I got completion letter on 18 August
https://www.canada.ca/en/immigration-refugees-citizenship/services/study-canada/work/after-graduation/apply.html
I think they followed the regulations strictly. My expectation was that since you had an ongoing study permit extension application, your eligibility for status restoration should depend primarily on whether you submitted your PGWP application within 90 days after receiving your completion letter.
For instance, my study permit also expired on July 31st, and I received my completion letter on December 11th. I plan to submit my PGWP application this weekend, before March 11th (which falls within the 90-day window). Initially, I intended to submit without a restoration-of-status request. However, based on your situation and the information you've shared, it seems I may now need to include a restoration-of-status application alongside my PGWP application.
Fortunately, I received a correspondence letter regarding my study permit extension today. I'm hopeful for approval between now and March 11th, which would help me avoid this issue entirely.
I would suggest contacting IRCC directly to get more clarity and confirmation on your specific circumstances. Unfortunately, however, it seems likely you might end up needing to pay the restoration fees. I understand how difficult this must be, especially since you've been unable to work since August. I'm really sorry you're experiencing this challenging situation.