TNM LTD v THE COMMISSIONER GENERAL ZIMBABWE REVENUE AUTHORITY

Key Issues

• {"issue_text":"Whether the appeal is invalid due to mis-citation of the respondent","issue_type":"procedural","dispositive":"yes","related_facts":"Notice of appeal cited Commissioner General instead of Zimbabwe Revenue Authority"}
• {"issue_text":"Whether the respondent failed to give reasons for reassessing the appellant","issue_type":"law","dispositive":"no","related_facts":"Reassessment issued in February 2018"}
• {"issue_text":"Whether there was fraud, misrepresentation or willful non-disclosure entitling reassessment after prescription period","issue_type":"law","dispositive":"no","related_facts":"Reassessment for years 2010 and 2011 after six-year prescription period"}
• {"issue_text":"Whether General Notice 274 of 2010 applies to loss brought forward from 2009","issue_type":"law","dispositive":"no","related_facts":"Loss of $33,849,878.00 from 2009"}
• {"issue_text":"Whether disallowance of various deductions is lawful and justifiable","issue_type":"law","dispositive":"no","related_facts":"Multiple disallowed deductions including capital redemption allowance, costs, penalties, fees, and interest"}

Background