6 March 2026 – Income Tax Act 58, 1962, and Tax Administration Act, 2011
Tax Law – general anti-avoidance rule (GAAR) under Income Tax Act 58 of 1962 (ITA) – appeal against GAAR assessment – statement of grounds for opposing appeal (rule 31 statement) in terms of rule 31 of rules promulgated under Tax Administration Act 28 of 2011 (TAA rules) – modification and amendment of GAAR assessment in rule 31 statement – irregular step application under uniform rule 30 by taxpayer in respect of rule 31 statement – whether modification and amendment authorised under section 80J(4) of ITA or TAA rule 31(3).