CZY (In Liquidation) v Commission for the South African Revenue Service (IT 45997)
CZY (In Liquidation) v Commission for the South African Revenue Service (IT 45997) [2024] ZATC 4; 87 SATC 255 (27 February 2024)
The court found that the applicant provided a reasonable and justified explanation for the delay in delivering the rule 36(6) notice, given the volume and technical nature of the discovered documents and the need to consult with liquidators and former employees. The court held that, on a prima facie basis, at least one category of documents sought was relevant to the issues in dispute, specifically those relating to the decision to impose understatement penalties. The applicant acted bona fide, and there was no evidence of intentional non-compliance or prejudice to SARS. The interests of just…
Source excerpt
- Condonation
- Tax Discovery
- Understatement Penalty
- Section 24c Allowance
- Tax Administration Act
- Interest On Tax