Shanmuganayagam and Another v. The Commissioner General of Inland Revenues – sllr 1991 volume 1 page 390

In the case between Mrs. Shanmuganayagam and partners (Flower Textiles) and the Commissioner–General of Inland Revenue, the court addressed the issue of whether Flower Textiles qualified as a “new industrial undertaking” eligible for income tax exemption under Section 6 of the Inland Revenue Act No. 4 of 1963. It was held that the business did not meet the criteria for exemption, as it was determined that the venture constituted a continuation and restructuring of an already existing saree printing business and not an entirely new undertaking. The findings established that the business, though expanded and relocated, retained essential features and assets of the original operation, such as raw material quotas and personnel. This reaffirmed the principle that tax exemptions under the releva