Choo Kah Sing JCA:

Introduction

[1] The respondent filed an appeal to the High Court by way of case stated pursuant to s 39(1) of the Stamp Act 1949 (Revised 1989) (hereafter 'the Act'). The respondent's appeal was against the appellant's decision made on 8 March 2021 (pursuant to s 38A(5) of the Act) in that the appellant had rejected the respondent's notice of objection dated 16 November 2020 which was in response to a Notice of Assessment of Stamp Duty dated 13 February 2019 (hereafter 'the Notice of Assessment') issued by the appellant.

[2] On 30 March 2022, the learned High Court Judge allowed the respondent's appeal. Consequently, the appellant's Notice of Assessment was set aside.

[3] Dissatisfied with the decision of the learned High Court Judge, the appellant filed this appeal. For ease of reference, the appellant shall hereafter be referred to as "the Collector".

(Note: The High Court decision is reported as Ann Joo Integrated Steel Sdn Bhd v. Pemungut Duti Setem; [2022] 10 CLJ 722).

[4] On 3 July 2024, this Court , after having read the written submissions and after having heard the oral submissions from the counsels for the respective parties, reserved its