In 1998, Mr. Simon Templar passed away and his wife Mrs. Templar inherited his business upon his death. The late Mr. Templar engaged in the real estate business. For a sentimental reason, Mrs. Templar carried on her late husband's business. There were a few pieces of land and some of them were developed into prime residential areas and put up for sale. Sale proceeds were subjected to income There were two other lots of land that were not developed and Mr. Templar has bought it when he first arrived in Malaysia in 1975 after quitting the secret intelligence service in Britain. He had intended to build his family home on these two pieces of land, lot 2125 and 2126 but he never got round to it and he never made the intention known. In 2007, Mrs. Templar decided to retire from business and several pieces of land including lots 2125 and 2126 were classified as fixed assets in the balance sheet of the business.

Mrs. Templar in 2020 disposed of the two pieces of land lot 2125 and 2126 when approached by Beng Choo, a land collector, and the sale proceeds were used to pay off her nephew's gambling debts. In 2020, the Inland Revenue assessed the gains arising from the sale proceeds to income tax. Mrs. Templar objected to the assessment and the assessor Mr. Win has asked her to file in the Form Q. She has come to you for advice.

REQUIRED: 

Discuss whether the disposal of the two pieces of land lot 2125 and 2126 are subjected to income tax.