Rule 56 default judgment against SARS: lessons from Virgin Mobile
SARS missed its Rule 31 deadline by more than a year, then filed five business days after receiving a Rule 56 notice. In CSARS v Virgin Mobile, the Supreme Court of Appeal ruled that this late filing cured the default. Here is what the judgment means for taxpayers seeking default judgment against SARS
Rules 31 to 33: how the courts treat new grounds in tax appeals
SARS rebuilt its case mid-appeal and lost at the Supreme Court of Appeal. Two taxpayers raised new grounds late and kept them. Three recent judgments show where Rules 31 to 33 draw the line, and why the objection you draft today decides the appeal you can argue later.