[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 t