This case is summarized in greater detail under s. 231(1). In brief, the appellant claimed a bad debt credit under s. 231 with respect to the GST in a customer receivable. After Revenue Quebec indicated that it would deny this claim on the basis that the situation instead engaged s. 232 (apparently based on the acceptance by the appellant of a proposal made by the customer to its creditors almost 23 months previously), the appellant thereupon issued a credit note to the customer, and claimed a credit under s. 232(3) for the GST in its return for the related reporting period. Revenue Quebec considered that the credit note had not been issued "within a reasonable time," as required by s. 232(3). Tardif J first found that the appellant was entitled to the s. 231 credit.
Respecting the "reasonable delay" issue arising under s. 232(3) in the alternative, Tardif J stated (at para. 55) that "it is true that a delay of 23 month is relatively long," but found that it was reasonable in the circumstances as the appellant did not find out that Revenue Quebec was denying its bad debt claim until shortly before issuing the credit note. The appeal was allowed.