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Merimen Online Sdn Bhd – Appellant
Versus
Ketua Pengarah Hasil Dalam Negeri – Respondent
| Table of Content |
|---|
| 1. facts about the appellant's corporate status and tax incentives. (Para 3 , 4 , 5 , 6 , 7 , 8) |
| 2. outline of the central issues in the appeal. (Para 12 , 18 , 19) |
| 3. the scit's decision on negligence and tax assessments. (Para 16 , 30 , 34 , 35 , 40) |
| 4. interpretation of the pia in context of the appellant's income. (Para 46 , 54 , 72) |
| 5. final ruling and implications on previous judgments. (Para 84 , 86) |
INTRODUCTION
[1]This is an appeal against the judgment of the High Court which had, by way of case stated affirmed the decision of the Special Commissioners of Income Tax (‘SCIT’) which had earlier dismissed the appellant’s appeal against the assessments raised by the respondent, the Director General of Inland Revenue (‘DGIR’) under the Income Tax Act 1967 (‘the ITA’).
[2]Having heard the appeal, examined the appeal records and considered the submissions by parties, we unanimously decided to set aside the decision of the High Court and the SCIT and therefore, allow the appeal, for the reasons which are set out herein.
KEY BACKGROUND FACTS
[3]The appellant is a company incorporated in Malaysia and having its registered office at Block D, UPM — MTDC Technolo
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