Hugessen,
J.A.:—We
are
all
in
general
agreement
with
the
reasons
of
McNair,
J.
in
the
Trial
Division.
The
decision
of
the
respondent,
the
Minister
of
Communications,
to
revoke
a”
certification"
of
a“
certified
production”
previously
given
under
subsection
1104
(2)
of
the
Income
Tax
Regulations
has
no
purpose
and
no
legal
effect
outside
the
scheme
of
the
Income
Tax
Act,
R.S.C.
1952,
c.
148
(am.
S.C.
1970-71-72,
c.
63)
(the
"Act")
itself.
The
certification
decision
and
the
subsequent
revocation
decision
can
have
no
consequences
other
than
upon
an
assessment
to
income
tax.
In
those
circumstances,
such
decisions,
and
their
effect,
may
be
reviewed
on
an
appeal
to
the
Trial
Division
under
the
Income
Tax
Act;
such
an
appeal
is
expressly
provided
for
in
that
Act
within
the
meaning
of
section
29
of
the
Federal
Court
Act,
R.S.C.
1985,
c.
F-7.
Accordingly,
those
decisions
cannot
be
attacked
by
section
18
proceedings.
(See
M.N.R.
v.
Parsons,
[1984]
2
F.C.
331,
indexed
as
Flemming
v.
M.N.R.,
[1984]
C.T.C.
352,
84
D.T.C.
6345.)
The
appeal
will
be
dismissed
with
costs.
Appeal
dismissed.
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