Key legal question
Whether the sealed accounting lists in S380, S392 and S403 had to be entered in the file despite the claimed disproportionate anonymization burden.
Extracted holding
Yes. Their evidentiary value could not be denied merely because the files were voluminous; they had to be entered, in principle unredacted.
Extracted reasoning
The court rejected a purely quantitative approach. The AFC was entitled to perform the checks it considered necessary, and the documents were not shown to be useless for the investigation.