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(a) Forge Packaging (Pty) Ltd v Commissioner for the South Africa Revenue Service; (b) United Manganese of Kalahari (Pty) Ltd v The Commissioner for the South African Revenue Service; (c) Rappa Resources (Pty) Ltd v The Commissioner for the South African Revenue Services; (d) Lueven Metals (Pty) Ltd v The Commissioner for the South African Revenue & (e) Absa Bank Limited & United Towers (Pty) Ltd v The Commissioner for the South African Revenue Service
On appeal from the Supreme Court of Appeal (hearing an appeal from the High Court of South Africa, Gauteng Division, Pretoria):
Synopsis:
Section 105 of Tax Administration Act 28 of 2011 — test for granting a direction — relevant considerations in granting or
refusing direction — discretionary nature of power to grant direction — production of rule 53 record pending direction
Peremption of appeal — relevant factors in overlooking