McLarens Lubricants Ltd vs Commissioner General of Inland Revenue – CA TAX/0053/2019-2022

In the case between McLarens Lubricants Ltd. (Appellant) and the Commissioner General of Inland Revenue (Respondent), the court addressed whether the sale of lubricants (bunker fuel) to non-resident ships out of bonded warehouses constitutes “qualified exports” under Sections 42 and 51 of the Inland Revenue Act, No. 10 of 2006 (as amended), thereby entitling the appellant to concessionary tax rates or exemptions. The court held that such sales do not qualify as exports within the meaning of the Act, in the absence of evidence demonstrating supply to ships bound for foreign destinations. This reaffirmed the principle that strict proof is required to establish tax exemption claims, particularly in fiscal matters, referencing statutory construction approaches and relevant precedent, including