Visionary Vault Engineers $($Pty$)$ Ltd$,($VVE$),$ is a dynamic engineering firm. VVE tackles complex challenges, from machinery design to software development. Their recent patent development showcases their commitment to pushing technological boundaries, solidifying their position as industry leaders. VVE sold one of its branches in Gqeberha on $1$ December $2023$ to a newly incorporated company, Evolve Edge $($Pty$)$ Ltd$,($Evolve Edge$)$ in exchange for a $52\%$ shareholding in Evolve Edge. The other $48\%$ of Evolve Edge is held by a BEE Trust, which is an independent third party. All the parties are residents of South Africa. On $1$ December $2023,$ the market value and the selling price of the Gqeberha branch was R$18000000,$ consisting of below: Description Rand $$ Fixed asset $($note $1)5000000$ Intangible asset $($patent$)($note $2)13000000$ Total $18000000$ Notes: $1.$ The fixed asset is an investment property held at cost price, which was originally purchased for R$5000000$ on $14$ September $2014.$ The property did not qualify for any capital allowances. $2.$ The base cost of the patent which was purchased on $14$ September $2014,$ is Rnil. The market value of the patent is R$13000000$ on $1$ December $2023.$ The R$18000000$ consideration was settled by Evolve Eve through the issue of a $52\%$ shareholding. Additional information: $$ According to the sales agreement VVE and the BEE Trust must keep their shares for a period of five years and Evolve Edge may not sell any of the assets for a period of five years. $$ Evolve Edge will continue to hold the property as an investment property and the intangible asset as a capital asset. $$ Evolve Edge and VVE do not form part of the same group of companies. REQUIRED: Discuss the application and the effect of the relief measures in terms of section $42$ of the above restructuring for Visionary Vault Engineers $($Pty$)$ Ltd$.$ First state the requirements of section $42$ of the Income Tax Act, whereafter you apply the requirements to the facts of the scenario. Show all calculations clearly. $(25$ marks$)$