JUDGMENT

Gunalan Muniandy JCA:

Introduction

[1] Muhibbah Engineering Sdn Bhd ['Muhibbah'], the Taxpayer/appellant, a well-known published listed company, has brought this appeal against the decision of the Learned High Court Judge ['LHCJ'] dated 27 July 2020 to dismiss the appellant's Application for Leave for Judicial Review dated 29 January 2020 ['Appellant's Application for Leave'] against the Revenue/ respondent ['respondent'].

[2] The sole issue for our determination in this appeal was whether the LHCJ had erred in law in her decision to dismiss the appellant's Application for Leave to apply for Judicial Review.

Factual Background

[3] The appellant is a public listed company incorporated in Malaysia, principally engaged in the business of providing oil and gas, marine, infrastructure, civil and structural engineering contract work.

[4] On 3 July 2019, the respondent concluded its tax audit and issued its preliminary audit finding letter to the appellant. The respondent disallowed the deduction of the Project Accrued Expenses and adjusted the losses that the appellant surrendered for group relief to its related company, Muhibbah Marine Engineering Sdn Bhd ['MME'] in years of assessmen