DCIT Vs. ROLLS ROYCE MARINE INDIA PVT. LTD.

JUDGEMENT

(1.) THIS is an appeal filed by the Revenue and Cross Objection by the assessee against the order passed under Section 143(3) read with Section 144C(13) of the IT. Act, 1961, giving effect to the order of DRP passed u/s. 144C(5) of the I.T. Act, wherein following grounds have been taken by the Revenue: -

(2.) THE appellant prays that the order of the DRP on the above grounds be set aside and that of the A.O. be restored.

(3.) RIVAL contentions have been heard and record perused. Facts in brief are that assessee M/s. Rolls -Royce Group (Marine Division) (in short 'RRM') is a global leader in power propulsion and motion control systems. It offers a product portfolio ranging from vessel design and gas turbine engines to water jets and deck handling equipment. RRM India is part of Marine division of Rolls -Royce Group. RRM India is engaged in the business of providing marketing & sales support, assembling services and after sales services to the Group for its activities in India and to third party clients. The various international transactions entered into by RRM India were categorized into 3 segments based on the nature of activities and functions performed i.e. after sales services, Assembly and Delivery Management Services and Marketing & sales support services. RRM India prepares a 'Transactional Profit & Loss Account' for ascertaining the margins earned by it from each category of the transactions.