The Supreme Court of Appeal (SCA) recently heard four cases in quick succession, where the taxpayers sought to engage the High Court’s jurisdiction (HC) directly to challenge SARS’ actions in the making of assessments. The taxpayers in these cases were United Manganese of Kalahari (Pty) Ltd (UMK), Rappa Resources (Pty) Ltd (Rappa), ABSA Bank Limited (ABSA) and Richards Bay Coal Terminal (Pty) Ltd (RBCT).