The court affirmed that an extension of time in judicial review requires justifiable reasons, and individuals must exhaust internal remedies before seeking judicial review.

[1] The appellant's appeal was against the decision of the Kuala Lumpur High Court granting the respondent's application for judicial review. We allowed the appeal and these are our grounds.

[2] The respondent's application for judicial review was for the following reliefs:

(i) an order of certiorari to quash the appellant's decision dated 18 January 2017 that the respondent's application for the special refund of sales tax for goods held on hand pursuant to s 190 of the Goods and Services Tax Act 2014 ("the GST Act") was rejected without any justification or reasoning;

(ii) an order of mandamus directing the appellant to refund the sum of RM5,120,368.28 for the special refund of sales tax for goods held on hand to be paid to the respondent by the appellant upon the final determination of the judicial review;

(iii) if the respondent's application was found to have been out of time, that the respondent be granted an extension of time pursuant to O 53 r 3(7) of the Rules of 2012 ("the Rules");

(iv) that the costs of and/or incidental to the application be costs in the cause; and/or

(v) such further, alternative, consequential or other relief as the Court deemed fit and proper in the circumstances.

[3] The learned judge allowed prayer (iii) above and thereafter proceeded to hear the merits of the respondent's application for review, at the conclusion of which she allowed the application.

[4] The salient facts are these. The respondent is a company incorporated in Malaysia on 22 March 2011 and is in the retail business of importing fashion apparels and accessories under the "Coach" brand name designed and produced by the respondent's holding company, Coach Inc for the purpose of being sold to its Malaysian customers. The respondent retails its goods through its 18 outlets in various locations in Malaysia.

[5] With the introduction of the GST Act which came into force on 1 July 2014 (Parts I, II, IV, VI and XVI) and on 1 April 2015 (Parts IX, XIII, XVII and XVIII), the respondent applied for registration and became registered under s 20 with effect from 1 April 2015.

[6] The GST Act has since been repealed. However, the repeal has no bearing on the outcome of this appeal as the respondent was still subject to the GST Act when the cause of action arose.

[7] On 29 September 2015, the respondent submitted an application to the Director General of Customs ("the DG") for a special refund of sales tax for goods held on hand pursuant to s 190 of the GST Act. The application was made online by the respondent and was in respect of "women's and men's bags, women's and men's small leather goods, business cases, footwear, wearables including outerwear, watches, weekend and travel accessories, scarves, sunwear, fragrance, travel bags and other lifestyle products". The total amount of special refund that the respondent applied for was RM5,120,388.28.

[8] The respondent claimed that it had satisfied all the requirements for the special refund application as stipulated by ss 190 and 191 of the GST Act.

[9] By email dated 9 December 2015, the DG requested for additional supporting documents and further information from the respondent for sales tax audit purposes. The request was complied with by the respondent vide email dated 16 December 2015 by handing over the physical copies of the relevant documents and information to the DG, which was received by the DG on 21 December 2015.

[10] On 18 January 2017, the appellant informed the respondent that its special refund application was rejected. The decision was conveyed to the respondent by uploading the rejection letter to the respondent's Taxpayer Access Point System account ("TAPS account"). The appellant followed