[1] On 25 August 2020, LPB Development Sdn Bhd (LPB) entered into a Sale and Purchase Agreement with Symphony Hills Sdn Bhd (Symphony) to acquire a property for RM29,855,022.12 (the said property).

[2] On 2 September 2022, LPB, Symphony, and the Plaintiff executed a Novation Agreement, under which the Plaintiff replaced LPB as the purchaser of the said property. On 24 October 2023, the Plaintiff signed the Memorandum of Transfer (Form 14A) and submitted a stamp duty adjudication application to the Collector of Stamp Duty (the Collector). To determine the applicable stamp duty, the Collector sought a valuation from the Valuation and Property Services Department (JPPH) which assessed the market value of the property at RM40,350,000.00. Unsatisfied with the valuation by JPPH, the Plaintiff filed Notice of Objection under s 38A(1) of the Stamp Act 1949 ( SA 1949), arguing that the stamp duty should be base