CRA may delay paying a refund if there is a pending audit

ITA s. 164(1) and ETA s. 229(1) require the Minister to pay refunds with "all due dispatch" after the corresponding return is filed. CRA considers that "this term allows for some discretion on the part of the Minister," so that it can delay paying a refund if there is a pending audit.

Neal Armstrong. Summary of CBAO National Commodity Tax, Customs and Trade Section – 2014 GST/HST Questions for Revenue Canada, Q. 7 under ITA, s. 164(1).