CEYSPENCE (PVT) LTD vs. COMMISSIONER GENERAL OF INLAND REVENUE – sllr 2015 volume 1 page 170

In the case between CEYSPENCE (PVT) LTD (under liquidation) and the COMMISSIONER GENERAL OF INLAND REVENUE, the court addressed the issue of whether proceeds from the sale of the appellant’s principal asset—a ship and its associated bunker fuel—were covered by a tax exemption granted under BOI Agreement No. 170, or whether such proceeds constituted a separate taxable business transaction under the Inland Revenue Act No. 10 of 2006. It was held that the sale of the ship did not fall within the tax-exempt operations but constituted a distinct taxable transaction, reaffirming the principle that specific capital asset disposals are treated separately from exempt business revenues where statutory provisions so mandate. The decision relied on the interpretation of the BOI Agreement and relevant