Fonterra Brands Lanka (Private) Limited vs The Commissioner General, Department of Inland Revenue and others – SC APPEAL 187/2014-2025

In the matter of Fonterra Brands Lanka (Private) Limited vs. The Commissioner General, Department of Inland Revenue, and others, the court addressed the validity of income tax assessments issued beyond statutory time limits, the definition of an ‘assessment,’ and the applicability of writ jurisdiction. It was held that an assessment is only complete upon communication to the taxpayer via a notice served within the statutory period, and time limitations are jurisdictional. Consequently, an assessment served after the expiry of the prescribed period is a nullity. The court further determined that writ jurisdiction is available to challenge the legality of an administrative act, even if statutory appeals exist, and that the appellant was not estopped from raising a time-bar objection which ha