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Harare High Court
MDS (PVT) LTD v Commissioner of the Zimbabwe Revenue Authority
HH 602-17
Case Details
Court
Harare High Court
Date
12 September 2017
Citation
HH 602-17
Neutral Citation
[2017] ZWHH 602
Outcome
unknown
Case Type
Appeal
Bench
Presiding
Kudya J
Full Bench
Kudya J
Areas of Law
Tax lawAdministrative law
Keywords
Income tax assessmentUnder-declared salesUnderstated purchasesMark-up calculationFuel business
Tags
Income taxTax assessmentBusiness incomeFuel sales
legislation
Statutes Cited
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ai analysis
Case Summary
Key Issues
- {"issue_text":"Whether invoices specified in grounds of appeal were cancelled and whether appellant was liable for tax on those amounts","issue_type":"mixed","dispositive":"yes","related_facts":"Disputed invoices totaling US$118,245 for 2010 tax year"}
- {"issue_text":"Whether appellant under-declared 2010 sales by US$119,556.59 representing 12% mark-up","issue_type":"factual","dispositive":"yes","related_facts":"Variance between declared sales and reconstructed sales using mark-up"}
- {"issue_text":"Whether appellant understated 2011 purchases by US$31,336.56 representing 12% mark-up","issue_type":"factual","dispositive":"yes","related_facts":"Variance between purchase schedules submitted"}
- {"issue_text":"Whether appellant was liable for tax on additional 2011 income of US$359,073","issue_type":"factual","dispositive":"yes","related_facts":"Difference between cash sales schedules"}
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background
Facts of the Case
Background
The appellant, MDS (PVT) LTD, appealed against amended income tax assessments for the 2010 and 2011 tax years where the Commissioner added back substantial amounts to gross income based on findings of under-declared sales, understated purchases, and application of mark-up rates to determine actual taxable income.
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