APL LANKA (PRIVATE) LIMITED vs THE COMMISSIONER GENERAL OF INLAND REVENUE – CA Tax 24/2022-2025

In the matter of APL Lanka (Pvt) Limited and the Commissioner General of Inland Revenue, the court addressed the appellant’s claims for tax exemption on ‘Transshipment Agency Fees’ under Section 13(ddd) and concessionary tax rates under Section 59B of the Inland Revenue Act, alongside the classification of undeclared income. It was held that the appellant’s income was commission-based, rendering it ineligible for exemption, and its status as an associate company precluded concessionary rates. The court also affirmed that the disputed amount was undeclared income due to insufficient proof of reimbursement. This decision reaffirmed the principle that the burden of proof rests with the taxpayer to substantiate claims for exemptions and classifications.

ANNALINGAM PREMASHANKER, J. delivered