Commissioner for South African Revenue Service v Clicks Retailers (Pty) Ltd (58/2019) [2019] ZASCA 187 (3 December 2019)

Income Tax Act 58 of 1962 – s 24C – claim for allowance in respect of cost
of complying with terms of loyalty card programme – customer applying for issue of card
– award of points on value of purchases – vouchers issued based on number of points
accumulated –vouchers presentable as part payment for future purchases of goods –
whether amount received from earlier sales used to finance future expenditure on same
contract