Dismissing the appeal  of the revenue the Court held that  , from the agreement executed by the assessee with the non-resident company, it was evident that the non-resident company was required to inspect the quality of fabrics and other accessories in accordance with the sample approved by the assessee and co-ordinate with the suppliers to ship the goods within the stipulated date. The assessee in consultation with the exporters identified the manufacturers as well as the quality and price of the material to be imported. The non-resident company was nowhere involved either in identification of the exporter or in selecting the material and negotiating the price. The quality of material was also determined by the assessee and the non-resident company was only required to make physical inspection to see if it resembled the quality specified by the assessee. For rendering this service, no technical knowledge was required. The Tribunal on the basis of meticulous appreciation of evidence on record, had recorded a finding that the non-resident company was not rendering any consultancy service to the assessee. Therefore, it would not fall within the services contemplated under section 9(1)(vii) .( AY.2007-08)