Judgment No. CCZ 7/2014 4 Const. Application No. 41/2014 simply expressed a view to the respondent that it would be prudent to await the outcome of the appeal. Concurrently with the review of the applicant’s value added tax affairs, the respondent carried out an assessment of the applicant’s income tax liability. The respondent assessed the applicant’s income tax liability to be an amount of US$2 066 652.84 including penalties and interest. On 3 June 2014 it sent to the applicant, a complete tax computation for both value added tax and income tax. The respondent threatened to put in place measures to recover the taxes in terms of s 48 of VAT Act should the applicant fail to pay the money voluntarily. It later appointed three of the applicant’s bankers and Sakunda Energy as agents for the payment of the value added tax assessed to be due and payable. On 5 June 2014, the applicant filed an application with the Constitutional Court in terms of s 85(1) of the Constitution, challenging the validity of ss 36of the VAT Act and 69(1) of the Income Tax Act. The allegation is that the legislative provisions violated the applicant’s fundamental right of access to the courts enshrined in s 69(3) and the right to administrative justice guaranteed under s 68(1) of the Constitution. The applicant sought, as the relief, a final order declaring ss 36 of the VAT Act and 69(1) of the Income Tax Act to be ultra vires ss 68(1) and 69(3) of the Constitution and therefore void. Simultaneously with the filing of the main application, the applicant filed the urgent chamber application seeking an order that the main application be heard on an urgent basis. It also sought interim relief in the following terms: