The appellant had demolished the fundamental assumption of the Minister that substantial completion occurred in April 1995 by advancing evidence that he had installed tiles in parts of the house, completed installation of some of the hardwood floor, installed light fixtures, installed moulding on the cabinet and installed shower stalls after that date. As the onus had shifted to the Minister to put forward evidence of another date that was still outside the two-year limit referred to in s. 256(3), and this had not been done, the appeal was allowed. Bowman T.C.J. also stated: