Senvec Lanka (Pvt) Limited vs Commissioner General of Inland Revenue – CA/TA 11/2010-2024

In the case between Senvec Lanka (Pvt) Limited and the Commissioner General of Inland Revenue, Department of Inland Revenue, Sri Lanka, the court addressed the issue of whether the appellant acted as an agent or a principal under the Sole Agency Agreement with Hattori Seisakusho Co. Ltd, Japan, and whether the commission received was for services consumed outside Sri Lanka, thereby qualifying for zero-rating under the VAT Act. The court held that the appellant was engaged solely as an agent providing agency services to a foreign principal, and the services in question were indeed for consumption outside Sri Lanka. This holding reaffirmed the principle that the interpretation of agency agreements must accurately reflect the nature and purpose of the transaction, particularly when determinin