Dupuis – Quebec Court of Appeal notes that there is no time limit for a notice of objection to be responded to

The taxpayer argued that the ARQ, in taking over three years to reassess in response to its objections, had failed to act with “all due dispatch” as required by the Quebec equivalent of ITA s. 165(3). The Court noted that the taxpayer had the option of appealing directly to the Court of Quebec after 180 days, or seeking a waiver of interest that accumulated due to undue delay (here, in fact, the ARQ had waived 16 months’ interest), and then stated:

The fact that no time limit is set for the assessment in response to a Notice of Objection is a deliberate choice by the legislature and is understandable. …

The Court of Quebec, like the Tax Court of Canada, has made it clear on numerous occasions that its powers do not include the power to set aside a notice of assessment on the basis that the Minister has not acted with dispatch.

Neal Armstrong. Summary of Dupuis v. Agence du revenu du Québec, 2021 QCCA 1061 under s. 165(3).