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That is- I'm 100 percent sure that is the day that I was considered served- Q:             The letter- A:            - the day you- Q:             The letter from Mr. ...

(b)        All GST amounts collectible [12]            After hearing argument from counsel for the applicants on the major issue whether the Minister's delegate had erred in the manner he calculated the applicants' net tax for rebate purposes and having considered the matter overnight, counsel for the Minister informed the Court the next day she had instructions to consent to this Court issuing an order quashing the Minister's reassessments (or determinations) in respect of each applicant's GST rebate application. [13]            She conceded the Minister's delegate had erred when calculating each of the applicant's net tax as defined in the Remission Order. ...

However, the Communiqués are administrative policies and were not issued pursuant to a discretionary power and may only be considered as concessions made by the Minister to resolve inequities within the Act. ...

In other words, "jurisdictional error"is simply an error on an issue with respect to which, according to the outcome of the pragmatic and functional analysis, the tribunal must make a correct interpretation and to which no deference will be shown. [16]            The factors to be considered in a pragmatic and functional analysis of the decisions in question here would involve consideration of the following issues: 1-       Presence of a privative clause: there is no privative clause in the Customs Tariff Act which would shield decisions of the Minister from judicial oversight. ...

Stickle. [24]       I have considered that Mr. Sawatzky, who was assisting Mr. ...

Villett confirmed that correspondence from Revenue Canada to Capitol Records, throughout the relevant period, reflected no suggestion that Revenue Canada considered Capitol Records and Kensington to be a single economic unit or that sales or transfers between the two companies should be ignored by virtue of the relationship between them. [12]      Mr. ...

However, because of the nature of the other materials used in constructing an above-ground pool and the way in which the latter is ordinarily assembled and installed, they considered that the contribution of the sheet to the load-bearing system or body of the pool generally used is insignificant. ...

There was no such contrary order in this case. [41]      In the present cases, no contrary orders were made with respect to interest on the costs awarded to the plaintiff. [42]      Section 40 of the Federal Court Act, as considered by the Court of Appeal in Bethlehem Copper, is identical to the section of the Federal Court Act which I have concluded was applicable to the 1988 judgments. ...

Such justification was considered by the Tax Court of Canada in Ginsberg, [1994] 2 C.T.C. 2063 at 2073, where it concludes:              I believe that if there is a delay that prima facie indicates a failure to examine and assess a return with all due dispatch as required under subsection 152(1) of the Act there is an onus on the respondent to establish by evidence pertaining to the manner in which that return was dealt with that the delay was not unreasonable....              ...

.), the Supreme Court considered the nature of the Requirement to Provide Information. ...