CEI Plastics Ltd vs Commissioner General of Inland Revenue – sllr 2019 volume 2 page 501

The case between CEI Plastics Ltd (Appellant) and Commissioner General of Inland Revenue (Respondent) addressed the issues of whether the assessment for the year 2007/2008 was time barred under section 163(5)(a), the deductibility of an interest expense of Rs. 167,075,212 incurred from share trading under section 25 or alternatively under section 32(5)(a) of the Act, and the proper classification of the Appellant’s activities as either a single business or two distinct businesses for tax purposes. It was held that the time bar objection was waived as it was not raised at the earliest opportunity, the share trading activities constituted a separate business under section 3(a) of the Act, and that the pertinent interest expense was not deductible under either section 25 or section 32(5)(a).