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Tax Law [2024] ZAGPJHC 827

TALT v Commissioner For South African Revenue Services (A2023/077887)

TALT v Commissioner For South African Revenue Services (A2023/077887) [2024] ZAGPJHC 827; 87 SATC 222 (27 August 2024)

The Full Court held that the taxpayer's objection to the 2012 additional assessment, although framed in terms of prescription, was in substance an objection to the inclusion of the taxable capital gain of R47 329 834 in its taxable income. The amended Rule 32(3) permits new grounds of appeal unless they relate to a part or amount of the assessment not previously objected to. Since the taxpayer's objection covered the disputed amount, the new ground—relying on the conduit-pipe principle—was permissible. The Court found that refusing to allow the new ground would prevent the true issue from bei…

  • Tax Administration Act
  • Income Tax Act
  • Prescription Of Tax Assessment
  • Grounds Of Objection
  • Taxable Capital Gain
  • Conduit Pipe Principle
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