The applicant objected to the denial of his claim to the Ontario new housing rebate, and he then accepted a CRA offer to refund the difference between his claim and amounts previously credited to him. When CRA tried to implement this settlement agreement, it discovered that the applicant was not entitled to any further rebate as he had purchased the house before the relevant entitlement date (June 18, 2009). The applicant filed an application under the Federal Court Act for enforcement of the settlement agreement.
After finding that he lacked the jurisdiction to consider the application (as it represented a "collateral attack on the validity of the tax reassessment"), Gascon J referred to the Galway and Cohen line of cases, and stated (at para. 54) that "the Agency was required to revoke the settlement agreement since no legal or factual basis supports Mr. Sood's claim to the provincial new housing rebate."
See summary under Federal Court Act, s. 18.5.