The Right To Information

For the BCAJ July 2006

Narayan Varma

It appears that the case of applicant Mrs. Farida Hoosenalli seeking information from income-tax files of Applause Bhansali Films Pvt. Ltd. (Producers of movie ‘BLACK’) shall continue for long. In May 2006 issue, the decision of the Central Information Commissioner (CIC) was reported. The CIC had directed the CCIT to supply relevant copies of the income-tax assessment orders, provided that the same are not exempted u/s.8(1) of the RTI Act.

The CCIT now has held that the assessment orders are exempted under clauses 8(1)(e) and (g) of the RTI Act.

The said clauses read as under :

     (e) Information available to a person in his fiduciary relationship, unless the competent authority is satisfied that the larger public interest warrants the disclosure of such information;

     (g) Information, the disclosure of which would endanger the life or physical safety of any person or identify the source of information or assistance given in confidence for law enforcement or security purposes;

The text of the Order dated 24-5-2006 is as under :

In the Office of the

Chief Commissioner of Income-Tax-IX

Appellate Authority u/s.19 of

The Right to Information Act, 2005

Room 321, Aayakar Bhavan, M. K. Road,

Mumbai-400020

Name and address of appellant :

Ms. Farida Hoosenalli

522, Sayani Road, Prabhadevi, Mumbai-400025

Appeal No. : 1/RTI Act/CCIT IX/2006-07

Date of Order : 24-5-2006

Order under the Right to Information Act, 2005

In this case, an order has been passed by the Central Information Commission on 30-3-2006 (Appeal No. 22/IC (A)/2006 : F No. 11/52/2006-CIC) wherein the Commission has held that the Income-tax return filed by the assessee is a confidential information. The information is given in fiduciary capacity. There is no public action involved in the matter. Therefore, disclosure of such information is exempted u/s.8 (1)(d) and (j).

2. The Commission, however, directed that copies of income-tax orders may be supplied to the petitioner if such documents are not exempted  u/s.8(1) of the Act.

3. In order to decide whether the assessment order is exempted u/s.8(1) of the Act, an opportunity of hearing was given to the petitioner. On behalf of the petitioner, Mr. Kewal Semlani attended. It was explained to Mr. Kewal Semlani that the income-tax assessment order contains the details regarding the income of a person. It also contains the scrutiny and investigation carried out by the Assessing Officer during the course of the assessment proceedings. A question was put to Mr. Semlani whether he would like such information in his own case to be disclosed to anybody. He was also asked to comment whether anybody would like the details of his income being known to anybody else. A proposition was made that no husband or wife would like his or her income details to be told to a third person. He was also asked whether disclosure of such information would not endanger the life and physical safety of the person.

4. In reply Mr. Semlani read out the following portion of the order of the Commission :

“In the spirit of the RTI Act, the public authority is required to adopt an open and transparent process of evaluation norms and procedures for assessment of tax liabilities of various categories of assessees. Every action taken by the public authority in question is in public interest, and therefore, the relevant orders pertaining to the review and revision of tax assessment is public action. There is, therefore, no reason why such orders should not be disclosed.’’

With reference to the above action of the Commission, it was submitted that the public authority is required to adopt an open and transparent process of evaluation and norms and procedures of assessment of tax liabilities. He argued that every action taken by the public authority is in public interest, and therefore, the copy of the assessment order should be made available to him. He also argued that in this particular case, the information sought by the petitioner was in public interest. Because the information she is asking as the party has defrauded the insurance company inasmuch as the value of articles or things, which were insured by the insurance company, was declared to be much less than the actual value. Therefore, there was a public purpose involved in seeking the information by the applicant.

 5. I have carefully considered the observations of the Central Information Commission, submissions and the arguments of the petitioner’s representative. U/s.8(1)(e) of the Right to Information Act, disclosure of information is exempted if the information is given by the person in his fiduciary capacity. Similarly, disclosure of information is exempted u/s.8(1)(g) if it would endanger the life or physical safety of a person. The income-tax assessment order contains the details of income, which are disclosed by the assessee in the return of income. The assessment order also discusses the various points which are picked up by the Assessing Officer for investigation. It gives details of investigations carried out and the conclusions arrived at by the Assessing Officer.

 6. The information about income is given to the Department in a fiduciary capacity. It is a public knowledge that information about the income of any person may endanger his life and his physical safety. Therefore, supply of the copies of assessment order has to be held as exempted under the provisions of S. 8(1)(e) and (g) of the Right to Information Act, 2005.

H. Tulsyan

Chief Commissioner of Income-tax — IX

Appellate Authority u/s.19 of the RTI Act, 2005

Mumbai

I am informed that the applicant is now filing 2nd appeal to the CIC, hopefully after that the matter may come to an end. May be not, as it is understood that probably a writ petition challenging the decision may also be filed in the Bombay High Court.

The RTI Act :

To continue the study . . . . . 

S. 8 and S. 9 are two very important Sections of the RTI Act. They provide for exemption from disclosure of information. S. 8 starts with an obstante clause : “Notwithstanding anything contained in this Act”. Hence, the Section has an overriding effect on all the provisions of the RTI Act. The PIO is not obliged to give any citizen information pertaining to 10 different items contained in 10 clauses U/ss.(1). They include :

      (a) Information, disclosure of which would prejudicially affect the sovereignty and integrity of India, etc.

