Dismissing the appeal of the Revenue  the Court held that  the services rendered by the assessee were project specific and terminated with submission of bid by ABB India after making necessary changes or corrections in the bid based on the evaluation report. If the agreement permitted the assessee to make available the results for guidance to other entities in the group, that could not be attributed as services “made available” which could be used in perpetuity. No income accrued or arose to the assessee in India. Appeal of Revenue is dismissed.  (AY.2009-10)