Judges: CORBETT CJ, JOUBERT JA, HEFER JA, NESTADT JA AND NICHOLAS AJA
Date: 14 November 1989 and 22 February 1990
Also cited as: 1990 (2) SA 353(A)
Income tax – Gross income – Accruals – ‘The total amount . . . accrued to or in favour of’ the taxpayer – Meaning of – Whether equivalent to ‘to which he has become entitled’ or ‘became due and payable’ – Retailer selling wares to its customers on ‘6-months-to-pay’ revolving credit scheme – At year-end amount representing instalments not yet payable still outstanding – Date of accrual of income – Valuation of accruals consisting of rights to future payments – Instalments not yet payable to be included in gross income of taxpayer in the year of assessment in which he became entitled to them – Being the year in which he acquired the right to them – To be included at no more than the present value of the right to receive those instalments in the future – Section 1: definition of ‘gross income’ of the Income Tax Act 58 of 1962.
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