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HIGH COURT MALAYA KUALA LUMPUR
KETUA PENGARAH HASIL DALAM NEGERI – Appellant
Versus
PROFOUND RELIANCE SDN BHD & ANOTHER APPEAL – Respondent
| Table of Content |
|---|
| 1. appeals filed concerning tax assessments. (Para 1 , 4) |
| 2. court's observations on legal principles and arguments. (Para 2 , 9 , 10) |
| 3. arguments from parties regarding tax assessments. (Para 5 , 6) |
| 4. key provisions of the income tax act. (Para 7 , 8) |
| 5. final judicial orders and costs awarded. (Para 11) |
(Enclosure 1 /L.1)
Introduction
[1] The parties in this proceeding have filed two (2) separate appeals against the same decision of the Special Commissioners of Income Tax (SCIT) dated 28 April 2022, as follows:
(A) WA-14-12-05/2022
1.1 This is an appeal by the Ketua Pengarah Hasil Dalam Negeri (DGIR) against the Deciding Order of the Special Commissioners of Income Tax (SCIT) dated 28 April 2022, that favoured the respondent (Profound Reliance Sdn Bhd). It concerns Profound's application for relief over a supposed error or mistake in the Year of Assessment (YA) 2009, 2010, and 2011, dated 20 March 2013, under s 131 Income Tax Act 1967 .
(B) WA-14-13-05/2022
1.2 This is an appeal by Profound against part of the SCIT panel of three's decision that had unanimously and on its motion denied Profound's appeal for YA 2011 over a supposed error or mista
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