The Case of Ceylon Cold Stores PLC vs. The Commissioner General of Inland Revenue – CA TAX/0024/2019-2022

In the case between the Commissioner General of Inland Revenue, Department of Inland Revenue (Appellant) and Ceylon Cold Stores PLC (Respondent), the court addressed whether the Tax Appeals Commission (TAC) erred in (1) determining that the cessation of glass bottles and crates was not a “disposal” under Section 25(7)(d) of the Inland Revenue Act, No. 10 of 2006, (2) finding that forfeited deposits were capital receipts not liable to income tax, and (3) whether the tax assessment was time-barred. It was held that the appellate court may consider an additional question of law—specifically, whether the tax assessment was time-barred—where the issue is material and was already raised before and determined by the TAC, even if it was not part of the original stated case. The principle reaffirme