- Parties: The appellant was Iris Technologies Inc. The respondent was His Majesty the King.

- Subject Matter: The appellant applied for an order directing the Minister of National Revenue to assess and pay it net tax refunds under the Excise Tax Act, 1985. Before the Federal Court, the Attorney General of Canada filed affidavits of a Canada Revenue Agency employee. The appellant cross-examined this affiant. The minister then issued notices of assessment disallowing input tax credits and refusing to pay net tax refunds. The appellant filed a motion for judgment under r. 170.1 of the Tax Court of Canada Rules (General Procedure), SOR/90-688a. The Tax Court dismissed the appellant’s motion.

- Ruling: The appeal court ruled in the respondent’s favour and dismissed the appeal with costs. The Tax Court committed no palpable and overriding error in finding no clear admission and committed no error of law in addressing the issue of the assessments’ validity, the appeal court said. The case of Western Minerals Ltd. v. Minister of National Revenue, [1962] S.C.R. 592, 34 D.L.R. (2d) 163 [Western] supported the conclusion that an assessment remained valid even if the minister did not complete or even begin her audit, the appeal court added.

- Date: The hearing was set on June 5, 2023. The court released its decision on June 5, 2023.

- Venue: This was a federal case before the Federal Court of Appeal.

- Amount: No financial award was specified.