http://decision.tcc-cci.gc.ca/tcc-cci/decisions/en/item/70359/index.do 
Deetlefs v. The Queen (March 26, 2014 – 2014 TCC 96) involved a taxpayer who had filed a GST notice of objection more than one year and 90 days after the date of the assessments in question. The court construed the application as one to extend the time to file the notice of objection. The taxpayer’s representative argued that the period should not start to run until the taxpayer became aware of the necessity to file a notice of objection. The court was obliged to reject this line of argument since the statute prohibited extension applications made more than one year after the expiry of the 90 day period for filing notices of objection:
[8] Ms. Deetlefs submits that the 90 day deadline should start to run from the time that the taxpayer becomes aware that a notice of objection is necessary.
[9] Unfortunately for the applicant, the applicable legislation does not permit this result. The deadline for filing a notice of objection is strict. It must be filed within 90 days after the relevant notice of assessment has been sent to the taxpayer.
[10] It appears that Ms. Deetlefs corresponded with the Audit and Collection Departments rather than the Appeals Division after the assessments had been issued. It is unfortunate that Ms. Deetlefs did not realize that a notice of objection had to be sent to the Appeals Division within 90 days, or an application to extend time had to be filed within the following year, in order to preserve the applicant’s objection and appeal rights. These steps were not taken.
[11] In the result, it is not possible to provide the relief that the applicant seeks and the application will be dismissed.