Edgar Joseph Jr FCJ:

[1] Datuk Haji Ghani Gilong, a businessman ("the taxpayer") and the respondent to this appeal, was assessed to income tax and increase of income tax (inclusive of penalties and interest) levied under sub-sections 4, 5 and 5A to s 103, of the Income Tax Act, 1967 ("the Act") for various sums, amounting in all, to RM504,052, in respect of the years of assessment 1970, 1971, 1972, 1973, 1982, 1983, 1984, pursuant to notices of assessment, duly sent by ordinary mail, and which were deemed to have been served, having regard to the provisions of s 145(2)(c) of the Act and were, by s 103(1) of the Act, payable on service of the same, whether or not he appealed under s 99 of the Act, against the assessment or composite assessments, as the case might be.

[2] A certificate purporting to have been issued under s 142(1) of the Act had been signed by the Acting Assistant Director General Puan Norlina bte Zainal for and on behalf of the Director General of Inland Revenue ("the Director General") giving the name and address of the taxpayer, and was, if valid, by reason of that provision, sufficient evidence of the amount, so due, as aforesaid, and sufficient authority f