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10.4 Zylog Systems Limited The Ld. AR submits that this comparable was rejected by the ITAT in assessee's own case for AY 2011-12 for functional difference i.e. revenue from consultancy services, license fee, projects and e-Governance and also for having in-house intangible difference in business model. The same has been confirmed by the Hon'ble Delhi High Court vide order dated 18.07.2017. This company is engaged in providing onsite services, specializes in providing software products and solutions and there is revenue from consulting, licensing fee, as well as from software products and solutions. There are diverse business activities such big data analytics, cloud computing etc. which requires owning large computing infrastructure. This company deals in software products therefore, it incurred high end product development cost. Besides this company also owns intangibles from which revenue is generated. The scale of operations is drastically high as can be seen from the operating income which is of Rs. 1219 crore.