Herbal Holiday Resorts (Private) Limited vs Commissioner General of Inland Revenue – CA TAX 07/2017-2020

In Herbal Holiday Resorts (Private) Limited v. Commissioner General of Inland Revenue, the court addressed whether a medical institution must be registered under the Ayurveda Act, No. 13 of 1961, as amended, to qualify for a Value Added Tax (VAT) exemption under the Value Added Tax Act, No. 14 of 2002. It was held that registration under the Ayurveda Act is not a prerequisite for the VAT exemption on healthcare services as provided in item (xii) of Part II of the First Schedule to the VAT Act. The decision reaffirmed that fiscal statutes cannot have additional requirements implied into them unless expressly stated, in line with established principles of statutory interpretation. The ruling clarified that eligibility for the exemption must be assessed according to the explicit language of t