S. Saravana Kumar

On the court record

A specialist revenue-law practice in income-tax disputes and judicial review of assessments across all three court tiers.

S. Saravana Kumar practises as tax and revenue counsel, appearing across the High Court (Mahkamah Tinggi), the Court of Appeal (Mahkamah Rayuan) and the Federal Court (Mahkamah Persekutuan). The reported decisions are dominated by disputes with the revenue authority — appeals to and from the Special Commissioners of Income Tax (SCIT) and matters in which the Director-General of Inland Revenue ("Ketua Pengarah Hasil Dalam Negeri") is the opposing party. The subject is income tax: the correctness of assessments, the characterisation of receipts, and the availability of deductions and reliefs under the Income Tax Act 1967.

A distinctive feature is the use of judicial review ("semakan kehakiman") as an alternative to the statutory appeal route. Several matters are applications for judicial review in which the taxpayer contends that an assessment was made without jurisdiction or in breach of a public-law duty, raising the boundary between the tax appeal machinery before the SCIT and the supervisory jurisdiction of the High Court. The reported work also engages specific charging and relief provisions, including the sections governing the deductibility of expenses and the treatment of particular classes of income.

Appearing on both sides across different matters — for taxpayers as appellant and applicant, and as respondent — the practice is organised around the statutory framework of direct taxation and the procedural choices a taxpayer faces in challenging the revenue. There is also land and company work that intersects with the tax questions, for example where the character of a land transaction determines its tax treatment.

The overall profile is a specialist revenue-law practice conducted at every tier up to the Federal Court. The matters turn on the interpretation of the Income Tax Act, the reviewability of assessments, and the relationship between the specialist tax tribunal and the ordinary courts, rather than on general commercial or criminal litigation, marking a focused public-and-revenue-law speciality.