This case arises from a dispute between the applicant and the Commissioner of the South African Revenue Service about the classification for customs duty purposes of certain goods imported into South Africa by the applicant.  As in all such matters, at the bottom of it is a question of money. [1]  If the classification contended for by the applicant is correct no duty is payable.  But if the Commissioner’s determination were to be upheld, the applicant will have to pay an amount of at least R547 214,34 by way of duty, additional VAT, interest and penalties.