Mokhtar Sidin JCA:

[1] In this case the appellant is a company incorporated under the Companies Act 1965. On 28 March 1980 the appellant purchased the following pieces of land for the sum of RM6,100,000:-

	Land Title	Lot No	Land Areas (sq ft)
GT 2047	(New Land Title GT 9344)	43)
		)
GT 2048	(New Land Title GT 9345)	44)
		)	101,004.75
GT 2049	(New Land Title GT 9346)	45)
		)
GT 2050	(New Land Title GT 9347)	46)
GT 9348		54)
		)
GT 16200		74)	89,243.55
		)
GT 16201		84)
			190,248.30

[2] On 20 August 1982, the appellant obtained approval from the Kuala Lumpur City Hall to build a 31-storey office block on the land. In the Annual Report dated 4 June 1983, the chairman of Hoklian Holdings Sdn Bhd, which has through its wholly-owned subsidiary company 50% equity participation in the appellant's company said:-

The Company has also through its wholly-owned subsidiary, Hoklian Development Sdn Bhd, entered into a joint-venture with Koperasi Jaya Diri Malaysia Bhd on a 50-50 basis, to acquire the entire issued capital of ALF Properties Sdn Bhd for $41.25 million. The Agreement for the said acquisition has been signed with the shareholders of ALF Properties Sdn Bhd recently. ALF Properties Sdn Bhd owns a piece of land exceeding 190,