The Minister of National Revenue demanded confidential information from a commodities broker regarding the trading activities of its customers to check general tax compliance.
The broker refused to identify specific accounts, and the Minister issued formal demands under s. 231(3) of the Income Tax Act.
The Supreme Court of Canada held that s. 231(3) cannot be used for a general 'fishing expedition' into a class of taxpayers unless a genuine and serious inquiry is being conducted into specific persons.
The Court allowed the appeal and declared the demands invalid.
