had pleaded that even if PAN and TAN are exempt, he be provided with the dates of allotment thereof, which would not be exempt. However, the CIC held that both the informations are composite and confidential in nature

Ss.(2) provides that when such part information is supplied, the PIO has to give notice to the applicant informing him that only part of the information is provided, the reasons for the decision for not supplying the part information and the name and designation of the person who took the said decision.

S. 11 makes detailed provisions for Third Party information. When an information sought by any citizen is in respect of any third party, (as in the case of Farida Hoosenalli) and the PIO intends to disclose the same, he has to give a written notice to such third party within five days from the receipt of the application.

The Section provides that such notice is to be given when the information relates to or has been supplied by a third party and has been treated as confidential by the third party.

What is the meaning of the above words in italics ? Has treatment to be explicit or can it be implicit ? Are all tax returns furnished by the assessees deemed to be treated by them as confidential or one has to so state on the said returns ? This was argued by the representative of Farida Hoosenalli that the returns of the producer of ‘Black’ movie were not treated by the said party as confidential, but it was negated and held that they were confidential.

The third party has a right to make a submission in writing or orally within 10 days from the date of receipt of such notice and the PIO has to keep in view such submission while taking a decision about disclosure of information. In spite of the above provision, protecting to some extent disclosure of anyone’s personal information to the other party is overridden under the proviso to this sub-section. It reads as under :

“Provided that except in the case of trade or commercial secrets protected by law, disclosure may be allowed if the public interest in disclosure outweighs in importance any possible harm or injury to the interests of such third party.”

U/ss.(3), the PIO is required to make decision within forty days (30 days normal period + 10 days, time taken by third party in making submissions) as to whether or not to disclose the information/record or part thereof to the third party. The said notice shall also state that the third party is entitled to prefer an appeal against his decision.

I am unable to understand clearly the implication of this Section and how it is to operate. If the PIO is allowed to give the information to the applicant in spite of the objection of the third party, then what is the purpose of the appeal of the said third party or is it to be understood that though he decides to give information and communicates that decision to the third party, he actually withholds parting of the information to the applicant, either till the time to make appeal elapses or till the appeal made is disposed of.

Other News :

·        RTI camps held from 1st July to 15th July in more than 40 cities in India with NDTV and Hindustan Times as media partners had a huge success. In Mumbai, it was located at the Government Law College, Churchgate under the charge of the RTI activist, Shailesh Gandhi. BCAS Foundation was one of the NGOs participating. Total RTI applications handled at Mumbai camp were 2222.

·        On this occasion of camp holding, BCAS Foundation published second booklet on RTI, namely Frequently Asked Questions on The RTI Act. Any member desiring to have a copy may obtain it from BCAS office.

·        An order issued by the Chief Information Commissioner Wajahat Habibullah states that in case of quotations, bid or tender or any other information prior to the conclusion of a contract, it could be categorised as trade secret. But once concluded, the confidentiality of the transactions cannot be claimed. Its information can be obtained under the RTI Act.

·        S. 7(1) of the RTI Act provides that the PIO shall as expeditiously as possible, and in any case within thirty days of the receipt of the request provide the information. However, the Proviso thereto states : “Provided that where the information sought for concerns the life or liberty of a person, the same shall be provided within forty-eight hours of the receipt of the request.”

It appears that possibly for the first time, this Proviso has been used successfully in connection with an application in respect of uncovered and unmarked trenches and stormwater drains in Bandra and Santacruz. Under the application, the names of the officers responsible for this neglect, etc. were sought from the Assistant Municipal Commissioner. On July 13, Information Commis-sioner Suresh Joshi held that 48-hour rule applied in this case.

·        The dates for the next RTI Clinic are :

19th August 2006 and 26th August 2006

From 11.00 a.m. to 1.00 p.m. at BCAS premises.