### 📉 Tax Justice Alert: New Bill Proposes "Evidentiary Lock-out"

A critical analysis of the proposed Inland Revenue (Amendment) Bill of 2026 reveals a shift from discretionary document oversight to a hard statutory bar, potentially impacting the ICT/BPM and broader corporate sectors. • Core Legislative Change Section 122(8A) introduces a "permanent evidentiary lock-out." For info requested after April 1, 2026, failure to submit documents within fixed windows—6 months (local) and 9 months (foreign)—renders evidence legally inadmissible in future judicial or Tax Appeals Commission (TAC) hearings. • The "14-Day" Compliance Risk While 6/9-month windows exist, they do not extend original deadlines. If an officer sets a 14-day limit for complex reconciliations and the taxpayer misses it, they face a "statutory guillotine," even if they hold proof that an assessment is erroneous. • Global Comparison & Outlier Status Unlike Sri Lanka’s proposed "hard bar," global peers use "Safety Valve" models: India: Allows evidence if "sufficient cause" for delay is shown. UK: Prioritizes "fairness and justice" over procedural rigidity. Australia: Focuses on whether late evidence causes "undue prejudice." • Key Concerns for Businesses Administrative Convenience vs. Natural Justice: Critics argue the bill punishes all taxpayers for the delays of a few. Third-party Delays: Obtaining foreign certificates or historical data often exceeds the proposed windows. Constitutional Risk: The bill may face Supreme Court challenges for violating Article 12(1) (equal protection).