IN THE HIGH COURT OF SOUTH AFRICA

(GAUTENG DIVISION, PRETORIA)

		Case number: 39219/2014
						          Date:

DELETE WHICHEVER IS NOT APPLICABLE
(1)	REPORTABLE: YES/NO
(2)	OF INTEREST TO OTHERS JUDGES: YES/NO
(3)	REVISED

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         DATE                           SIGNATURE

							
In the matter between:

THE COMMISSIONER FOR THE SOUTH
AFRICAN REVENUE SERVICE
APPLICANT

And

ALAN GEORGE MARSHALL N.O.
1ST RESPONDENT
RENE PIETER DE WET N.O.
2ND RESPONDENT
KNOWLEDGE LWAZI MBOYI N.O.
3RD RESPONDENT
JOHN ANDREW DE MARTIN N.O.
4TH RESPONDENT
RAY SIPHOSOMHLE SITHEMBELE
5TH RESPONDENT
MSENGANA N.O.
6TH RESPONDENT
KOVIN SHUNMUGAM NAIDOO
7TH RESPONDENT
SAMSON MAKHUDU GULUBE
8TH RESPONDENT

JUDGMENT
(APPLICATION FOR LEAVE TO APPEAL)
_____________________________________________________________
PRETORIUS J,
[1]	This is an application for leave to appeal against the judgment delivered on 6 May 2015.
[2]	I have read the notice for the application for leave to appeal and have listened to the arguments by counsel.
[3]	Although I am still convinced that my finding on the interpretation of section 8(5) of the Value Added Tax No. 89 of 1991 read with section 11(2) n of the Value Added Tax Act is correct, there is a possibility that another court may come to a different conclusion.
[4]	Therefore I make the following order:
1.	Leave to appeal is granted to the Supreme Court of Appeal;
2.	Costs of this application to be costs in the appeal.

_____________________
Judge C Pretorius

Case number				: 39219/2014

Appeal for leave to appeal
heard on				: 6 August 2015

For the Applicant			: Adv. A Sholto-Douglas/Adv Cassim
Instructed by				: STATE ATTORNEY

For the Respondent			: Adv. PA Swanepoel
Instructed by		: EDWARD NATHAN SONNENBERGS 
		  INC 

Date of Judgment			: