Transalta - Federal Court of Appeal states that CRA is bound to assess in accordance with its applicable IT Bulletin

Before achieving complete success at trial, the taxpayer made a settlement offer on the basis that some cash bonuses paid by some subsidiaries were non-deductible, but all the other (share and cash) bonuses at issue were fully deductible. In finding that the rejection of this offer did not give rise to Crown responsibility for post-settlement costs of the taxpayer, Blais CJ found that there was no principled basis on which the Minister could have accepted the offer.  In what arguably is an extension of this Galway principle, he further stated that the Minister was obliged to assess in accordance with his view of the law set out in the applicable Bulletin (IT-113R4).

Neal Armstrong.  Summary of Transalta Corporation v. The Queen, 2013 FCA 285 under s. 152(1).