Background Facts Leading To This Appeal

[1] Vide a notice of appeal dated 23 October 2013 the appellant ('the appellant/taxpayer') had appealed against the decision of the learned Special Commissioners of Income Tax ('the SCIT') dated 27 September 2013, who had decided in favour of the respondent, ie the Ketua Pengarah Hasil Dalam Negeri ('the respondent/revenue')

[2] The appeal was made, to this court by way of case-stated, dated 15 January 2014, filed by the SCIT, under para 34, Schedule 5 of the Income Tax Act 1967 ('Act 53') for the opinion of this court on questions of law.

[3] Hence, the legal issues for the determination of this court as stated by the SCIT, were the same issues that were heard by the SCIT, namely:-

(a) on the first issue of time bar:-

Whether the notices of assessment ('the impugned notices') issued by the respondent/revenue for the Years of Assess