Taxpayer B v Commissioner for the South African Revenue Service (IT45710)
Taxpayer B v Commissioner for the South African Revenue Service (IT45710) [2022] ZATC 10; 85 SATC 388 (29 November 2022)
The Court held that the applicant is not entitled to rely on the new ground of appeal in its rule 32 statement because the new ground constitutes a challenge to the gross income amount of the disputed assessment, which was never specifically objected to under rule 7. An objection to the deduction amount is not equivalent to an objection to the gross income amount, and rule 32(3) prohibits new grounds of objection against parts or amounts not previously objected to. The Court distinguished the present matter from ITC 1912 and Matla Coal, finding that in those cases the new grounds related to t…
Source excerpt
- Tax Court Rules
- New Grounds Of Appeal
- Income Tax Assessment
- Deductions
- Statutory Interpretation