Trans-Kenari Express (TKE) operated an express bus service for various routes in Malaysia. The company was also granted approval by the Public Transport Council of Thailand to operate the buses(from Changlun) into Thailand on condition that passengers embarking the buses in Thailand to Kuala Lumpur, Ipoh, Penang and Johor Bahru should buy the tickets in Thailand. The sale of the tickets was done by the agents of TKE. The income from the sale of tickets in Thailand and related costs were reflected separately in the accounts. Return tickets which were sold in Malaysia for the journey to Thailand were treated as Malaysian income in the accounts. REQUIRED: Discuss whether the sale of bus tickets in Thailand can be treated as income accruing in or derived from Malaysia. Support your answer with relevant cases.

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