[1] This appeal by the Director General of Income Tax ['the DGIT' or 'the Revenue'] had related to the question of whether the expenditures incurred by the taxpayer for years of assessment 2000-2004 could properly be subject to be taxed under the Income Tax Act 1967 ['the ITA of 1967'] or otherwise.

[2] The factual matrix pertaining to this case may be described as follows:

The tax payer was a company whose main business has been involved in the leasing of property or real estate, such as renting out its properties to tenants for payments of rental as consideration. As far as the taxation on rental income was concerned, there appeared to be a non-issue. What had become the issue between the parties in this appeal had been whether