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The Tax Court dismissed Web Listings Inc.’s application to extend time to object to GST/HST assessments, finding the mailing evidence showed notice through an authorized online account.
The Tax Court quashed Dionne Smith’s application for an extension of time to object to a GST new housing rebate assessment for lack of jurisdiction.
The Tax Court quashed a large corporation’s appeals for 2020–2022 because its notices of objection did not satisfy the statutory objection requirements.
The appeal is dismissed because the appellant failed to comply with the procedural requirements of the Income Tax Act for filing notices of objection or obtaining extensions of time and failed to serve the required notice of constitutional question; statutory time limits apply even to Indigenous claimants, so the Tax Court correctly denied the extension and this Court will not grant the relief sought.
Source excerpt
The Tax Court of Canada allowed an application, finding credible evidence that a GST Notice of Objection was effectively transmitted on August 20, 2024.
The Tax Court dismissed Mr. Tolley’s application to extend time to object to reassessments, holding objections to the 2011 and 2012 reassessments were barred by the Act.
The Tax Court held the notice of assessment was sent, making the taxpayer’s objection and extension requests out of time. The appeal was quashed for lack of jurisdiction.
The Tax Court denied an extension of time to file a notice of objection after finding the assessments were mailed on September 13, 2022 and the statutory deadline had passed.
The application is dismissed because the Notice of Reassessment was posted to the applicant's My Business Account on October 12, 2022, starting the 90‑day objection period, the applicant did not serve a notice of objection within 90 days nor apply to the Minister for an extension within one year, and under s.166.2(5) of the Income Tax Act the Court lacks jurisdiction to grant an extension absent a timely application to the Minister.
Source excerpt
The Tax Court quashed a GST appeal after finding no valid, timely notice of objection was proved and no statutory power existed to extend the deadline.
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