Issue: Iris Technologies Inc. filed for judicial review in the Federal Court after the Minister of National Revenue disallowed its input tax credits and assessed penalties under the Excise Tax Act (ETA). Iris claimed procedural unfairness, lack of evidence for the assessments, and improper conduct by the Minister. The Attorney General moved to strike the application, arguing the Tax Court had exclusive jurisdiction over assessment disputes.
Decision: The Supreme Court dismissed Iris’s appeal, affirming the Federal Court of Appeal’s decision to strike the judicial review. The Court held that challenges related to the correctness of tax assessments fall under the exclusive jurisdiction of the Tax Court.
Jurisdiction:
The Tax Court handles the correctness of tax assessments (including procedural fairness and evidence issues).
Judicial review in the Federal Court is limited to discretionary decisions by the Minister, not related to tax assessments.
Reasoning: Iris’s claims (procedural unfairness, evidentiary deficiencies, improper purpose) were seen as attacks on the assessments’ correctness, which the Tax Court should resolve. The improper purpose claim lacked factual support.
Outcome: The declaratory relief sought by Iris was deemed to have no practical effect, as it would not influence the assessments. No monetary award was specified.
