Ogilvy Action (Pvt) Ltd. vs. The Commissioner General of Inland Revenue – CA TAX/0016/2013-2021

The case between Ogilvy Action (Pvt) Ltd (Appellant) and The Commissioner General of Inland Revenue (Respondent) addressed whether vehicle-related expenses, claimed as travelling costs and rentals by the Appellant in the 2007/2008 assessment year, are deductible under Section 25(1)(k) of the Inland Revenue Act, No. 10 of 2006, or prohibited by Section 26(2) of the same Act. It was held that specific deduction provisions for actual travelling expenses under Section 25(1)(k) are not overridden by general prohibitions contained in Section 26(2) unless the Act expressly provides otherwise. The decision reaffirmed the principle that specific legislative permission for deductions prevails over general prohibitions in tax statutes. This conclusion was grounded in established principles of statuto