S. U. B. Karalliyadde, J.

This case has been transmitted to this Court in terms of Section 170 of the Inland Revenue Act, No.10 of 2006 seeking for an opinion to the questions of law mentioned in the "case stated" formulated the Tax Appeals Commission established under the Tax Appeals Commission Act, No.23 of 2011.

The Ceylinco Leasing Corporation Ltd, the Appellant is a limited liability Company incorporated in Sri Lanka engaged in the business of leasing, hire purchase and earning rental income. The Appellant submitted its return of income for the year of assessment 2012/2013 and by letter date 23.11.2015, [at page 338 L of the appeal brief.] the Deputy Commissioner of the Department of Inland Revenue informed the Appellant that the return of income was rejected for the reason that the Appellant remains the owner of the Staana Vaasi Portfolio despite CLC Asset Management Ltd enjoy the economic benefits accrued on the lease portfolio due to a Participatory Agreement and considering the fact that the Appellant has declared lease rentals arising from Staana Vaasi Portfolio in the VAT Return.

Thereafter, the Notice of Assessment dated 27.11.2015, [at page 338 J of the appeal brief.] was