Malwatte Valley Plantations PLC v. The Commissioner General of Inland Revenue – CA TAX/06/2017-2021

In the case between Malwatte Valley Plantations PLC and The Commissioner General of Inland Revenue, the court addressed the issue of the validity and substance of VAT assessments issued on the sale of live rubber trees. It was held that key VAT assessments were not time-barred, the sales were taxable activities, and that live trees did not constitute “unprocessed agricultural products” exempt from VAT. The findings established that while the assessments were mostly procedurally sound, the valuation method, specifically the arbitrary 40% uplift, lacked lawful justification and required adjustment. The decision reaffirmed that VAT exemptions for “unprocessed agricultural products” do not extend to the sale of live trees by plantation companies, and that assessments must rest on lawful and ev