Lanka Marine Services (Private) Limited v. The Commissioner General of Inland Revenue – CA TAX/0013/2015-2021

In the case between Lanka Marine Services (Private) Limited and The Commissioner General of Inland Revenue, the court addressed whether the Tax Appeals Commission’s VAT ruling was procedurally and substantively lawful, focusing on the interpretation of “export” under the VAT Act and the applicability of statutory time-bars to assessments and appeals. It was held that timelines set by Section 10 of the Tax Appeals Commission Act are directory rather than mandatory, the supply of bunker fuel to ships for foreign travel does not constitute an “export” under the VAT Act for zero-rated status, and that assessments for periods prior to November 2004 were not time-barred, given the application of specific override provisions. The judgment reaffirmed principles of strict statutory interpretation i