In tax appeal, the Board of Review will listen, analyse and assess the evidence and the grounds submitted by the applicant and the IRD. The burden on calling witnesses to testify is on the applicant. The common law trial proceedings practised in Hong Kong was an adversarial system and not inquisitorial system. The parties of the hearing should submit the evidence and the grounds favourable to them for the Board to decide. The initiative to submit legal grounds or to call witness was on the parties of the hearing.