Statute barred input tax credits, in my opinion, is one of the most complex and often frustrating provisions, within the Excise Tax Act, to interpret and apply accurately.
In my experiences with Auditors, this view is shared universally, whereby Auditors simply deny outright statute barred input tax credits declared on a HST/HST return, under audit, or Auditors will not even consider credit assessing omitted statute barred input tax credits.
With that said, I am going to give my interpretation in the Guide of the Excise Tax Act section provisions, applications, and Tax Court of Canada examples.