In theory. That's why I suggested in the past that we need to revisit how the provisions of the act are enforced, because we are seeing more and more cases taking more than one election cycle to resolve. I'm not sure that it's appropriate for the circumstances.
The purpose of subsection 463(2) is not to determine whether there has been a breach or not. It's to ensure that the return is filed and is filed correctly. Matters of breaches will be dealt with as a separate matter, but the first thing we need is an accurate return that reflects the transactions. If that return points to breaches, well, the process would follow its course and it may be referred to the commissioner.
Again, subsection 463(2) is about a procedure to ensure that we bring closure in ensuring that there is a returned file and that it's accurate.