The penalty imposed by the Director General of Inland Revenue was 20% of the tax assessed for the year. The 20% penalty should not be based on the difference between the tax payable and the tax already paid because that was not what s 112(3) of the Income Tax Act 1967, whether expressly or impliedly provides. Yung Lung Holdings Sdn Bhd v Ketua Pengarah Hasil Dalam Negeri (2016). KCH-14-2/12-2015. High Court, Kuching. Dato’ Rhodzariah binti Bujang J. 4 May 2016.