Confab Steel (Private) Limited vs Commissioner General of Inland Revenue – CA TAX/02/2012-2022

In the case between Confab Steel (Private) Limited (Appellant) and the Commissioner General of Inland Revenue (Respondent), the court addressed the issue of whether interest income earned by the Appellant during the relevant year of assessment was exempt from income tax under Clause 10(1) of its agreement with the Board of Investment (BOI), pursuant to Section 17 of the BOI Act. It was held that interest income derived from deposits did not qualify for exemption under the BOI agreement and must be treated as a separate source of income subject to tax. The principle reaffirmed is that tax exemptions for BOI-enterprises are confined to profits generated directly “in connection with and/or in relation to” the core business, and not to passive investment income such as bank interest, unless sp