This new Chinese TEL chassis looks remarkably similar to the 9K331 Tor M1 -- The Chinese edition sports a rectangular headlight, where as the Russian Tor M1 is illuminated by the classic round.
In 1999 the PLA ground force armed its Air Defense Brigade, 31st Group Army, Nanjing MR with 35 sets of imported Tor M1 Air Defense systems. However, the follow-up negotiation for a co-produced variant yielded no fruit. The PLA reportedly has a requirement for 160 additional systems.
It is easy to start speculating with this set of photos but it is not warranted without any additional evidence.
Notice the rectangular headlight and new rubbered road wheels.
The rounded headlight of the Tor M1 currently in service with 31st Group Army's AD Brigade.