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Motion for further documentary discovery granted; requested CRA audit documents met the low relevance threshold.
The appellant brought an interlocutory motion seeking an order compelling the respondent to produce a further list of documents under Rule 82 of the Tax Court of Canada Rules (General Procedure).
The appellant sought documentation related to CRA audits of scrap gold suppliers, Integras cases, and Collections diaries relevant to alleged GST/HST carousel schemes.
The Tax Court of Canada granted the motion, finding that the requested documents met the low threshold for relevance on discovery and rejecting the respondent's proportionality arguments.