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(d) internet access services providing connectivity between a port located at an Administrations point of presence in a country and the global internet (―GIA‖);
(e) global IP VPN Service being a service providing a TCP/IP Virtual Private Network connectivity between designated access end points (being ports) (―IP VPN‖), operated by each of the Administrations and the.
(i) in the case of IPLC, Frame Relay and ATM, both of the half circuits comprising an International Service; and
(ii) GIA and IP VPN, and Local Loop, through a single point of contact at either of the Administrations, with the option of requesting SEB and SPFR ; and
(b) Administration B may provide SEB and SPFR to Administration A in respect of the International Service subject to the SEO.
―2.5.1 M/s Telstra Singapore is a company incorporated in Singapore, outside of India, and is in the business of providing connectivity solutions (International Private Leased Circuits, Multiprotocol Label Switching ('MPLS'), IP /VPN etc) to facilitate high speed data connectivity (hereinafter referred to as 'bandwidth services'). Telstra Singapore holds the infrastructure and equipment, either owned or leased, outside India required to provide bandwidth services to customers.‖

36. This position, according to Mr. Sabharwal, is also evident from a reading of the directions of the DRP dated 16 October 2015 and where the business of the respondent assessee was examined and understood as having the following characteristics: -

―1.0 The assessee, M/s. Telstra Singapore Pvt. Ltd., is a non-resident company incorporated in Singapore. It is engaged in the business of providing connectivity solutions (International Private Leased Circuits, Multi-Protocol Label Switching ('MPLS'), IP/VPN etc.) to facilitate high speed data connectivity (hereinafter referred to as 'bandwidth services'). Telstra Singapore holds the infrastructure and equipment, either owned or leased, outside India required to provide bandwidth services to customers. Under the Indian telecom regulations, only a licensed service provider can provide Bandwidth Services in India. To facilitate provision of bandwidth services in India, it entered into an agreement with Bharti Airtel Limited ('Bharti'), an unrelated telecom company (referred as One Stop Shop ('OSS') Agreement).