In this article, the author suggests that there is material overhead associated with SET NOCOUNT ON and that \"By removing this extra overhead from the network
SET NOCOUNT ON
The last link in my question here: "SET NOCOUNT ON usage" refers to an article on it.
Given how trivial it is, why not leave it in and stop the client processing another resultset?
And without SET NOCOUNT ON, nHibernate can break too (mentioned in question)