Faizah Jamaludin J:

A. Introduction

[1] This is an application by the Government of Malaysia for summary judgment under O 14 r 1 of the Rules of 2012 ("ROC") for its claim against the defendant, Nooryana Najwa Mohd Najib, for tax due and payable for the years of assessment 2011, 2012, 2013, 2014, 2015, 2016 and 2017 ("YAs 2011 to 2017").

[2] The plaintiff had filed a civil suit against the defendant for recovery of the sum of RM10,335,292.36 being income tax assessed against the defendant for YAs 2011 to 2017 including penalties and increases under the Income Tax Act 1967 [Act 53] (" ITA "). The suit and this application for summary judgment was filed by the Inland Revenue Board of Malaysia ("IRB") on the plaintiff's behalf, pursuant to the IRB's function under s 10(a) of the Inland Revenue Board of Malaysia Act 1995 [Act 533] ("IRB Act").

B. Background Facts

[3] The defendant did not file her tax returns for any of the said YAs within the time stipulated in s 77 of the ITA . The Director General of Inland Revenue ("DGIR") through Notices of Assessment (Form J) dated 15 March 2019 raised assessments for each of the said YAs under sub-section 90(3) of the together with pen