Can a Respondent in two cases be prejudiced by the amendment concerning interest paid relevant to the acquisition of limited partnership interests?

It is difficult to see how the respondent in these cases could be prejudiced by the amendment concerning interest paid relevant to the acquisition of the appellants’ limited partnership interests, as the respondent in her Amended Replies has pleaded that one of the assumptions on which the Minister relied in assessing the appellants is that: [The General Partner] committed to provide financing to the individual investors … in exchange for non-assignable promissory notes from each investor … Amended Reply in Belchetz v. The Queen, p. 9(o)