Szabunia v. Canada (Attorney General)

canada, canadian, case law, court opinion, canlii, fct, 2026canlii99930, 2026 canlii 99930 (fc), 2026, canlii, 99930, (fc), 26-t-336, 2026, procedure, judicial review, extension of time, whether continuing intention to pursue judicial review shown, steps taken to challenge cra decision through taxpayer relief and objection, effect of cra letter not advising 30 days for judicial review, continuing intention found despite gaps, extension of time granted, administrative law, judicial review, procedural fairness and reasonableness, whether proposed application has some potential merit, cra refusal to consider second review request as late, evidence of cra agents advising portal submission despite expired deadline, respondent submissions not addressing that evidence, potential merit found, extension of time granted, procedure, judicial review, extension of time, whether respondent would suffer prejudice from delay, respondent asserting prejudice based on delay and lack of reasonable explanation, requirement for evidence of actual prejudice as independent factor, no material evidentiary or procedural prejudice asserted, no prejudice found, extension of time granted, procedure, judicial review, extension of time, whether delay reasonably explained for entire period, applicant unaware until cra call that judicial review was only recourse, preparation as self, represented litigant and registry rejection for deficiencies, lack of legal understanding not a reasonable justification, explanation not reasonable for entire period, extension of time granted