V. A. Muttiah vs The Commissioner General of Inland Revenue – CA TAX/0001/2022-2022

In the case between V. A. Muttiah (partner of “A. Valentine Trading Co.”) and The Commissioner General of Inland Revenue, the court addressed the issue of whether income derived from renting warehouse premises qualified the appellant for a 10% concessionary tax rate under item 31 of the Fifth Schedule of the Inland Revenue Act, and/or under section 59B, by determining if such income amounted to “operating and maintaining facilities for storage” as an “undertaking” or constituted mere rental income. It was held that the appellant’s activities were limited to earning rental income and did not meet the statutory definition of a business undertaking required for the concession. This judgment reaffirmed the legal principle that entitlement to statutory tax relief mandates clear compliance with