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16. Persistent is constantly innovating new technology solutions that are focused on the four key building blocks of their IP portfolio, Cloud Computing, BI & Analytics, Collaboration and mobility. Persistent has also customized end to end solutions as per their specific requirement. Perusal of Profit & Loss account, available at page 495 of Paper Book - I, shows that Persistent has ITA No.2744/Del./2017 ITA No.594/Del./2017 sale of software services and products with no segmental data. The ld. DR for the Revenue contended that the taxpayer has failed to point out as to which product has been developed. But this contention is not tenable in the face of the P&L account which shows the income jointly from sale of software services and product.