Tholo Energies vs SARS – tick all the boxes or forfeit admission

A summary of the Tholo Energy Services CC v Commissioner for the South African Revenue Service (CCT 252/24) [2026] ZACC 1 (16 January 2026) case in which the Constitutional Court had to decide whether to uphold the Supreme Court of Appeal’s decision to disallow the taxpayer’s claim for a refund on levies paid.