Transfer pricing adjustment made in respect of sourcing commission

Author
View profile
Last updated: 10 July 2021
Quick Summary
This case concerns a transfer pricing adjustment made by the tax authorities regarding sourcing commission paid by Nike India Private Limited. Nike India claimed a commission of 7% for sourcing materials, benchmarking it against comparable companies. However, the Transfer Pricing Officer (TPO) determined the arm's length price (ALP) for this commission to be nil, resulting in a significant adjustment. The Dispute Resolution Panel (DRP) upheld this decision. The assessee appealed, citing a similar issue in a previous assessment year where the matter was sent back to the TPO for a fresh review.

Court :
ITAT Bangalore

Brief :
The assessee has filed this appeal challenging the order dated 28.12.2016 passed by the A.O. for assessment year 2013-14 u/s 143(3) r.w.s. 144 C of the Act in pursuance to the directions given by Ld. Dispute Resolution Panel (DRP).

Citation :
IT(TP)A No.2809/Bang/2017

Daily Limit Reached

You have reached your daily limit of 2 Free Judgements

Subscribe to CCI PRO for unlimited access

Why Upgrade to CCI PRO?
  • No Ads
  • WhatsApp Community
  • Daily E-Newsletter
  • Unlimited Judgements Access
  • Profile Visitors
  • Link Social Profiles
  • Featured Job Posts
  • Pro Badge
  • Expert GST Guidance
  • Unlimited Forum Replies
  • Download Content in PDF
1 Year PLAN
1999
(Excl. of GST ₹359)

2 Years PLAN
3499
(Excl. of GST ₹629)

BEST VALUE
3 Years PLAN
4999
(Excl. of GST ₹899)

View all CCI PRO benefits

Already a PRO member? Login here for an ad-free experience. 07941056694

 


Guest

Judgement posted by

Guest

View Judgements
Comments


Recent Judgments :

  1. No Fresh Pre-Deposit for GSTAT Appeal When Earlier Deposit Already Covers 20% of Disputed Tax
  2. CESTAT: Service Tax Demand Based Solely on ITR Data Unsustainable; 40% Valuation Applicable to Original Works Contract
  3. CESTAT: Renting Vehicles on Per-Trip Basis Not Taxable as Supply of Tangible Goods
  4. CESTAT Denies Refund of Ocean Freight Service Tax Claim Filed Beyond Limitation
  5. CESTAT Quashes Service Tax Demand Based Merely on Form 26AS; Renting of Residential Hostel Held Non-Taxable
  6. CESTAT: Rajasthan Sales Tax Subsidy under RIPS 2010 Not includible in Excise Assessable Value
  7. CESTAT: Late Payment Charges in the Nature of Interest Not Taxable as Declared Service
  8. CESTAT: Educational Services Exempt Under Section 66D; Extended Period Cannot Be Invoked Without Wilful Suppression
  9. CESTAT: No Service Tax on Royalty under RCM if Mining Lease Was Executed Before 1 April 2016
  10. No pre-deposit required for filing appeal before the GSTAT against penalty-only orders where proceedings commenced prior to October 01 2025

View More Judgments »


Trending Online Classes

view all classess

CCI Pro
Meet our CAclubindia PRO Members
Pro Member shashishashiPro Member B L BhojwaniB L BhojwaniPro Member DHANASHRI KARMARKAR DHANASHRI KARMARKAR Pro Member CA. K. BRAHMANAYAGAMCA. K. BRAHMANAYAGAMPro Member CA Varun GuptaCA Varun Gupta
Subscribe to Pro
Join an elite circle of professionals

Browse by Category




Latest Job Openings

View all
Company
Featured 07 November 2026
Paid Assisstant

DPV & Associates

Chennai

CA Inter

View Details
Company
31 October 2026
Accountants

sankaran and krishnan

New Delhi

B.Com

View Details
Company
ARTICLESHIP 28 October 2026
Article assistants

Shyam S Gupta and Company

New Delhi

CA Inter

View Details
Company
13 November 2026
Chartered Accountant - Fresher

Neeraj Bhagat & Co

New Delhi

CA

View Details
Company
Featured 07 November 2026
Chartered Accountant

DPV & Associates

Chennai

CA

View Details
Company
ARTICLESHIP 29 October 2026
Article Assistant (CA Inter / CMA Inter) - Thrissur

Varma Raja & Associates

Thrissur

CA Inter

View Details
Company
10 November 2026
FP&A Executive

Gujarat Guardian

Ankleshwar

CA Final

View Details
Company
ARTICLESHIP 07 November 2026
Article Assisstant

DPV & Associates

Chennai

CA Inter

View Details