(1) |
A taxpayer who is aggrieved by an assessment made in respect of the taxpayer may object to the assessment. |
(2) |
The following decisions may be objected to and appealed against in the same manner as an assessment— |
(a) |
a decision under subsection (4) not to extend the period for lodging an objection; |
(b) |
a decision under section 107(2) not to extend the period for lodging an appeal; and |
(c) |
any other decision that may be objected to or appealed against under a tax Act. |
(3) |
A taxpayer entitled to object to an assessment or "decision" must lodge an objection in the manner, under the terms, and within the period prescribed in the "rules". |
(4) |
A senior SARS official may extend the period prescribed in the "rules" within which objections must be made if satisfied that reasonable grounds exist for the delay in lodging the objection. |
(5) |
The period for objection must not be so extended— |
(a) |
for a period exceeding 30 business days, unless a senior SARS official is satisfied that exceptional circumstances exist which gave rise to the delay in lodging the objection; |
[Section 104(5)(a) substituted by section 57 of the Tax Administration Laws Amendment Act, 2016 (Act No. 16 of 2016)]
(b) |
if more than three years have lapsed from the date of assessment or the "decision"; or |
(c) |
if the grounds for objection are based wholly or mainly on a change in a practice generally prevailing which applied on the date of assessment or the "decision". |