What is the authority for a general procedure decision?

Canada (Federal), Canada

The following excerpt is from Le v. The Queen, 2018 TCC 65 (CanLII):

The authority for this principle comes from a general procedure decision of Bowman, C.J. in Scavuzzo v. R., [2005] G.S.T.C. 199. At para. 27 he wrote:

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