Background:

1. Situation: Ossai became a permanent resident of Canada in 2013 and was erroneously informed by the Canada Revenue Agency (CRA) that he had accrued Tax-Free Savings Account (TFSA) contribution room from 2009 to 2012.
2. Excess Contribution: Based on this information, Ossai over-contributed to his TFSA in 2020 and 2021.
3. CRA's Decision: The CRA refused to waive taxes on the excess contributions, despite Ossai's argument that he based his contributions on incorrect information provided by CRA.

Legal Proceedings:

1. Ossai's Actions: Ossai sought a waiver of the taxes, which was denied on first and second review.
2. Judicial Review Application: Ossai filed for judicial review, seeking cancellation of tax assessments and reimbursement for the taxes he paid, along with compensatory damages for distress.

Court's Analysis & Judgment:

1. CRA's Unreasonableness: The Court found CRA’s decision unreasonable, lacking transparency, and justification in relation to both the 2020 and 2021 tax years.
2. CRA's Miscommunication: The Court highlighted CRA's error in informing Ossai about his TFSA contribution room and the lack of timely notification about its correction.
3. Outcome: The application for judicial review was granted. The decision was set aside, and the matter remitted for redetermination by a different CRA officer.
4. Costs: No costs were awarded for this application.

Key Legal Principle:

• This case underscores the significance of accurate and timely communication from administrative bodies like CRA, especially when it leads to erroneous financial decisions by taxpayers. The need for decisions by such bodies to be reasonable, transparent, and justified was also emphasized.