Mokhtar Sidin JCA:

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

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