Lutzkie vs SARS – reconsider your stance, but also be able to justify it too

A summary of the Lutzkie v Commissioner for the South African Revenue Service (1135/2023) [2026] ZASCA 11 (6 February 2026) in which the court had to decide whether an amount received by a taxpayer was taxable income or a loan repayment (thus making it capital in nature and not taxable).