Chang Min Tat J:

The appellant, after "a back-duty investigation" by Revenue as to his tax liabilities, was assessed to tax in the sum of $8,145,841.50. This sum represented in part additional assessments for the years of assessment 1953, 1957 to 1961 inclusive and also 1971. The balance consisted of original assessments for the years of assessment 1962, 1966 to 1972, inclusive, in respect of which years no tax had previously been computed; in other words for those years returns were made by the appellant, showing no income chargeable to tax.

He appealed to the Special Commissioners. The hearing before them occupied a total of 30 days spread over nine months from 3 December 1974 to 2 September 1975. Oral evidence was taken from the appellant himself, and on behalf of Revenue from Mr. Sadasivam, an Assistant Director of Inland Revenue (Investigation) who was in charge of this back-duty investigation and who was himself a Chartered Accountant. Both witnesses were examined and cross-examined at length. A total of 240 exhibits were also introduced and considered. Finally on 27 September 1975, the Special Commissioners made an unanimous deciding order, assessing the appellant'