Dismissing the appeal of the revenue  the Court held that a new activity may produce the same commodities of the old business or it may produce some other distinct marketable products. In the instant case, the assessee was engaged in on site development of software program. The programs were delivered at the premises of the client at the work site in South Korea. The activities of the assessee finally culminated at the work site of the clients at South Korea and there was no need for full fledged infrastructure facilities in India.  ( AY. 2007 -08)