Lanka Marine Services (Private) Limited v. The Commissioner General of Inland Revenue – CA TAX/0020/2013-2021

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 the appellant to foreign vessels constitute “exports” eligible for concessionary tax rates under the Inland Revenue Act, No. 10 of 2006. It was determined that, for such supplies to be considered exports under Sections 42 or 52 of the Act, the goods must be shown to be carried for a foreign destination, and mere delivery to ships within Sri Lankan waters does not suffice. The court reaffirmed the principle that concessionary tax treatment is contingent upon demonstrating a genuine export characterized by a clear foreign destination. The decision analyzed definitions in domestic legislation and relevant foreign jurisprudence, conc