Commissioner General of Inland Revenue vs. Osprey Clothing (Private) Limited – CA TAX/0019/2015-2024

In the case between the Commissioner General of Inland Revenue, Department of Inland Revenue (Appellant), and Osprey Clothing (Private) Limited (Respondent), the court addressed whether a tax exemption originally granted under the initial agreement extended to encompass additional business activities introduced by a Supplementary Agreement, including a washing plant, finishing section, and a bounded warehouse. It was held that the supplementary agreement did not alter the material tax exemption clause, and that the expanded business activities remained within the scope of the granted tax relief. The court reaffirmed the principle that, where the terms of a statutory agreement remain unaltered in respect of a tax concession, the benefit of the concession continues to apply except where expr