Commissioner for South African Revenue Service v Spur Group (Pty) Ltd (320/2020) [2021] ZASCA 145 (15 October 2021)

Tax Law – Income Tax Act 58 of 1962 (the ITA) – whether
there was a sufficiently close connection between the taxpayer’s
expenditure of a contribution to a trust in respect of the implementation of
an employees’ share incentive scheme and its income producing
operations so as to qualify for a deduction under s 11(a) of the ITA – the
connection between the contribution and the taxpayer’s production not
close or immediate enough to justify the deduction – SARS not precluded
from raising additional assessments in respect of the taxpayer’s 2005-2009
years of assessment by operation of the period of limitations provided in
s 99(1) of the Tax Administration Act 28 of 2011