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Sections 353-10 & 353-15 relate to information gathering powers for indirect taxes, i.e. GST, FBT, etc. They mirror the income tax administration powers to a large extent. As Paul says, once a taxpayer has given the ATO case officer cause to escalate the response then it is VERY hard to stop.

The accountant, bank manager and adviser will all ask the ATO to serve a s.264 notice on them personally. That way the client cannot sue them for breach of contract by divulging sensitive client information.