Yes it can. 

In March 2013 the Administrative Appeals Tribunal (AAT) upheld the decision by the Commissioner of Taxation in Hadrian Fraval Nominees Pty Ltd V TC of T,  to reject an entity's R & D Tax Concession claim because it could not substantiate the claim.

The Australian Taxation Office (ATO) sought repayment of the tax incentive offsets and imposed penalties at the rate of 25%.

This action by the ATO demonstrates the need to maintain adequate records to substantiate the R & D Activities claimed.

Refer to below for information concerning compliance:

http://mcnamaraandco.com/news/2013/04/what-are-the-compliance-obligations-of-companies-for-the-research-and-development-r-d-tax-incentive/