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), prescribing the procedures to be followed in lodging an objection and appeal against an assessment or a decision subject to objection and appeal referred to in Section 104(2) of that Act, Procedures for Alternative Dispute Resolution, the conduct and hearing of appeals, application on notice before a Tax Court and Transitional RulesPart 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 a clearly and concise statement of— |
| (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. |