Introduction

[1] This is an appeal (encl 1) by Ketua Pengarah Hasil Dalam Negeri, the Appellant (DGIR) against the Deciding Order of the learned Special Commissioners of Income Tax (SCIT) dated 15 May 2020 which allowed the Respondent's (Company's) appeal and set aside the Notice of Additional Assessment for the Year of Assessment (YA) 2010 and Notices of Assessment for YA 2011 and 2012 all dated 29 December 2014 respectively (collectively, Impugned Assessment) which have been issued by the DGIR pursuant to the adjustment made under s 140A of the Income Tax Act 1967 ( ITA ) .

[2] The particulars of tax in the Notice of Additional Assessment for YA 2010 and Notices of Assessment for YA 2011 and YA 2012 all dated 29 December 2014 are as follows:

[3] After the hearing, I dismissed the DGIR's appeal in