Before dismissing an application for judicial review of a decision of the CCRA not to waive interest and penalties in respect of the failure of the taxpayer's accountant to file the taxpayer's return on time while the taxpayer was out of the country, and the omission from the return of a T-4, Noël J. stated:
"Where a body such as the CCRA is given a broad discretion like that accorded by s. 220(3.1) of the ITA, the deference shown to that body should be broad. The reviewing court should consider whether the discretion was 'exercised in good faith and, where required, in accordance with principles of natural justice, and where reliance has not been placed upon considerations irrelevant or extraneous to the statutory purpose' .... If these criteria are properly met, the Court should not interfere."