Commissioner General of Inland Revenue (CGIR) vs. Fonterra Brands Lanka (Pvt) Ltd – CA/TAX/47/2019-2024

In the case between the Commissioner General of Inland Revenue, Department of Inland Revenue, and Fonterra Brands Lanka (Pvt) Ltd, the court addressed the issue of whether the Tax Appeal Commission erred in law by denying the deduction of royalty payments under Section 32 of the Inland Revenue Act as amended. It was held that the disallowance of the deduction for royalty payments was legally sound, reaffirming the principle that claims for tax deductions must strictly comply with statutory requirements. Reliance was placed on the interpretation and application of Sections 25, 32, and 82 of the Inland Revenue Act, which emphasize the need for clear demonstration that claimed payments satisfy all statutory criteria for deductibility. This decision reinforces that deductions not meeting legis