Raiply Malawi Limited vs. Commissioner General of the Malawi Revenue Authority

Abstract

The judgment addresses the legal dispute regarding the calculation of export allowances under Malawi's Taxation and Export Incentives Acts. The court emphasizes that statutory provisions must be interpreted according to their plain and unambiguous meaning, rejecting any conflicting practices or representations that are not supported by law. The court clarifies the roles of the Malawi Revenue Authority and the statutory bodies responsible for granting allowances, affirming that the authority to determine and implement export allowances rests with the designated statutory bodies, not the Revenue Authority. The court dismisses the appeal, stating that estoppel does not apply where statutory interpretation is involved, and reinforces that legal correctness must prevail over reliance on past practice or representations. Costs are awarded to the respondent.