The Minister of National Revenue brought a motion to strike three affidavits filed by Gold Line Telemanagement Inc. in opposition to an application under section 311 of the Excise Tax Act.
The Court struck portions of the expert affidavit of Timo Vainionpaa that directly challenged the CRA's analysis of call detail records, finding them irrelevant to the preliminary stages of the application.
However, the Court declined to strike the balance of the Vainionpaa affidavit or the factual affidavits of Joel Bowers and Alexei Tretiakov, finding they provided necessary technical background and foundational evidence.
