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46. The third issue pertains to the treatment and functional significance of the Open Connect Appliances (OCAs). The Revenue has viewed the OCAs servers installed with Internet Service Providers to enhance streaming efficiency as substantive technological assets owned by Netflix India, conferring upon it a pivotal infrastructural role in the group‟s global operations and exposing it to investment risk. The assessee disputes this, asserting that OCAs are merely cache devices akin to logistical tools for temporary content storage, devoid of processing capability or customer data, and that they serve only to assist ISPs in bandwidth management. Whether these appliances are to be viewed as core technological assets or routine logistical aids bears directly on the FAR profile of the Indian entity.