A judicial review application can proceed despite the existence of alternative remedies if those remedies do not cover all the relief sought.

[1] This is an application for leave by the Applicant for judicial review under O 53 r 3(1) Rules of 2012 to move the Court for the following relief:-

(a) an Order of Certiorari to quash the Notices of Additional Assessment for the Years of Assessment ("Y/As") 2007, 2008, 2009, 2010, 2011 and 2012 dated 4 December 2017 which were issued by the Respondent under the Income Tax Act 1967 (" ITA ") (hereinafter collectively referred to as "the Disputed NOAAs");

(b) a Declaration that the Disputed NOAAs are invalid in law;

or, in the alternative to the relief referred to in sub-paragraphs (a) and (b) above:-

(c) a Declaration that the imposition of taxes and penalties under the Disputed NOAAs for Y/As 2007, 2008 and 2009 (up to 31 December 2008) by the Respondent in reliance upon the "Transfer Pricing Guidelines" issued by the Inland Revenue Board and/or the Respondent on 2 July 2003 under the cover of the Respondent's letter dated 2 July 2003 (hereinafter referred to as "Transfer Pricing Guidelines 2003") and/or s 140 of the ITA is invalid in law as the Respondent and the Inland Revenue Board did not have the power to raise the Disputed NOAAs for Y/As 2007, 2008 and 2009 (up to 31 December 2008);

(d) a Declaration that the imposition of taxes and penalties under the Disputed NOAAs for Y/As 2009 (commencing 1 January 2009), 2010, 2011 and 2012 by the Respondent in reliance upon the "Transfer Pricing Guidelines" issued by the Inland Revenue Board and/or the Respondent on 20 July 2012 (hereinafter referred to as "Transfer Pricing Guidelines 2012") and/or s 140A of the ITA is invalid in law as the Respondent and the Inland Revenue Board did not have the power to raise the Disputed NOAAs for Y/As 2009 (commencing 1 January 2009), 2010, 2011 and 2012;

or, in the further alternative to the relief referred to in sub-paragraphs (a) to (d) above:-

(e) an Order of Prohibition to prohibit the Respondent from taking any steps pending the determination of the validity of the Disputed NOAAs;

or, in the alternative:-

(f) an Order of Mandamus to compel the Respondent to grant a standover of all taxes and penalties purportedly assessed under the Disputed NOAAs pending the determination of the validity of the Disputed NOAAs;

or, in the further alternative to the relief referred to in sub-paragraphs (a) to (f) above:-

(g) an Order of Certiorari to quash the penalties under s 113(2) of the ITA ;

(h) a Declaration that the Applicant is not liable to pay penalties under s 113(2) of the ITA ;

or, in the further alternative to the relief referred to in sub-paragraphs (a) to (h) above:-

(i) a Declaration that the taxes and penalties under the Disputed NOAAs are excessive and erroneous and should be reduced;

and as a consequence of the relevant Orders granted above,

(j) an Order of Mandamus to compel the Respondent to discharge, revise, revoke or amend, as the case may be, the Disputed NOAAs;

(k) an Order of Mandamus to compel the Respondent to refund any taxes and penalties paid by the Applicant under the Disputed NOAAs, if any;

or, in the alternative to the relief referred to in sub-paragraphs (j) and (k) above:-

(l) an Order of Mandamus to compel the Respondent to allow the Applicant to utilise any tax refunds owed by the Respondent to be set off against the taxes and penalties under the Disputed NOAAs;

(m) a Declaration that the Applicant can utilise any tax refunds owed by the Respondent to be set off against the taxes and penalties under the Disputed NOAAs;

(n) an Order of Mandamus to comp