AAR held  that the apportionment of profits to the technical services rendered by the applicant could not be done in an arbitrary manner. Such apportionment can be done only out of the “f. o. b. price for main equipment” and not against the other payments. It would be appropriate if the Assessing Officer determined this aspect and gave value to the fees for technical services, as these were included in the sale price of offshore supply of equipment, after making further necessary enquiries and giving a basis thereof.