Judgment No. CCZ 7/2014 3 Const. Application No. 41/2014 tax on the invoices, was liable to be paid to the fiscus regardless of the purpose for which transport services were supplied. On 7 February 2014, the respondent issued the applicant with an assessment of value added tax liability in an amount of US$1 619 161.32 including penalties and interest. According to the respondent, it was what the applicant and Sakunda Energy were doing in their business transactions as revealed by the examination of books of account, which produced evidence of tax evasion. The applicant was dissatisfied with the tax liability assessment arguing that it did not owe the whole amount of the value added tax assessed to be due and payable. On 27 February 2014, the applicant lodged a formal objection with the Commissioner against the correctness of the assessment in terms of s 32 of the VAT Act. The allegation was that the respondent had adopted a wrong method of assessing the applicant’s tax liability. The respondent was accused of having misunderstood the nature of the applicant’s business operations. Correspondence was exchanged on the matter between the parties between 14 and 17 March 2014. The Commissioner disallowed the objection in respect of the assessment of value added tax liability on 13 May 2014. The applicant noted an appeal to the Fiscal Appeal Court against the correctness of the assessment on 23 May 2014. On 27 May 2014, the Commissioner reminded the applicant of its continuing obligation to pay the amount of the tax assessed to be due and payable, notwithstanding the noting of the appeal to the Fiscal Appeal Court. On 30 May 2014, the applicant’s tax consultant