http://decision.tcc-cci.gc.ca/tcc-cci/decisions/en/item/72955/index.do 
Academy of Applied Pharmaceutical Sciences v. The Queen (June 5, 2014 – 2014 TCC 171 ) was a GST/HST appeal dealing with the allocation of ITCs between the exempt and non-exempt components of a business:
[3] The Appellant, the Academy of Applied Pharmaceutical Sciences, was at all material times a GST/HST registrant. The Appellant is a post-graduate training college for persons who are seeking a career in pharmaceutics. The Appellant also provides continuing education programmes for the pharmaceutical industry.
[4] The Academy has two kinds of programmes:
1) The Diploma Programme on pharmaceutical science which is GST/HST exempt, and
2) The Workshop Programme which provides continuing education in the form of conferences on new trends in pharmaceutical sciences. The Workshop Programme is subject to GST/HST.
The appellant had used a 50% allocation and claimed that it was based on advice from a CRA auditor. An audit of subsequent period resulted in a much lower allocation:
[8] In November 2012, another audit was conducted by Mr. Dunstan Egbert of the CRA dealing with the period of January 1, 2008, to June 30, 2012. After having completed the audit, Mr. Egbert advised that a 50% allocation was simply not reasonable in the circumstances for the period under review. Mr. Egbert determined that no more than 11% should have been allocated to mixed expenses for the period of January 1, 2010 to December 31, 2010. He also determined that no more than 14% of the mixed expenses incurred by the Appellant in the period from January 1, 2011 to June 30, 2012, related to the provision of taxable supplies. Mr. Egbert recommended that the Appellant re-examine and re-evaluate the apportionment every year.
The appellant relied upon the doctrines of estoppel and officially induced error. The court did not accept this position:
[29] Whatever representations may have been made by Ms. Yu, these were representations concerning the operation of the law and not representations of fact. Any representations purportedly made by Ms. Yu are not binding on the Minister and the Minister can re-assess the Appellant subject to any limitation period. This does not relieve the Appellant of its obligation to accurately report liabilities pursuant to the Act. It does not relieve the Appellant of its obligation to allocate mixed expenses as between exempt and taxable supplies or commercial activities in a fair and reasonable way that has some basis in the Appellant’s business operations.
Conclusion
[30] In conclusion, I find that:
a) Neither the equitable doctrines of estopped or officially induced error are available to the Appellant in the circumstances of this case on the basis that Ms. Yu may have suggested that an allocation ratio for mixed expenses of 50% could be used on a go-forward basis. There is nothing in law to prevent the Minister from re-assessing the GST/HST liability of the Appellant for the period here under review.
b) The Appellant has not demonstrated on a balance of probabilities that the percentage of expenses incurred by the Appellant attributable to taxable supplies and commercial activity of the Appellant of 11% and 14% for the period January 1, 2010 to December 31, 2010, and the period January 1 2011 to June 30, 2012, respectively was not fair or reasonable and not reflective of the Appellant’s business activity.
As a result the appeal was dismissed.