The taxpayer is a company incorporated in Malaysia and its principal activities are the letting of properties and property investment. In 2005, the taxpayer entered into a Sale and Purchase Agreement for the acquisition of 59 apartment units in the city centre. The taxpayer's ultimate intention was to place these assets in a real estate investment trust, where they were projected to increase in value due to the up-and-coming development around the area. The assets were consistently treated as the taxpayer's fixed asset in its audited accounts. In 2010, the taxpayer was approached by a third party who informed the taxpayer that it has potential buyers for the 59 apartment units. The taxpayer then entered an en-bloc transaction for the sale of the 56 apartment units and separate transactions for the sale of the 3 remaining units. The sale of the 3 apartment units was completed in the YA2010 and the sale of the remaining 56 units were completed in YA2011.