Honeywell Limited v. The Queen, 2006 DTC 3124, 2006 TCC 325 -- summary under Expressio Unius est Exclusio Alterius

After noting that s. 152(4.01) permitted the Minister to assess beyond the normal reassessment period, where the taxpayer had provided a waiver, only in respect of the "matter" specified in the waiver, Bowman C.J. found that the Minister could not then do a "end run" around the restrictions in s. 152(4.01) by relying on the doctrine that there is virtually no restriction on what the Crown can plead in a reply and therefore now support his reassessment on an entirely different basis than that specified in the waiver given by the taxpayer.