Dismissing the appeal of the revenue the Court held that 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.  No question of law. (AY. 2007-08)