D.M.S. Fernando and Another v. Mohideen Ismail – sllr 1982 volume 1 page 222

In the case between D. M. S. Fernando and Another (officers of the Inland Revenue Department of Sri Lanka) and Mohideen Ismail (the taxpayer), the court addressed whether, under the Inland Revenue Act (particularly Section 93(2)(b) as amended by Inland Revenue Amendment Law No. 30 of 1978), the failure by an assessor to provide written reasons for the non-acceptance of a tax return renders a subsequent notice of assessment null and void, or whether such a requirement is merely procedural. It was held that the communication of reasons for rejecting a return is a substantive requirement, and non-compliance can invalidate the assessment, reaffirming the principle that statutory duties must generally be complied with to maintain the validity of administrative actions. This decision relied on s