CRA’s policy is to deny initial ITC claims without opportunity for representation

CRA stated that “RIP examiners” (i.e., staff reviewing GST/HST refund claims as initially filed) are not required to provide any notice:

when only disallowing ITCs. Proposal of examination results is only mandatory if GST/HST is assessed, a self-assessment is raised or when reassessing a prior period. However, RIP examiners are required to send a final letter to all registrants explaining their adjustments.

Neal Armstrong. Summary of May 2016 Alberta CPA Roundtable, GST Q.8 under ETA s. 229(1).