Telkom SA SOC Limited v The Commissioner for the South African Revenue Service (239/2019) [2020] ZASCA 19 (25 March 2020)

Income Tax Act 58 of 1962 (the Act) – s 24 I – losses or gains caused by
foreign exchange fluctuations – proviso to s 24 I(10) – not a self-standing provision for
deduction of a commercial loss unconnected to foreign exchange currency differences
– Natal Joint Municipal Pension Fund v Endumeni Municipality 2012 (4) SA 593 (SCA)
– unitary but not uniform exercise in purposive interpretation of contracts and statutes
– application of contra fiscum rule and presumption that statute law not unjust,
inequitable or unreasonable.