Sharing of knowledge shall not be called as consulting engineering service when expertise acquired by a concern is also used for its own benefit along with others

RELEVANT PARAGRAPH  6. We have thoroughly gone through the averments of both the sides. To appreciate the case of the Revenue, Revenue should have brought to record that Nyco is a consulting engineering firm providing engineering service commercially having been manned by professional qualified engineers. But primary object appears to be sharing of know how to participate in a joint venture to enjoy fruit thereof by each other. Nothing is shown by Revenue to establish that Nyco shall leave India after rendering consulting engineering service without participation in joint venture. We find fro...