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Finality of assessment ito section 79A; deductibility of cost ito s11(a) (Custodial Services Case)

10 January 2012   (0 Comments)
Posted by: SAIT Technical
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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)

To access the full case, click here


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.


The Act requires that a minimum academic and practical requirments be set to register with a controlling body. Click here for the minimum requirements of SAIT.

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