SARS disputes, done right the first time.
Deadlines you can rely on, validity traps you can avoid, and grounds you can defend, with every citation verified against the source before you see it.
Business days, not calendar days.
The dispute clock runs in business days under the Tax Administration Act and the dispute-resolution rules. SilkeAI computes each deadline against the assessment date and flags what's coming up.
- Step 01Day 0Assessment or decision issued
The clock starts on the date of the assessment or decision under s 104 TAA and rule 7 of the dispute-resolution rules.
- Step 02Within 80 business daysLodge the objection
Objection must be delivered on the prescribed form, stating the grounds, together with supporting documents (rule 7).
- Step 03+ up to 30 business daysExtension on reasonable grounds
A senior SARS official may extend by up to 30 business days on reasonable grounds (s 104(4)); further extension only in exceptional circumstances and no later than three years (s 104(5)).
- Step 04Within 30 business days of receiptSARS notifies validity
SARS must notify whether the objection is valid; if invalid, the taxpayer has 20 business days to resubmit (rule 7(4)).
- Step 05Within 60 business daysSARS allows or disallows
SARS must notify the taxpayer of its decision to allow, allow in part, or disallow the objection (rule 9).
- Step 06Within 30 business days of disallowanceNote the appeal
Notice of appeal on the prescribed form (rule 10). ADR, Tax Board or Tax Court follows.
Statutory references: Tax Administration Act 28 of 2011, ss 103–107; rules promulgated under s 103 (GN 550 of 2014, as amended).
Why objections get bounced.
No grounds stated
Rule 7(2) requires the objection to specify the grounds of objection in detail. 'The assessment is wrong' is not grounds.
Wrong or missing form
PIT/CIT/VAT/PAYE disputes are lodged on the eFiling ADR forms; other taxes use ADR1/ADR2. Wrong form invalidates the objection.
Out of time, no condonation
Late objections without a request for extension (with grounds) are rejected under s 104(4)/(5).
Objecting to an unappealable decision
Certain decisions are excluded from objection and appeal. Objecting to them wastes the clock.
Same grounds as a prior disallowed objection
A second objection on substantively the same grounds is invalid.
Missing supporting documents
Rule 7(2)(b) requires the documents supporting the grounds; omission is a validity failure.
Drafted grounds of objection.
A labelled preview of how SilkeAI structures a draft Notice of Objection. Every citation is a link to the source; every quoted passage is verified against the source text.
Additional assessment for the 2024 year of assessment dated 12 March 2025, disallowing a trading-stock write-down of R1,842,650 claimed under s 22(1)(a) ITA.
The taxpayer is a wholesale distributor of consumer electronics. At year-end, obsolete SKUs were written down to net realisable value based on documented sell-through data over 24 months.
- Section 22(1)(a) requires trading stock to be valued at cost less any amount by which its value has been diminished, as the Commissioner may think just and reasonable. s 22(1)(a) ITA
- SARS's own approach to the just and reasonable diminution is set out in Interpretation Note 65, paragraph 4.2, which recognises reduced net realisable value as a permissible basis. IN 65 §4.2
- The write-down is supported by contemporaneous sell-through data (Annexure B) which is the type of evidence approved in ITC 1489, 53 SATC 99. ITC 1489
- The additional assessment fails to engage with the evidence supplied in the verification response of 4 February 2025 and, to that extent, is procedurally defective under s 96(2) TAA.
That the additional assessment be reduced to reinstate the R1,842,650 trading-stock write-down, and that any resulting understatement penalty imposed under Chapter 16 TAA be withdrawn. ss 222–224 TAA
The dispute lifecycle, end to end.
Extract issues, amounts, deadlines and the section SARS is relying on.
Time, form, grounds specificity and supporting documents, before you file.
Facts, grounds, law and relief, each grounds paragraph tied to a citation.
Sections, Interpretation Notes, rulings and case law, verified against the source.
Package for eFiling upload or as the ADR1/ADR2 attachment, with an audit trail.
Every citation is checked against the source before you see the answer. Closed SA corpus, point-in-time law, and refusal instead of guessing.
How verification works →SARS disputes are the flagship, but the same engine handles research, opinions and change alerts across the practice.
Practitioner workflows →SilkeAI is in development. Founding practitioners get in first.
Shape the roadmap, pilot the platform on real (anonymised) matters, and lock in founding-member benefits at launch.