Delta Beverages (the Applicant) challenged tax assessments issued by the Zimbabwe Revenue Authority (the Respondent) for the period March 2019 to October 2021. The Respondent had issued assessments requiring payment of tax obligations in foreign currency, and threatened to garnish the Applicant's bank accounts as a collection measure. The Applicant initially sought a provisional order interdicting the Respondent from instituting collection measures and garnishing accounts, and sought a declaration that the Respondent should complete the audit process taking into account all ZWL (local currency) transactions and payments, and thereafter issue final assessments. The matter was initially filed as an urgent application but was later removed from the urgent roll by consent on 21 June 2024 and referred to the opposed roll. The same issues regarding the validity of these tax assessments had previously been litigated in HH577/23 (where the High Court dismissed the Applicant's objections to the assessments) and subsequently in SC62/24 (where the Supreme Court dismissed the Applicant's appeal and confirmed the validity of the assessments requiring payment in foreign currency).