@azi3020980: you appear to be in need of competent, experienced professional assistance.
Lawyer-Up if you have not already.
Actually, the days in Canada would NOT count anyway, or to be more precise, are NOT relevant for purposes of whether the applicant met the actual physical presence requirement.
This is true for any citizenship applicant. ONLY days IN Canada BEFORE the day the citizenship application was made count at all toward meeting the citizenship requirement. There is no counting of days AFTER applying. That is, being reported for a breach of the RO some three years after making the application (as is the situation here) has NO relevance for purposes of meeting the actual physical presence requirement.
HOWEVER, of course the OP, the applicant, MUST win the appeal to keep PR status, let alone be eligible for a grant of citizenship.
The response by PMM needs to be clarified.
The Minister has discretion (which is commonly exercised) to "suspend" processing a citizenship application even BEFORE a Removal Order is issued if there is cause to investigate the applicant for inadmissibility, such as for a failure to comply with the Residency Obligation. This is prescribed by
Section 13.1 in the Citizenship Act.
Generally, if the application is suspended, as PMM states, there is no "progress," no further processing of the application pending the resolution of the matter triggering the suspension.
However, the issuance of a Removal Order itself can be grounds to deny the application outright, since a PR subject to a Removal Order does NOT meet the requirement to not be under a removal order, as prescribed in the requirements for a grant of citizenship in
Subsection 5(1)(f) in the Citizenship Act, and the applicant MUST not only meet those requirements (as listed in Subsection 5(1) Citizenship Act) when the application is made, but continue to meet those requirements right up to the taking of the oath.
It is not clear whether IRCC employs a uniform practice in how it approaches these situations. At the least, Subsection 22(6) prohibits taking the oath for citizenship if the applicant "no longer" meets "the requirements . . . for the grant of citizenship," which an applicant subject to a Removal Order does not (again, pursuant to Subsection 5(1)(f) in the Citizenship Act). Thus, unless and until the IAD actually sets the Removal Order aside, the applicant is not eligible to take the oath.
Again, it appears to be time to get a lawyer.
