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Telkom SA SOC Limited v The Commissioner for the South African Revenue Service(Case no 239/19) [2020] ZASCA 19 (

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Telkom SA SOC Limited v The Commissioner for the South African Revenue Service(Case no 239/19) [2020] ZASCA 19 (

25th March 2020

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Click here to read the full judgment on Saflii

Income Tax Act 58 of 1962 (the Act)–s24I–losses or gains caused by foreign exchange fluctuations –proviso tos24I(10)–not a self-standing provision for deduction of a commercial loss unconnected to foreign exchange currency differences –Natal Joint Municipal Pension Fund v Endumeni Municipality 2012 (4) SA 593 (SCA) –unitary but not uniform exercise in purposive interpretation of contracts and statutes–application of contra fiscum rule and presumption that statute law not unjust, inequitable or unreasonable.

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