[126] .... Similarly, promissory estoppel can be raised against a public authority (Malcolm v. Canada (Minister of Fisheries and Oceans), 2014 FCA 130, 460 N.R. 357 at para. 38 [Malcolm]).
....
[134] Finally, estoppel in a public law context has narrow application, and "“requires an appreciation of the legislative intent embodied in the power whose exercise is sought to be estopped”" (Malcolm at para. 38). The Commissioner cannot be prevented from carrying out its statutory duty today because of an equivocal representation made over a decade prior.
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