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8. Section 136 of the Income Tax Act read with Section 195 Cr. P.C therefore makes it clear that the proceeding for assessment of income tax before an income tax authority is deemed to be a proceeding before a civil court and will therefore attract the provisions of Section 195 Cr. P.C.

9. Section 471 I.P.C. provides for punishment for fraudulently or dishonestly using as genuine any document which the person using the same knows or has reason to believe to be a forged document. Obviously this Section of the Indian Penal Code has been included in the F.I.R. in view of the allegation contained therein that the petitioners used forged or fabricated documents in the proceeding before the income tax authority regarding assessment of income tax payable by them. This Section 471 I.P.C. finds place in Section 195(1)(b)(ii) Cr. P.C. and therefore in view of Section 136, Income Tax Act read with Section 195 Cr. P.C. a prosecntion for the said offence Under Section 471 I.P.C. which has been included in the F.I.R. can be launched only on the basis of a written complaint of the concerned income tax authority or of some authority to which the former is subordinate. Such also is the case in respect of the offence Under Section 468 I.P.C. which has been included in the F.I.R. inasmuch as Section 468 encompasses the offence described in Section 463 I.P.C. as mentioned in Section 195(1)(b)(ii) Cr. P.C. Section 468 I.P.C. provides for punishment for commission of forgery with the intention that the document forged shall be used for the purpose of cheating. Section 463 I.P.C. defines forgery. Evidently therefore an offence punishable under Section 468 is an offence described in Section 463. Since Section 195(1)(b)(ii) Cr. P.C. applies to 'any offence described in Section 463 I.P.C, Section 468 I.P.C. which provides for punishment for commission of forgery with a particular intention, obviously comes within the ambit of Section 195(1)(b)(ii) Cr. P.C. as answering an offence described in Section 463 I.P.C. mentioned therein. (For supporting views see., S. L. Goswami v. M. P. High Court, ; Dina Nath v. Hansraj, 1974 Cr LJ 198). Evidently therefore if an offence Under Section 468 I, P.C. has been committed in respect of a document produced or given in evidence in any income tax proceeding before the income tax assessment authority the offender can be brought to book for that on the basis of a complaint by the appropriate income tax authority Under Section 195(1)(b)(ii) Cr. P.C. and not through any separate police investigation at the instance of police.