… the grounds of assessment were unreasonable in two respects, namely the incorrect utilisation of the Net Asset Value (NAV) methodology and the Commissioner’s valuation of the shares as nil:
unreasonable grounds of assessment COMMISSIONER FOR THE SOUTH AFRICAN REVENUE SERVICE v STEPNEY INVESTMENTS (PTY) LTD 78 SATC 86Download
This judgment is useful for arguing against unreasonable conduct by Revenue agencies when they issue TP assessments without following the OECD TPGs on methodologies.
