Canadian commercial pilot license question...?

Question

The 35 dual hours that must be completed... Can that include dual instruction during the PPL, or does it have to be post-PPL new dual hours?

Answer 1

http://www.tc.gc.ca/CivilAviation/Regser...

Yes the hours are after the PPL.

If you scroll down to Division VII (4) Experience, it says following the issue of a PPL.

Answer 2

Both times are "following the issue of a Private Pilot License".

Really, you are going to need them anyways.  Remember, you need 200TT and 100PIC.  Also, they want more polish for your commercial flight test (read the CPL Flight Test Standards) and you probably want to throw a few ratings on there to be more marketable (night, multi-engine, seaplane, mountain training, etc).  I did my Group 1 IFR as part of my buildup and saved a ton of cash, but it was pretty intense.