SINGAPORE CEMENT MANUFACTURING COMPANY (PRIVATE) LIMITED v COMPTROLLER OF INCOME TAX

Q: Which legislation does [2023] SGHC 57 consider?

The judgment refers to Income Tax Act (Cap 134). The statutes cited are listed in full on this page, each linking to its primary text.

[2023] SGHC 57 High Court (General Division) 10 March 2023 HC/TA 10/2022 13 min read

2 cases cited (1 SG, 1 foreign)

Outcome

Appeal dismissed

I therefore dismiss the appeal.

Source: [2023] SGHC 57, High Court (General Division), decided 10 March 2023. Read directly from the judgment.

Key facts

Court	High Court (General Division)
Decided	10 March 2023
Judge	Choo Han Teck
Charges / claim	Revenue Law
Outcome	Appeal dismissed
Counsel	Inland Revenue Authority of Singapore (Law Division), Rajah & Tann Singapore LLP, Bjorn Lee Long Jin, Koh Chon Kiat, Timothy Tan Ding Yuan, Vikna Rajah

Source: [2023] SGHC 57, High Court (General Division), decided 10 March 2023 — eLitigation. Updated 10 July 2026.

Catchwords

Revenue Law — Income taxation — Capital allowance

Practice Areas

Revenue Law

Judges (1)

Choo Han Teck Delivered

Counsel (6)

Inland Revenue Authority of Singapore (Law Division) Firm Rajah & Tann Singapore LLP Firm Bjorn Lee Long Jin Counsel Respondent Koh Chon Kiat Counsel Appellant Timothy Tan Ding Yuan Counsel Respondent Vikna Rajah Counsel Appellant

Parties (2)

Comptroller of Income Tax Respondent Singapore Cement Manufacturing Company (Private) Limited Applicant

Case Significance

Singapore Cement Manufacturing Co (Pte) Ltd v Comptroller of Income Tax [2023] SGHC 57 was heard by Choo Han Teck J in the General Division of the High Court on Tax Appeal No 10 of 2022, with reserved judgment delivered on 10 March 2023 under Revenue Law — Income taxation — Capital allowance. The appellant, a Singapore-incorporated company importing cement for sale to concrete suppliers, claimed accelerated capital allowance under s 19A of the Income Tax Act for a cement silo with a 24,000-ton capacity constructed in 2013 to prepare for increased demand of Portland fly-ash cement ("PFAC") under the Japanese TAIHEYO brand. The Comptroller of Income Tax rejected the claim and the Income Tax Board of Review dismissed the appellant's appeal in a grounds of decision dated 29 August 2022; the excerpt sets out the background to the further appeal rather than stating its final outcome.

[2023] SGHC 57 explained

SINGAPORE CEMENT MANUFACTURING COMPANY (PRIVATE) LIMITED v COMPTROLLER OF INCOME TAX ([2023] SGHC 57) is a Singapore judgment decided by the High Court (General Division) on 10 March 2023. It is categorised under Revenue Law. It is a recent decision; within this corpus no later judgment has cited it yet. This page summarises what the reported decision covers and links the primary sources — the full judgment, the statutes it cites, and the other cases it engages with — so the decision can be read in context. It is reference information, not legal advice, and it does not state the outcome or any holding beyond what the official judgment records.

What is [2023] SGHC 57 about?

SINGAPORE CEMENT MANUFACTURING COMPANY (PRIVATE) LIMITED v COMPTROLLER OF INCOME TAX ([2023] SGHC 57) is a High Court (General Division) decision from 2023. Its published catchwords are “Revenue Law — Income taxation — Capital allowance”, which indicate the subject matter the judgment addresses. The full reasoning and orders are in the judgment itself, linked below.

Which legislation does [2023] SGHC 57 consider?

The judgment refers to Income Tax Act (Cap 134). The statutes cited are listed in full on this page, each linking to its primary text.

Summary

Singapore Cement Manufacturing Company appealed against the Income Tax Board of Review's rejection of its claim for accelerated capital allowance under s 19A of the Income Tax Act for a cement silo it constructed in 2013. The key issue was whether the silo qualified as a 'plant' rather than a building for capital allowance purposes. The court dismissed the appeal, holding that the Board was not wrong to find the silo was a building and not a plant.

What was Singapore Cement Manufacturing Co v Comptroller of Income Tax [2023] SGHC 57 about?

It was a tax appeal before Choo Han Teck J over the appellant's claim for accelerated capital allowance under s 19A of the Income Tax Act for a 24,000-ton cement silo built in 2013, which the Comptroller rejected and the Income Tax Board of Review dismissed.

Why did Singapore Cement Manufacturing build the silo at issue in the case ([2023] SGHC 57)?

The appellant, which imported cement for distribution to concrete suppliers, began importing Portland fly-ash cement (PFAC) under the Japanese TAIHEYO brand in 2011 and constructed the 24,000-ton silo in 2013 in preparation for increased demand for PFAC.