Knox Contracting Ltd. v. Canada, 90 DTC 6447, [1990] 2 SCR 338, [1990] 2 CTC 262 -- summary under Subsection 231.3(1)

The provisions of ss.231.3 and 239 are by their nature criminal law. Because appeals from interlocutory orders by the parties in criminal proceedings must be based upon a statutory provision and no such statutory provision exists, no appeal lies to the provincial Court of Appeal from an order issuing search warrants (per Cory J.). Parliament in choosing a criminal sanction, has chosen to adopt the ordinary procedures of the criminal law for the enforcement of the Income Tax Act, with the result that no appeal lies from such an order (per La Forest J.).