I expect that it went a bit pear shaped when CASA wrote to the applicant for the AOC and asked for:
[A] tabular legend, showing how and where the actions called up under each applicable provision of the civil aviation legislation germane to the conduct of operations ... are effectively addressed in the terms of the contractual agreement(s).
With so many people employed by someone other than the holder of the AOC authorising the proposed Bonza operations, that's gonna be a very complicated 'tabular legend'. And producing that is the 'easy' bit. Then CASA's gonna want to be shown how the AOC holder monitors and secures compliance with the contractual agreement(s).