Madam Phew is one of the developer company directors, Availing Property Sdn Bhd. Madam Phew acquired a piece of raw land in 2018 with the purpose to distribute the land for 3 of her children. She consumed her own saving and 40% of the balanced of the acquisition was financed by bank borrowings. In 2019, Madam Phew develop the land for residential use. In 2020, Madam Phew received an interesting offer from Availing Property Sdn Bhd to purchase the land. She sold the land amounting to RM1,250,000 to Availing Property Sdn Bhd in 2021. Madam Phew submitted the Real Property Gains Tax (RPGT) return instead of income tax return to Inland Revenue Board (IRB) for the disposal. Required: Discuss the difference between RPGT and income tax, and state the argument whether the disposal is subject to tax? (25 marks)