CRA indicates that it has the “flexibility” to accommodate a requested assessment of a prior GST/HST return to allow an unclaimed s. 232 rebate credit

In P-149R, CRA states that it generally will not assess a prior GST/HST return at the request of the registrant to the extent this will result in a reduction in net tax, so that the registrant should instead carry forward unclaimed input tax credits for claiming in its current return. However, this does not work for a credit arising under ETA s. 232 (re rebating consideration and related GST/HST for a previous reporting period) where the registrant missed claiming the s. 232 credit for the reporting period in which the adjustment was made, as that credit (unlike an ITC) cannot be carried forward to a subsequent return.

However, CRA has indicated that in its policy under P-149R, it has the “flexibility” to allow assessing the prior return “where the adjustment relates to an amount that may not be reported or accounted for in a subsequent period,” which appears to be a very guarded “yes,” that it generally would be receptive to opening up the return to allow the s. 232 credit.

Neal Armstrong. Summary of 2016 CBA Roundtable, Q.8 under ETA s. 296(1).