Commissioner General of Inland Revenue v Aitken Spence Travels (Pvt.) Ltd. – CA TAX/0031/2019-2022

In the case between Commissioner General of Inland Revenue, Department of Inland Revenue, Sri Lanka and Aitken Spence Travels (Pvt) Ltd., the court addressed whether the Tax Appeals Commission (TAC) erred in its interpretation of Section 13 (dddd) of the Inland Revenue (Amendment) Act, No. 9 of 2009, specifically whether Aitken Spence Travels (ASTL) rendered services to foreign tour operators (FTOs) outside Sri Lanka or to foreign tourists within Sri Lanka, affecting eligibility for income tax exemption. The court held that ASTL provided services to persons outside Sri Lanka, namely the FTOs, and confirmed that income received from such FTOs qualified for exemption under Section 13 (dddd). This reaffirmed the principle that for income tax exemption purposes, the contractual counterparty an