Unilever Sri Lanka Limited v. Commissioner General of Inland Revenue – CA TAX/0019/2018-2022

In the case between Unilever Sri Lanka Limited (USL) and the Commissioner General of Inland Revenue, the court addressed whether the Tax Appeals Commission (TAC) determination was time barred, the applicability of statutory time limits, the classification of USL as a “manufacturer” under the VAT Act despite outsourcing production, and the propriety of VAT assessments and penalties imposed. The appellate inquiry centered on statutory interpretation, the substance of commercial manufacturing arrangements, and the legislative intent behind time limit provisions, including recent amendments. It was held that the TAC’s decision was not time barred, USL qualified as the manufacturer due to its control and contractual relations, and the assessments made by the TAC were valid, affirming the Commis