M/S STERLING URBAN DEVELOPMENT PVT LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(1)(2), BANGALORE
In the result, the grounds of appeal are decided as follows: Ground
ITA 3282/BANG/2018[2014-15]Status: DisposedITAT Bangalore22 Nov 2021AY 2014-15
Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.3282/Bang/2018 Assessment Year : 2014-15 M/S. Sterling Urban Development Pvt. Ltd., Vs. The Deputy Commissioner Of Income Tax, No.8, Level-5, Prestige Nebula, Circle -6(1)(2), Cubbon Road, Bengaluru. Opp. To Income Tax Office Building, Bengaluru – 560 001. Pan : Aaacf 9183 C Appellant Respondent Appellant By : Shri. Ramasubramaniyan, Ca Respondent By : Shri. Muzaffar Hussain, Cit(Dr)(Itat), Bengaluru Date Of Hearing : 12.10.2021 Date Of Pronouncement : 22.11.2021 O R D E R Per Chandra Poojari: This Is An Appeal By The Assessee Against The Final Order Of Assessment Dated 12.10.2018 Passed By The Dcit, Circle-6(1)(2), Bengaluru, Passed U/S. 144C R.W.S. 143(3) Of The Income-Tax Act, 1961 [The Act] Relating To Assessment Year 2014-15. 2. The Assessee Is A Company Incorporated Under The Companies Act, 1956 On 12Th June 2002 Under The Name & Style “Foundation Habitats (India) Private Limited”. The Company Has Been Converted As A Spv In The Year 2006. The Assessee Is Engaged In The Activities Relating To Real Estate
For Appellant: Shri. Ramasubramaniyan, CAFor Respondent: Shri. Muzaffar Hussain, CIT(DR)(ITAT), Bengaluru
Section 144C
section 40A(2)(b) of the Act. Therefore, the transactions with HDFC Property Fund are not to be treated as Specified Domestic Transactions. The assessee also submitted that it is no doubt true that the petitioner itself treated the transaction as SDT, prepared a Transfer Pricing
