Sri Lanka Insurance Corporation Limited vs. The Commissioner General of Inland Revenue – CA TAX/0019/2019-2022

In the case between Sri Lanka Insurance Corporation Limited (Appellant) and the Commissioner General of Inland Revenue (Respondent), the court addressed whether statutory time-bar provisions under section 10 of the Tax Appeals Commission Act are mandatory or directory, and whether the Appellant’s life insurance business, including its investment income, constitutes the “supply of financial services” subject to VAT under sections 25A and 25F of the VAT Act. The findings established that, although the Tax Appeals Commission’s (TAC) determination on the time-bar issue was to the Respondent’s advantage, the remaining VAT liability issues favored the Appellant. It was determined that life insurance contracts, including their investment components, fall within a statutory exemption from VAT even