http://decision.tcc-cci.gc.ca/site/tcc-cci/decisions/en/item/66420/index.do 
George v. The Queen[1] (January 16, 2014) dealt with a claim for GST Input Tax Credits. CRA had rejected the claim because it was not documented:
[1] In her GST/HST return for the period from January 1, 2011 to December 31, 2011 (Exhibit R-3), the appellant claimed under the Excise Tax Act (ETA) input tax credits (ITCs) of $22,000. She had operated a buffet restaurant for one year.
[2] During the audit and at the objection level, neither she nor her representative provided a list of incurred expenses in order to substantiate the ITCs claimed. Ms. Lucy Bell, the auditor for the Canada Revenue Agency (CRA), and Ms. Brie Gill, the appeals officer for the CRA, both testified that they had spoken to the appellant and her accountant, Mr. Reuben Morgan, more than once, and had given them plenty of time to comply with the request to provide supporting documentation for their claims.
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[5] Just before trial, the appellant sent to counsel for the respondent a copy of the lease (being part of Exhibit R-1), and the respondent conceded an amount of $12,655.50 as ITCs for GST/HST paid on the rent. There remains an amount of $9,344.50 that is still at issue.
[6] The appellant did not present additional evidence to convince the Court that ITCs had not already been claimed in a prior year with respect to the purchase of the POS system. However, she now claims that she made cash disbursements of $107,622 for renovations for her business in 2011, on which she says she paid $12,381 in GST/HST. In support of this new claim, she filed an invoice from Nu-Port Homes Inc. (Exhibit A-1), billing her $40,241 for materials and $55,000 for labour. There is no GST/HST registration number on that invoice. Ms. Bell conducted a search on the CRA web site and found a GST/HST registration number for Nu-Port Homes Inc. that had not been active since at least the end of 2007. The appellant’s agent, Mr. Morgan, attempted to file an Ontario government document regarding that corporation for 2009. I did not accept it because no one from Nu-Port Homes Inc. was present to testify concerning that document and it was not relevant to the period at issue.
The court concluded that the evidence did not substantiate the appellant’s claim:
[8] In court, the appellant relied on Exhibit A-1 to claim the disallowed balance of the ITCs. I cannot accept the invoice filed as Exhibit A-1 as supporting the appellant’s right to claim ITCs on renovation expenses paid in cash to a supplier that is not validly registered for GST/HST purposes.
[9] Under subsection 169(4) of the ETA, a registrant may claim ITCs only if he or she provides the information required in section 3 of the Input Tax Credit Information (GST/HST) Regulations (Regulations). The GST/HST registration number is one item of prescribed information. That number is not shown on the invoice provided by the appellant, and she did no verification to determine whether the supplier was validly registered. The information required by the regulations is mandatory (
Davis v. Canada, [2004] T.C.J. No. 505(QL), [2004] G.S.T.C. 134, 2004 TCC 662) and the requirement must be strictly enforced (
Systematix Technology Consultants Inc. v. Canada, [2007] F.C.J. No. 836 (QL), [2007] G.S.T.C. 74, 2007 FCA 226).
[10] In the circumstances, the appellant has not demonstrated that she is entitled to the amount of $9,344.50 remaining out of the total ITCs claimed in her GST/HST return for the year 2011.
Accordingly the appeal was dismissed.
[1] 2014 TCC 19