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Tax Law [2024] ZATC 12

X and Another v Commissioner for the South African Revenue Service (52/2023)

X and Another v Commissioner for the South African Revenue Service (52/2023) [2024] ZATC 12 (2 December 2024)

The court held that the applicants' Second Objection failed to comply with the mandatory requirements of rule 7(2)(b) of the Tax Administration Act rules. The objections were vague, lacked specificity, and did not address each assessed amount or provide the documents required to substantiate the grounds of objection. The applicants failed to provide SARS with access to the Healthbridge system and did not submit supporting documentation for their objections regarding donations tax, VAT, and unexplained deposits. The court found that SARS was justified in invalidating the objection under rule 7…

  • Tax Administration Act
  • Validity Of Objection
  • Burden Of Proof
  • Donations Tax
  • Vat Assessment
  • Procedural Compliance
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