The GST registration number of the supplier shown on the invoices provided to the Appellant ("Comtronic") was not that of the suppliers but was a validly issued number belonging to someone else. Comtronic paid for the supplies together with GST but the supplier never remitted the GST. Boyle J held that not only did s. 169(4) of the Act require that the registrant have obtained the GST registration number of the supplier, but it must be the number which had been assigned to that supplier. After quoting Systematix, he stated (at paras. 26, 33):
Given the wording of paragraph 169(4)(a), as well as the Reasons for Judgment of Archambault J. in the Tax Court ( 2006 TCC 277 (CanLII), [2006] G.S.T.C. 120) with which the Federal Court of Appeal agreed, I take the court's reference to "valid GST registration numbers from those suppliers" to mean GST registration numbers validly assigned to those suppliers.
… I am unable to see how the broad wording of the relevant provisions and the interpretation thereof by the Federal Court of Appeal that the wording is mandatory and should be strictly enforced, and which requires that the ITC claimant have the registration number assigned to the supplier, should result in any different outcome in this case