Tax Administration Act, 2011 (Act No. 28 of 2011)RulesRules Promulgated under section 103 of the Tax Administration Act, 2011 (Act No. 28 of 2011)Part E : Procedures of tax court32. Statement of grounds of appeal |
| (1) | The appellant must deliver to SARS a statement of grounds of appeal within 45 days after delivery of— |
| (a) | the required documents by SARS, where the appellant was requested to make discovery under rule 36(1); or |
| (b) | the statement by SARS under rule 31. |
| (2) | The statement must set out clearly and concisely— |
| (a) | the grounds upon which the appellant appeals; |
| (b) | which of the facts or the legal grounds in the statement under rule 31 are admitted and which of those facts or legal grounds are opposed; and |
| (c) | the material facts and the legal grounds upon which the appellant relies for the appeal and opposing the facts or legal grounds in the statement under rule 31. |
| (3) | The appellant may not include in the statement a ground of appeal that constitutes a new ground of objection against a part or amount of the disputed assessment not objected to under rule 7. |