Seylan Bank PLC v. The Commissioner General of Inland Revenue – CA TAX 23/2013-2013

In the case between Seylan Bank PLC and The Commissioner General of Inland Revenue, Department of Inland Revenue, the court addressed whether a tax assessment for the financial year 2007/2008, dated 26.03.2010 and issued against Seylan Bank PLC, was time-barred under Section 163(5)(a) of the Inland Revenue Act, in light of subsequent legislative amendments. The central holding determined that the amended provision—which extended the assessment period—applies to returns filed before the amendment’s commencement, as the change was procedural and not substantive. Existing legal principles regarding the retrospective operation of procedural statutes were reaffirmed, emphasizing that legislative extensions governing procedural timelines for assessments operate with immediate effect unless other