(b) That's wrong. The words 'in trade or commerce' are defined in section 2(1) of the ACL. The phrase includes "any business or professional activity (whether or not carried on for profit)". It covers trade or commerce within Australia, as well as trade or commerce between Australia and places outside of Australia.
This definition is consistent with what the courts have said about the meaning of the phrase, that conduct takes place 'in trade or commerce' when it involves selling or dealing, particularly for business purposes or as a livelihood.
In the present case, the leasing transaction clearly takes place in the course of A Pty Ltd's business and the director's statements are certainly made 'in trade or commerce'.