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(e), wherein it was reported as under:-

"e) The SNIPL owns three separate undertakings engaged into Research & Development relating to software solutions and export activity. All these units are established as 100% Export Oriented Units with separate registrations with the STPI, the controlling authority for the said purpose. The functions to be performed in all the Undertakings are different and there exist separate contracts with the SNC to whom the software services are exported with respect to both the Undertakings separately. The first unit (Undertaking) is engaged into software development for element / network management systems, the second unit/undertaking is engaged into intelligent mobile gateway to provide support services & the third unit/undertaking is engaged into developing voice applications like voice instant messaging, push to talk, voice over IP etc. Regular invoices are raised from all these undertakings and the same are filed with the STPI vide Softex forms specifically stipulated for the said purpose. On the basis of these contractual undertakings and in light of the factual matrix, the present exercise is carried out."