Assignment 2 Semester 2 2025
Unique #
Due Date: 18 September 2025
Detailed solutions, explanations, workings
and references.
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, QUESTION 1
Gross Income Analysis for Moses Patel (Pty) Ltd (10 marks)
The amount of R95 000 received by Moses Patel (Pty) Ltd (MP) must be tested
against section 1 of the Income Tax Act 58 of 1962, which defines gross income.
Each component is considered below:
1. Resident
MP is a South African incorporated company, thus a resident as defined in section 1
(3.3). Residents are taxed on receipts and accruals from anywhere in the world
(Cohen v CIR 13 SATC 362). Since MP operates in KwaZulu-Natal and received the
payment locally, it falls within the scope for gross income.
2. Total Amount (in cash or otherwise)
The R95 000 is a measurable amount of money. According to Lategan v CIR 2
SATC 16, ―amount‖ includes money and every form of property with money value.
The value is objective and ascertainable on the date received (CIR v Butcher Bros
(Pty) Ltd 13 SATC 21). Thus, the R95 000 qualifies as a ―total amount‖ (3.4).
3. Received by or Accrued to or in Favour of
The amount was received on 27 September 2024. Under CIR v Delfos 6 SATC 92,
an amount is taxed at the earlier of receipt or accrual. The payment was received
upfront for services already rendered, so it is includible for the 2025 year of
assessment.
4. Year or Period of Assessment
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