3 Jul 2025
Lembaga Hasil Dalam Negeri (LHDN) PROFOUND RELIANCE SDN BHD
- Citation
- WA-14-12-05/2022 (Mahkamah Tinggi)
- Court
- High Court
- Case number
- WA-14-12-05/2022 (Mahkamah Tinggi)
The court allowed the DGIR appeal (WA-14-12-05/2022) and set aside the SCIT decision for YA2009-2010, holding that Profound's tax returns were correctly assessed as business income under s.4(a) ITA because the Development Agreement and surrounding facts disclosed badges of trade and active commercial participation; s.131 relief was properly refused because the returns were made in accordance with the DGIR's prevailing practice (Public Ruling No.1/2009) and Profound's s.131 application for YA2011 failed the precondition of no outstanding tax; global costs RM10,000 awarded to DGIR.