In the matter between A GROUP CC (Appellant) and the commissioner for the South African Revenue Services (Respondent). Judgement delivered on 2 February 2005.
We will refer to the parties to this appeal as the "Taxpayer” and the"Commissioner” respectively.The taxpayer in fact represents a number of entities which by agreement and pursuant to an order of court have been consolidated into one for the purposes of the tax assessments.This appeal concerns the Commissioner’s revised assessments for the tax years 2000, 2001 and 2002 respectively.The taxpayer is represented by the joint liquidators of the various entities.The essential factual background is not in dispute.For the purposes of this appeal the parties have placed before the court a comprehensive set of agreed facts which we will refer to where it is necessary to do so.
Section 240A of the Tax Administration Act, 2011 (as amended) requires that all tax practitioners register with a recognized controlling body before 1 July 2013. It is a criminal offense to not register with both a recognized controlling body and SARS.