The judgment, delivered by Judge Choo Han Teck, reaffirms the Comptroller of Income Tax’s earlier decision to deny capital allowances on these assets, classifying them as “structures” rather than “tools of trade.”
CAG’s expenditures for the assets in question totalled $272,575,162. CAG and the Comptroller agreed that the purpose of the runways and taxiways was to ensure the safe landing, takeoff, and taxiing of aircraft. Judge Choo noted that while these runways and taxiways are integral to airport operations, their primary function as structures outweighed any operational or navigational support role they may provide to the aerodrome.The court’s focus, Judge Choo clarified, was on the assets’ structural purpose rather than their operational importance in CAG’s business.