Seylan Bank PLC vs. Commissioner General of Inland Revenue – sllr 2021 volume 1 page 054

In the case between Seylan Bank PLC and the Commissioner General of Inland Revenue, the court addressed whether the tax assessment for the year 2007/2008, issued on 26.03.2010, was time barred under section 163(5)(a) of the Inland Revenue Act as amended by Act No. 19 of 2009. The court held that the relevant amendments to the Inland Revenue Act were to operate prospectively, not retrospectively, and thus the assessment in question was time barred. This decision reaffirmed the principle that, unless explicitly provided, statutory amendments—especially those involving procedural rights—operate prospectively. The holding relied on statutory interpretation, the express provisions within the Inland Revenue Act, and established legal principles governing retrospective operation of laws. The ruli