Generally, taxpayers must disprove assumptions CRA makes in its assessment. So, a CRA assumed property value would be presumed correct unless the taxpayer disproved it. But here CRA went even further. It brought the municipal property valuator to court to explain how he arrived at the evaluation. The taxpayer did not bring its own property valuator. So the court accepted CRA's valuation, even though cases have held that municipal property valuations may not be reliable. But key to this case, perhaps, was the fact that the municipal property valuator was there as a witness.
Although it may not always be so, the decision in this case makes it clear that if you are challenging CRA's assessment based on disputing a property value it has used, you should take your own valuation expert to court with you.
See K.M. Construction et Rénovation inc. c. La Reine 2015 CCI 206 (Lamarre, ACJ)