{"issue_text":"Whether the Commissioner General was correctly cited as respondent or whether the Zimbabwe Revenue Authority should have been cited","issue_type":"procedural","dispositive":"yes","related_facts":"Citation of parties in the application"}
{"issue_text":"Whether the applicant was obliged to collect Value Added Tax on the goods sold to the foreign resident","issue_type":"law","dispositive":"yes","related_facts":"Nature of export transaction and compliance with VAT Act"}
{"issue_text":"Whether the respondent is estopped from demanding VAT due to past conduct of its employees","issue_type":"law","dispositive":"no","related_facts":"Past practice of accepting zero-rating without objection"}
{"issue_text":"Whether the applicant has a claim for damages for negligent misrepresentation","issue_type":"law","dispositive":"no","related_facts":"New cause of action raised in heads of argument"}
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background
Facts of the Case
Background
The applicant, a manufacturer, exported goods and did not charge Value Added Tax, believing exports were zero-rated. The respondent conducted an audit, determined the exports were not compliant with the zero-rating provisions, and garnished the applicant's bank account for $2,184,861,227-71. The applicant sought a refund, arguing the goods were exported and zero-rated.
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