On the contention that the sale concludes in India, Mr. Dastur argued that the Revenue has once again relied on the agreement between the OEM (i.e. Motorola) and Tata dated 8.12.2007 to say that since the OEM is to bear the cost of packing/loading/unloading, transportation, carriage, freight, unloading charges, insurance and any other cost or any nature at any time prior to delivery, therefore the