Is a Minister's duty to assess a taxpayer's income tax returns mandatory or discretionary?

Canada (Federal), Canada

The following excerpt is from Nautica Motors Inc. v. Canada (Minister of National Revenue), 2002 FCT 422 (CanLII):

The applicants submit that the Minister's duty to assess the taxpayer's income tax returns is mandatory, not discretionary (see Schatten v. M.N.R. 96 D.T.C. 6102 (F.C.T.D.)).

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