Le
Dain,
J:—The
section
28
application
must
be
dismissed
for
lack
of
jurisdiction
on
the
ground
that
a
requirement
for
information
or
documents
issued
under
subsection
231(3)
of
the
Income
Tax
Act,
SC
1970-71-72,
c
63.
is
not
a
decision
required
by
law
to
be
made
on
a
judicial
or
quasi-judicial
basis
within
the
meaning
of
section
28
of
the
Federal
Court
Act,
RSC
1970,
c
10
(2nd
Supp).
Cf
MNR
v
Coopers
&
Lybrand,
[1979]
1
SCR;
[1978]
CTC
829;
78
DTC
6528.
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