Badariah Sahamid JCA:

Introduction

[1] This is an appeal by the Applicant in the High Court, Uniqlo (Malaysia) Sdn Bhd against the decision of the learned High Court Judge, Datuk Hajjah Azizah bt Hj Nawawi, who dismissed with costs the Applicants application for judicial review.

[2] The Applicants application for judicial review pursuant to O 53 r 3(1) of the Rules of 2012 (ROC 2012) had sought the following orders:

(i) An order of certiorari to quash the Respondents decision dated 16 November 2016 that the Applicants application for special refund of sales tax for goods held on hand pursuant to s 190 of the Goods and Services Tax Act 2014 (GST Act) is rejected without any justification or reasoning; and

(ii) An order of mandamus directing that the Respondent refund the sum of RM6,076,369.33 for the special refund of sales tax for goods held on hand to be paid to the Applicant by the Respondent upon final determination of this judicial review.

Background Facts

[3] The narration of the background facts is derived from the learned High Court Judges (learned Judge) "Grounds of Decision", with suitable modifications.

[4] For ease of reference, parties will be referred to as they wer