Before finding that a seizure pursuant to s. 231.3 was not contrary to s. 8 of the Charter, Desjardins J. stated:
"[I]f the issuing judge comes to the conclusion that the conditions of paragraphs 231.3(3)(a), (b) and (c) are met, he need not nor is he permitted to consider whether there has been a previous substantive voluntary compliance by the taxpayer, whether further documents might be remitted voluntarily, or whether the applicant for the warrants has taken all reasonable steps to obtain the information from an alternative source ..."