Lanka Marine Services (Private) Limited v. The Commissioner General of Inland Revenue – CA TAX/0004/2009-2009

In the case between Lanka Marine Services (Private) Limited and the Commissioner General of Inland Revenue, the court addressed whether supplies of bunker fuel by Lanka Marine Services (Private) Limited to foreign ships may be lawfully classified as “exports” under the Inland Revenue Act, No. 38 of 2000, thereby entitling the Appellant to a concessionary tax rate or exemption pursuant to Sections 47 and 15(j). It was determined that such supplies do not constitute “exports” under the Inland Revenue Act, as the sales did not demonstrably involve goods leaving Sri Lankan territory for a foreign destination, nor was sufficient documentation provided to establish these as exports. The principle reaffirmed is that for the purpose of tax benefits under the Inland Revenue regime, “export” require