TAXATION - whether disclosure of protected material sought by the issue of a subpoena was "necessary...for the purpose of carrying into effect the provisions of a taxation law" within the meaning of s 355-75 of Sch 1 to the Taxation Administration Act 1953 (Cth) (the Act) - whether primary judge erred in finding that disclosure was necessary for such a purpose - whether subpoena seeking disclosure of protected material ought to be set aside - consideration of factors relevant to deciding whether disclosure is "necessary" under the Act - differences between compulsory disclosure and voluntary disclosure by an officer under the Act- application for leave to appeal granted - appeal allowed
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