Prosecution initiation guidelines emphasise prioritising serious tax frauds and require a show-cause notice before proceedings. Departmental guidance requires thorough factual examination and, where prosecution parameters are met, service of a show-cause notice to the assessee before initiating prosecution, except for offences under section 276C(1) and 277; prosecutions are to focus on significant frauds and major defaults, with avoidance normally for persons aged seventy or above and with specified thresholds for various sections determining non-initiation.