CRA is considering whether denials of requested GST/HST return adjustments can ground objection rights

Regarding whether, if CRA declines a requested adjustment to a GST/HST return through a denial letter, so that technically there may be no assessment to which the registrant can object, CRA stated:

We are working cross-functionally with Appeals and the GST/HST Audit program to develop new policies and procedures to address this concern.

Neal Armstrong. Summary of 7 April 2022 CBA Roundtable, Q.2 under ETA s. 296(1).