bad debts - whether company carrying on the business of the lending of money - whether the money lent was in the ordinary course of business - ss 16(1D) and 17(1C) of Inland Revenue Ordinance
sale of intellectual property - licence back to original vendor - whether transactions artificial - whether sole or predominant purpose was to obtain a tax benefit - ss 61 and 61A of the Inland Revenue Ordinance
quarters provided by employer - taxpayer required to occupy quarters under terms of employment - whether value of quarters should be subject to salaries tax and whether it was excessive