Commissioner for the South African Revenue Service v Marshall NO and Others (39219/2014) [2015] ZAGPPHC 609 (21 August 2015)

50 Reportability

Brief Summary

Appeal — Application for leave to appeal — Interpretation of section 8(5) of the Value Added Tax Act — Applicant sought leave to appeal against a judgment regarding the interpretation of tax provisions — Court found that while it remained convinced of its interpretation, there existed a possibility of differing conclusions by another court — Leave to appeal granted to the Supreme Court of Appeal, with costs to be included in the appeal.

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[2015] ZAGPPHC 609
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Commissioner for the South African Revenue Service v Marshall NO and Others (39219/2014) [2015] ZAGPPHC 609 (21 August 2015)

IN
THE HIGH COURT OF SOUTH AFRICA
(GAUTENG
DIVISION, PRETORIA)
Case
number: 39219/2014
Date:
In
the matter between:
THE
COMMISSIONER FOR THE SOUTH
AFRICAN
REVENUE SERVICE
APPLICANT
And
ALAN
GEORGE MARSHALL
N.O.                                                                     1
ST
RESPONDENT
RENE
PIETER DE WET
N.O.                                                                              2
ND
RESPONDENT
KNOWLEDGE
LWAZI MBOYI
N.O.                                                                  3
RD
RESPONDENT
JOHN
ANDREW DE MARTIN
N.O.                                                                    4
TH
RESPONDENT
RAY
SIPHOSOMHLE
SITHEMBELE                                                                5
TH
RESPONDENT
MSENGANA
N.O.                                                                                                   6
TH
RESPONDENT
KOVIN
SHUNMUGAM
NAIDOO                                                                       7
TH
RESPONDENT
SAMSON
MAKHUDU
GULUBE                                                                         8
TH
RESPONDENT
JUDGMENT
(APPLICATION FOR LEAVE TO APPEAL)
PRETORIUS
J,
[1]
This
is an application for leave to appeal against the judgment delivered
on 6 May 2015.
[2]
I
have read the notice for the application for leave to appeal and have
listened to the arguments by counsel.
[3]
Although
I am still convinced that my finding on the interpretation of section
8(5) of the Value Added Tax No. 89 of 1991 read with
section 11(2) n
of the Value Added Tax Act is correct, there is a possibility that
another court may come to a different conclusion.
[4]
Therefore
I make the following order:
1.
Leave
to appeal is granted to the Supreme Court of Appeal;
2.
Costs
of this application to be costs in the appeal.
_____________________
Judge C Pretorius
Case number

: 39219/2014
Appeal for leave to appeal
heard on

: 6 August 2015
For the Applicant

:
Adv. A Sholto-Douglas/Adv Cassim
Instructed by

: STATE ATTORNEY
For the Respondent

: Adv. PA Swanepoel
Instructed by

: EDWARD NATHAN SONNENBERGS
INC
Date of Judgment

: