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17. The marine work takes in construction of breakwater, dredging and LNG Jetty. Equipment under import in the circuit LNG Jetty are foundation piles, steel profiles fenders, mooring systems, navigational aids etc. The Commissioner had included only those service charges which according to him related to imported goods meant for the jetty. It is contended on behalf of the appellant that the nature of the service rendered by the sub-contractor Six Construct Limited, is such that its value is not includible. Therefore, the assumption that one third of the value of the services under this heading should be added to the transaction value of the imported equipment is incorrect. The appellant submits that the service rendered under the Heading 'Engineering & Management does not at all involve identifying any specification for any equipment or material required for marine works. It relates to cost to Six Construct Limited for planning, directing, controlling, evaluating the activities in order to accomplish the task. Under the Heading 'Commercial Management' the service provider has covered its cost of commercial management and coordination of financing, management taxes and duties, insurance services, currency management etc. It has no connection to the services contemplated under Rule 9(1)(b)(iv). As far as Heading 'Detailed Engineering Design' is concerned, the appellant would contend that imported items for the Jetty are readily available articles such as piles, fenders, mooring systems, navigation aids etc. which do not require any design or engineering drawing supplied by the purchaser. The Basic Engineering and Stability calculation is an activity which precedes detailed engineering and therefore, it has also no connection to the services contemplated under Rule 9(1)(b)(iv). Seismic Engineering is something related to the site in India which also does not involve any engineering required for production of imported goods. This service rendered under Heading 'Scheduling' is in respect of an overall project schedule for implementation of project execution. It contemplates targets for completion and progress on monthly basis. The service has also no relevance under Rule 9(1)(b)(iv). According to the appellant, the service rendered under Mathematical Mooring Testing is also not connected with any engineering design specification. The services rendered under the Mathematical Wave Testing relates to determination of design parameters at the berth and along the trestle. It is part of jetty work which is mostly a concrete construction utilising materials purchased in India. The appellant would therefore, submit that addition made by the Commissioner in respect of the activities undertaken under the marine work is unsustainable.