European Marine Contractors Ltd. v. Canada (Customs and Revenue Agency), 2004 DTC 6070, 2004 FC 114 -- summary under Subsection 231.6(5)

After dismissing the taxpayer's application for review of a requirement based on its allegation that the requirement included information and documents which might have no link to the determination of its liability for Canadian taxes, Rouleau J. stated (at p. 6072) that "the test to be applied is not whether the information requested will be relevant in determining the applicant's Canadian tax liability, but rather whether the information is relevant to the administration of the Act".