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* The terms and conditions of the original contracts were determined in substance by its AE, M/s Tellabs Denmark and were only subsequently subcontracted/assigned to the assessee.
* The assessee merely carried out the contract with PGCIL in accordance with the terms and conditions originally determined in sum and substance by its AE, Tellabs Denmark. As a result the transaction between the assessee and PGCIL is squarely covered by the deeming provisions of Sec 92B(2) of the Act.