Central Finance Company PLC vs The Commissioner General of Inland Revenue – CA TAX/0008/2018-2023

In the case between Central Finance Company PLC and the Commissioner General of Inland Revenue, Department of Inland Revenue, the court addressed whether the tax assessment for the year 2009/2010 was time barred under section 163(5) of the Inland Revenue Act, and whether the extended deadline introduced by the Inland Revenue (Amendment) Act, No. 22 of 2011 applied retrospectively. It was held that the assessment was made beyond the statutory time limit and that the amendment extending the deadline operated only prospectively, not applying to the relevant year. The court annulled the determination of the Tax Appeals Commission, reaffirming the statutory interpretation principle that amendments affecting limitation periods should not be construed as retrospective absent explicit legislative