Important:
This answer is based on tax law for the year ending 28 February 2020.
Answer:
We may need more information before we can provide the required guidance. The ground for invalidity that was stated in the notice is not a correct one. It is very likely that SARS required additional substantiating documents necessary to decide the objection, but then didn’t do the rule 8 request, but considered the objection invalid (incorrectly so).
It appears that the dispute relates to the apportionment of the income - the remuneration is deemed to have accrued evenly over the period that those services were rendered; paragraph (C) of the proviso to section 10(1)(o)(ii).