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4. The assessee has set up an equipment in the form of midrange and mainframe computer and network at Phoenix USA and AEIPL was using this computer and network from 01.04.2002. The assessee was allowing the AEIPL use of mainframe and midrange computing facilities situated at Phoenix, storage of data on the mainframe or providing access to server incidental, electronic mail access, consolidated data and network access. An amount of USD 3,661,721 was payable by AEIPL to AETRSCO for the period 01.04.2002 to 31.03.2003.