The Appellants, operating in the construction industry, claimed input tax credits (ITCs) for supplies from subcontractors that the Minister characterized as suppliers of accommodation invoices.
The Minister disallowed the ITCs and imposed gross negligence penalties, assessing outside the normal period.
The Tax Court found the Appellants failed to prove the suppliers were genuine, except for one supplier whose invoices were time-barred.
The appeals were allowed in part, referring the assessments back to the Minister to vacate the time-barred assessments, but confirming the disallowance of ITCs and penalties for the other suppliers.