Zimbabwe Revenue Authority v Stanbic Bank Zimbabwe Limited

Judgment No. SC 13/19

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Case Details

Court

Supreme Court

Date

22 February 2019

Citation

Judgment No. SC 13/19

Neutral Citation

[2019] ZWSC 13

Judgment No.

SC 13/19

Outcome

unknown

Case Type

Appeal

Bench

Presiding

MAVANGIRA JA

Full Bench

GUVAVA JAMAVANGIRA JAZIYAMBI AJA

Areas of Law

Tax LawStatutory Interpretation

Keywords

Income Tax ActCapital vs Revenue ExpenditureSpecial Initial AllowanceComputer SoftwareFourth Schedule

Key Issues

{"issue_text":"Whether the Special Court for Income Tax Appeals erred in granting a special initial allowance for computer software expenditure incurred in 2009, when such allowance was not provided for in the Income Tax Act as it existed at that time.","issue_type":"law","dispositive":"yes","related_facts":"The expenditure was incurred in 2009; the Fourth Schedule was amended in 2014 to include computer software."}
{"issue_text":"Whether a court can grant relief not sought or argued by the parties, particularly a relief that is inconsistent with the party's stated position.","issue_type":"procedural","dispositive":"yes","related_facts":"The respondent argued the expenditure was revenue in nature but the court granted a capital allowance."}

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background

Facts of the Case

Background

The appellant (ZIMRA) issued amended tax assessments to the respondent (Stanbic Bank) for 2009-2011, disallowing deductions for computer software expenditure and treating a written-off loan and certain dividends as taxable income. The respondent objected and appealed. The Special Court of Income Tax Appeals found the software expenditure was capital in nature but ordered ZIMRA to grant a special initial allowance for it. ZIMRA appealed, arguing such an allowance was not available under the law in 2009.

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