Seylan Bank PLC v. The Commissioner General of Inland Revenue – SC APPEAL NO. 46/2016-2021

In the case between Seylan Bank PLC and the Commissioner General of Inland Revenue along with the Department of Inland Revenue, the court addressed whether an income tax assessment for the year of assessment 2007/2008, issued on 26th March 2010, had become time barred under section 163(5)(a) of the Inland Revenue Act, as amended by Act No. 19 of 2009. It was determined that the amendments relating to filing extensions and assessment periods had only prospective effect, and therefore, could not be applied to tax returns already filed prior to the amending law’s certification. The holding established that the assessment in question was time barred, reaffirming the statutory principle that procedural amendments expressly stated to be prospective cannot apply retroactively to concluded assessm