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28 April 2026 – Income Tax Act, 1962
Whether the Tax Court was correct in granting SARS leave to amend its rule 31 statement and refusing BASF leave to amend its rule 32 statement – whether SARS’s proposed amendments constituted an impermissible novation of the legal and factual basis of the additional assessment on transfer pricing transaction issued under section 31(2) of the Income Tax Act 58 of 1962 (as it read in 2011).
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