ICICI Bank Limited vs The Commissioner General of Inland Revenue – CA TAX NO: 28/2013-2015

In the case of ICICI Bank Limited (Appellant) v. The Commissioner General of Inland Revenue (Respondent), the Court addressed whether the Appellant engaged in more than one trade or business under section 106(11) of the Inland Revenue Act No. 10 of 2006, and whether borrowing costs related to tax-exempt Sri Lanka Development Bonds (SLDBs) could be deducted. It was held that investment in SLDBs constituted a separate source of income and business for tax purposes. Expenses incurred in generating tax-exempt income could not be deducted under sections 25 or 32(5) of the Inland Revenue Act. The Commissioner General’s pro rata allocation method for attributing expenses was upheld due to the failure to maintain separate accounts. All legal questions were resolved in favor of the Respondent, conf