Dismissing the appeal of the Revenue the Court held that where contract entered into by assessee with a consortium of companies in connection with contract for designing, manufacturing, supply, testing, commissioning of passenger rolling stock and training was an indivisible contract and dominant object of contract was supply of rolling stock and work taken up was ancillary to supply of rolling stock and did not amount to professional or technical service, payment made by assessee to consortium is  not  liable to deduct tax at source. (AY. 2011-12)