WNS Global Services (Private) Limited vs Commissioner General of Inland Revenue – CA/TAX/0043/2023-2024

In the case between WNS Global Services (Private) Limited and the Commissioner General of Inland Revenue, the court addressed the issue of the appellant’s eligibility for an income tax exemption under Section 13(ddd) of the Inland Revenue Act in the context of its BOI agreement. It was held that the appellant did not qualify for the full tax exemption claimed under the Act and was instead subject to concessionary tax rates as stipulated in the BOI agreement. The reasoning reaffirmed the principle that statutory provisions governing tax exemptions must be interpreted in light of their specific language and the prevailing contractual arrangements. Reliance was placed on statutory interpretation, case law, and procedural requirements regarding the acknowledgment of appeals. The court emphasiz