Back
COURT OF APPEAL (PUTRAJAYA)
KAMALUDIN MD SAID, ABU BAKAR JAIS, COLLIN LAWRENCE SEQUERAH, JJ
Keysight Technologies Malaysia Sdn Bhd – Appellant
Versus
Ketua Pengarah Hasil Dalam Negeri – Respondent
| Table of Content |
|---|
| 1. appeal against tax assessment (Para 1 , 2 , 3 , 4) |
| 2. appellant's conversion to contract manufacturer and ip rights sale (Para 5 , 6 , 7 , 10 , 12) |
| 3. assessment beyond time bar; negligent reporting (Para 18 , 27) |
| 4. badges of trade and their inapplicability to ip rights (Para 21 , 22 , 24 , 25) |
| 5. arguments on capital vs income nature of receipt (Para 28 , 29 , 33 , 36 , 179) |
| 6. decision to allow appeal with costs (Para 190 , 192 , 193 , 197) |
[1]The Appellant’s appeal is against the decision of the learned High Court Judge (“HCJ”) delivered on 6.5.2020.
[2]The Respondent is the Director General of Inland Revenue (“the Revenue”), who had assessed the Appellant to tax in the sum of RM311,057,602.46 for the Year of Assessment (“YA”) 2008 under the Income Tax Act 1967 (“ ITA 1967”).
[3]The Appellant disputed the assessment raised by the Revenue and had appealed to the Special Commissioners of Income Tax (“SCIT”). The said appeal was dismissed by the SCIT on 12.3.2020.
[4]The Appellant then appealed against the decision of the SCIT to the High Court (HC) which appeal was dismissed. Hence, the appeal to this court.
(B) CHRONOLOGY OF EVENTS
[5]The Appellant had since its incep
An indispensable Tool for Legal Professionals, Endorsed by Various High Court and Judicial Officers
Please visit our Training & Support
Center or Contact Us for assistance
Scan Me!
India’s Legal research and Law Firm App, Download now!
For Daily Legal Updates, Join us on :
Back to top
