SUMMARY The Supreme Court of Appeal (the “SCA”) recently upheld an appeal against the decision of the Tax Court that had upheld an appeal by Clicks Retailers Ltd (the “Respondent”) against the refusal by the Commissioner for the South African Revenue Service (the “Appellant”) to approve an allowance in terms of section 24C of the
BACKGROUND In May 2014, the South African Revenue Service (“SARS”) audited a taxpayer (the appellant) and assessments were raised against the taxpayer in or during December 2014. The taxpayer lodged an objection against these assessments on 5 June 2015, despite the fact that the taxpayer was obliged to lodge said objection within 30 (Thirty) business