In Bank of America v. Canada (Attorney General) (Fed CA, 2025) the Federal Court of Appeal dismissed an appeal, here from a JR of a dismissal of an late-filed application [under Excise Act s.141.02] to become a "qualifying institution", which would allow the applicant to "claim input tax credits above a prescribed rate".
Here the court considers the legal effect of an 'acknowledgement of receipt':
[8] .... The letters that the Bank now asserts constitute initial decisions by the Minister to accept its applications for late filing are nothing more than acknowledgements of receipt. While they trigger a time period for the Minister to respond to the applications, they do not affect the Bank’s legal rights, nor do they impose legal obligations on it or have prejudicial effects: Air Canada v. Toronto Port Authority, 2011 FCA 347 at paras. 29-30; 1099065 Ontario Inc. (c.o.b. Outer Space Sports) v. Canada (Minister of Public Safety and Emergency Preparedness), 2008 FCA 47.
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