The longstanding position of the Inland Revenue Board of Malaysia (“IRB”) in regard to judicial review applications to challenge tax assessments raised by them is that the appeal procedure under section 99 of the Income Tax Act 1967 (“ITA”) is sufficient to address taxpayers’ complaints. Accordingly, the IRB have always argued that since a domestic remedy is available, aggrieved taxpayers should not be given leave to apply for judicial review, much less be heard on the merits.

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