IN THE COURT OF APPEAL OF THE DEMOCRATIC SOCIALIST REPUBLIC OF SRI LANKA In the matter of an appeal by way of a Stated Case under section 11A of the Tax Appeals Commission Act, No. 23 of 2011 as amended by Act, No. 29 of 2013.

Central Finance Company PLC, 84, Raja Veediya, Kandy.

Appellant Case No. CA/TAX/0008/2018 Tax Appeals Commission No. TAC/IT/007/2015 Vs.

The Commissioner General of Inland Revenue, Department of Inland Revenue, Sir Chittampalam A. Gardiner Mawatha, Colombo 02. Respondent Before : Dr. Ruwan Fernando J. &

M. Sampath K.B. Wijeratne J.

: Dr. Shivaji Felix with Nayantha Satharasinghe for the Appellant Sumathi Dharmawardena, P.C.. Additional Solicitor General with Amasara Gajadeera and Pramod Perera for the Respondent.

Argued on : 10.12.2011, 31.03.2022, 06.05.2022, 02.11.2022 & 04.05.2023 Written Submissions filed on : 03.01.2019 & 16.05.2023 (by the Appellant)

17.01.2019 & 12.05.2023 (by the Respondent)

Decided on : 19.05.2023 Dr. Ruwan Fernando, J.

Introduction [1] This is an appeal by way of a Case Stated against the determination of the Tax Appeals Commission dated 20.03.2018 confirming the determination made by the Commissioner-General of Inland Revenue on 05.12.2014,