The appellant provided IT services through subcontractor consultants. The consultants in issue variously did not provide registration numbers on their invoices, did not have registration numbers, or used invalid registration numbers. The appellant was not entitled to ITCs in respect of these invoices. Sexton JA stated (at para. 4):
We are of the view that the legislation is mandatory in that it requires persons who have paid GST to suppliers to have valid GST registration numbers from those suppliers when claiming input tax credits.