WONG YUNG CHUN v Ketua Pengarah Hasil Dalam Negeri

ka-14-1-03-2024 High Court (Mahkamah Tinggi) 27 August 2025 • KA-14-1-03/2024

Catchwords

Real Property Gains Tax (RPGT)-- Assessment—Notice of Assessment—Setting aside assessment based on erroneous primary facts. Real Property Gains Tax (RPGT)-- Market value (MV)—Determination of acquisition price—Inconsistency in valuation by revenue body. Real Property Gains Tax (RPGT) -- Acquisition date—Determination for non-citizen beneficiary—Effect of State Authority consent on registration date. Tax appeal—High Court jurisdiction—Review of SCIT decision. Tax appeal -- Findings of fact—Intervention by High Court—Error of law arising from inconsistent facts. Tax appeal -- Principle of Edwards v Bairstow—Conclusion inconsistent with primary facts. Statutory Interpretation -- Taxing statute—Rule of strict construction—Ambiguity resolved in favour of taxpayer. Land Law -- Non-citizen acquisition of land—Requirement for State Authority approval—Section 433B National Land Code (NLC).

Practice Areas

Real Property Gains Tax (RPGT)-- Assessment—Notice of Assessment—Setting aside assessment based on erroneous primary facts. Real Property Gains Tax (RPGT)-- Market value (MV)—Determination of acquisition price—Inconsistency in valuation by revenue body. Real Property Gains Tax (RPGT) -- Acquisition date—Determination for non-citizen beneficiary—Effect of State Authority consent on registration date. Tax appeal—High Court jurisdiction—Review of SCIT decision. Tax appeal -- Findings of fact—Intervention by High Court—Error of law arising from inconsistent facts. Tax appeal -- Principle of Edwards v Bairstow—Conclusion inconsistent with primary facts. Statutory Interpretation -- Taxing statute—Rule of strict construction—Ambiguity resolved in favour of taxpayer. Land Law -- Non-citizen acquisition of land—Requirement for State Authority approval—Section 433B National Land Code (NLC).

Judges (1)

John Lee Kien How @ Mohammad Johan Lee Delivered

Parties (2)

Ketua Pengarah Hasil Dalam Negeri Respondent Wong Yung Chun Appellant

Case Significance

WONG YUNG CHUN v Ketua Pengarah Hasil Dalam Negeri is a High Court (Mahkamah Tinggi) decision dated August 27, 2025 (citation: ka-14-1-03-2024). The case was decided by John Lee Kien How @ Mohammad Johan Lee.

What was the outcome of WONG YUNG CHUN v Ketua Pengarah Hasil Dalam Negeri?

WONG YUNG CHUN v Ketua Pengarah Hasil Dalam Negeri is a High Court decision dated August 27, 2025. The case was heard by John Lee Kien How @ Mohammad Johan Lee. See the full judgment for details.