[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 inception and for some years now operated as a full-fledged manufacturer of various microwave devices, test accessories, amplifiers and transceivers. The Appellant sold its manufactured products to customers in various fields of industrial research, technology and other industries.

[6]In the course of its operations as a full-fledged manufacturer, the Appellant developed technical know-how in manufacturing and marketing activities (“hereinafter referred to as IP