Richard Pieris Rubber Compounds Ltd. Vs. The Commissioner General of Inland Revenue – CA TAX 0015/2017-2021

In the case between Richard Pieris Rubber Compounds Ltd. (Appellant) and The Commissioner General of Inland Revenue (Respondent), the court addressed issues concerning the validity of a Value Added Tax (VAT) assessment, interpretation of statutory provisions regarding the open market value for related-party transactions, and procedural fairness in the assessment process. It was determined that the assessment for VAT (Assessment No. 7070597) was not time-barred under Section 33(1) of the VAT Act No. 14 of 2002. The court further established that transactions between two VAT-registered persons are governed by Section 5(1)(a), not Section 5(2), of the VAT Act, rendering the Appellant’s arguments on statutory exclusivity unsound. The rationale that no state revenue loss arises from related-par