APL LANKA (PRIVATE) LIMITED vs THE COMMISSIONER GENERAL OF INLAND REVENUE – CA Tax 29/2022-2025

This case involves an appeal by APL Lanka (Private) Limited (Appellant) against a determination by the Tax Appeals Commission (TAC), which affirmed an assessment by the Commissioner General of Inland Revenue (Respondent). The core legal issues revolved around whether the Appellant’s income, specifically ‘transshipment agency fees,’ qualified for tax exemption under Section 13(ddd) of the Inland Revenue Act (IRA) as non-commission income, whether the Appellant was entitled to concessionary tax rates under Section 59B of the IRA, and whether a sum of Rs. 46,500,174/= constituted undeclared income or a reimbursement expense. The TAC had concluded that the Appellant’s income was solely commission-based, that it was an associate/subsidiary company, and that the disputed amount was undeclared in