New Garden Restaurant and Tavern Ltd. v. MNR, 83 DTC 5338, [1983] CTC 332 (SCO) -- summary under Subsection 231.1(3)

By services, 28 November, 2015

The procedure contemplated by S.231(1)(d) should not be regarded as interfering with the types of privacy interests protected by S.8 of the Charter, given the public interest in a reasonably efficient system of collecting taxes.

S.231(1)(d) (as opposed to S.231(4)) does not authorize an auditor to seize if he had formulated a belief of probable guilt prior to coming upon the incriminating records.

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