Summary of the case: CSARS v South African Custodial Services (Pty)Ltd
Income Tax Section 79A - finality of assessment; s.22(2A) - whether letter from Commissioner constitutes a revised assessment;
Income Tax Section 11(a) - deductibility of cost of building prison in terms of concession agreement on land owned by State; sub-contractor, not respondent incurring expenses concerning materials and equipment; (s.11(a) - s.11(bA) - cost of building prison not deductible; interest and related fees deductible)
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.