9 February 2026 – Tax Administration Act, 2011, and Promotion of Administrative Justice Act 3 of 2000
Section 164(3) of the Tax Administration Act 28 of 2011 (TAA) – Pay Now Argue Later – Section 9 reconsideration request – Section 6(2)(f) of Promotion of Administrative Justice Act 3 of 2000 (PAJA) – whether SARS, acting under section 9 and section 164 of the TAA, and subject to review under section 6 of PAJA, acted lawfully and fairly when it refused to suspend the taxpayer’s obligation to pay the disputed tax debt despite the taxpayer offering substantial security through his TMM shareholding.
