Issues before the court:
1. Whether ZIMRA could lawfully issue replacement notices of revised tax assessments that were previously invalidated by a Supreme Court ruling (SC 148/21).
2. Whether ZIMRA’s replacement notices were valid under the Income Tax Act after the previous assessments were declared a nullity.
Court decision:
1. The Supreme Court dismissed ZIMRA’s appeal with costs. The Court upheld the High Court’s ruling that ZIMRA could not issue replacement notices of assessment after the prior assessments were nullified.
2. The Court emphasized the principle of finality in litigation and ruled that the replacement notices were invalid