Unilever Sri Lanka Limited Vs. Commissioner General of Inland Revenue – CA TAX/0015/2013-2022

In the case between Unilever Sri Lanka Limited and the Commissioner General of Inland Revenue, the court addressed the issue of whether Unilever Sri Lanka Limited should be regarded as the manufacturer under the Value Added Tax Act in light of its contractual arrangements with unrelated manufacturers RMCC and PSL. It was determined that the specification of requirements, provision of moulds, exercise of overall control, and maintenance of trademark standards by Unilever amounted to an effective manufacturing activity, rendering the Appellant liable for VAT as a manufacturer. The decision reaffirmed that the legal definition of “manufacture” under section 83 of the VAT Act requires effective managerial control and supervision, rather than direct engagement in the production process. The sta