D. Samson and & Sons (Pvt) Ltd vs Commissioner General of Inland Revenue – CA TAX/0009/2014-2023

In the case between D. Samson & Sons (Pvt) Ltd (Appellant) and the Commissioner General of Inland Revenue, Department of Inland Revenue (Respondent), the court addressed whether the appellant’s acquisition of shares in Kelani Valley Canneries Ltd qualified for an income tax exemption under Section 21 E of the Inland Revenue Act, and if so, under which sub-clause such an exemption may apply. It was held that the appellant did not satisfy the statutory requirements for ownership or management rights, nor did it meet the 51% shareholding threshold as mandated by the relevant legal provisions. This decision reaffirmed the principle that statutory exemptions for tax relief must be interpreted strictly in line with legislative intent, and substantive compliance with shareholding and management r