      (b) Information which has been expressly forbidden by any court, etc.

      (d) Information including commercial confidence, trade secrets or intellectual property, the disclosure of which would harm the competitive position of a third party, unless the competent authority is satisfied that larger public interest warrants the disclosure of such information;

      (e) Information as reproduced earlier;

      (g) Information as reproduced earlier;

      (h) Information which would impede the process of investigation or apprehension or prosecution of offenders;

      (j) Information which relates to personal information, the disclosure of which has no relationship to any public activity or interest, or which would cause unwarranted invasion of the privacy of the individual, unless the PIO, etc. is satisfied that the larger public interest justifies the disclosure of such information.

Even though words underlined above already appear in 3 out of 10 clauses, Ss.(2) again emphasises : “Notwithstanding anything in the Official Secrets Act, 1923, nor any of the exemptions permissible in accordance with Ss.(1), a public authority may allow access to information, if public interest in disclosure outweighs the harm to the protected interests.”

Thus, it may be observed that as such, there are very few items of information which need not be given, but it may be noted that it is neither mandatory not to give, nor mandatory to give. The PIO is only not obliged to give. Further, in any case, if public interest in disclosure outweighs the harm to the protected interests, the PIO is  authorised to allow access to information.

I understand that a number of RTI applications received by the Mumbai Municipal Corporation seek building plans of third parties. The PIOs are confused whether under clause (d) they can refuse to give such plans.

As you may have observed in Mrs. Farida Hoosenalli’s case, clauses (d) & (j) were applied by the CIC to refuse the copies of return of income and now the CCIT has applied clauses (e) and (g) to refuse copies of assessment orders.

The CIC has in one another case decided,

“Investigations of the complaint on tax evasion by the IT Department is a part of the process of identifying the offenders and assessing the extent of tax evasion by them. Until the nature of offence is duly examined and thoroughly investigated and necessary action is taken under the relevant provisions of tax laws, the disclosure of investigation report on tax evasion is barred u/s.8(1)(h)”.

Thus, out of 10 clauses, five have become related to income-tax matters. Incidentally, the CIC has also surprisingly ruled that personal information like PAN and TAN of the complainant cannot be disclosed.

S. 9 is simple and provides additional grounds for rejection to access in certain cases. The PIOs are authorised to reject a request for information where such a request for providing access would involve an infringement of copyright subsisting in a person other than the State.

Other News :

·        U/s.4, every public authority is obliged to publish 17 manuals including (a) a directory of its officers and employees and (b) information on the monthly remuneration received by them including the system of compensation as provided in its regulations.

The CIC now has confirmed the above requirement in one ruling in the case of Punjab National Bank when the said Bank had refused the information sought for one clerk/typist with the PNB Zonal Office, Dehradun.

·        I am unable to trace a Section which empowers the CIC to fine anyone other than PIOs. However, for the first time, the CIC has ordered the Centre to pay Rs.5,000 to an RTI applicant. The case was of one M. N. Trivel. She wanted information on her father’s medical history from the Central Government Health Scheme Officials. They went on harassing her by seeking additional details about the case and giving flimsy excuses. At the last count, the officials “invented a new and novel justification that the information cannot be given in the economic interest of the government”. All this, probably because they did not even have the information which was sought. Of course, the officials did give her some information, but charged her Rs.50 instead of Rs.4.

·        In another case, the CIC has recommended to the Government that departmental action be initiated against one Mr. Chaubey and warning be issued to him for the delay in giving information under the Act. Mr. Chaubey is General Manager of South Eastern Coalfields. This decision was arrived at after hearing Mr. Chaubey through a video conference between New Delhi and Raipur on May 12.

·        It is believed that Courts & Tribunals are covered under the RTI Act. In February, the Bombay High Court had issued a circular saying RTI applications would be kept pending till it decides whether the RTI Act can apply to judicial fora at all. In a sweeping disclaimer, the rules drafted by the Delhi High Court exempt it from disclosing any “such information which is not in the public domain or does not relate to judicial functions and duties of the court and matters incidental and ancillary thereto”.

This goes far beyond the exemption provided by S. 8(1)(b) of the Act, which is limited to “information which has been expressly forbidden to be published by any court of law or Tribunal or the disclosure of which may constitute contempt of court”. Even otherwise, if the High Court proposes to disclose only what is already in the public domain, the draft rules fly in the face of the RTI Act which seeks to “promote transparency and accountability in the working of every public authority”, including the judiciary.

·        RTI Clinic run by BCAS Foundation at BCAS office continues to be doing fine. Our members and other citizens are being provided required guidance. It is interesting to note that our members are using the RTI Act for various purposes outside their professional activities.

·        Mumbai will be one of the 40 cities to run RTI campaign from 1st to 15th July. In Mumbai, it shall be at the Government Law Collage, Churchgate. Hectic preparations are on. NDTV shall widely cover it, so also Hindustan Times and some regional newspapers. BCAS Foundation is one of the supporting NGOs for this campaign.

·        It is gratifying to note the result of the last poll as reported in June 2006 BCAS Newsletter in reply to the question “Can the Right to Information Act be used as a catalyst in transforming the working of Income-tax Department ?

91% have replied : YES

In a later article, I shall report on how the RTI Act is benefiting the assessees.