The Commissioner General of Inland Revenue vs Stafford Motor Company (Private) Limited – SC APPEAL 120/2021-2025

In the case between Commissioner General of Inland Revenue and Stafford Motor Company (Private) Limited, the court addressed whether the tax assessment issued under Section 163 of the Inland Revenue Act No. 10 of 2006 was made within the prescribed statutory time, and whether Nation Building Tax (NBT) paid at the point of importation was deductible under Section 26(1)(l)(iii) of the same Act. It was held that the assessment was issued within the allowable two-year period as calculated by applying Section 14(a) of the Interpretation Ordinance and that the taxpayer was not entitled to deduct NBT paid upon importation. The court further determined that the time limit imposed on the Tax Appeals Commission by Section 10 of the TAC Act is directory, not mandatory, and the Commission’s determinat