5 Nov 2024
Ketua Pengarah Hasil Dalam Negeri KIND ACTION (M) SDN BHD AMICUS CURIE BAR MALAYSIA
- Citation
- 01(f)-18-05/2024(J) (Mahkamah Persekutuan)
- Court
- f
- Case number
- 01(f)-18-05/2024(J) (Mahkamah Persekutuan)
Because the Director General accepted the RPGT returns and issued a certificate of clearance and no appeal was filed, the RPGT assessments became final and conclusive under s.20(1) RPGTA; therefore estoppel in pais and legitimate expectation barred the appellant from imposing additional income tax under the ITA, and the respondent was entitled to seek judicial review in the High Court without first pursuing the Special Commissioners of Income Tax; appeal dismissed.