Purlish Holdings (Proprietary) Limited v Commisioner for South African Revenue Service (76/2018) [2019] ZASCA 4 (26 February 2019)

Appeal against imposition of understatement penalties – the appellant’s conduct fell within the category listed in items (a) to (d) of the definition of ‘understatement’ in s 221 of the Tax Administration Act – SARS suffered prejudice – no bona fide or inadvertent error – the imposition of penalties was justified – the increase of understatement penalties by the Tax Court incompetent and set aside.