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4. On the other hand, the ld. DR for the revenue supported the order of lower authorities. The ld. DR submits that the assessee-company provides IT Solutions like managed hosting, cloud computing, collocation, Network connectivity and IT consulting supported by assessee's global data centre. The assessee delivers IT Infrastructures as services by combining cloud technology, a global network 50 data centre in North America, Europe and Asia automatic management and provisioning system and a best practices operation model. The ld. CIT(A) while passing the impugned order, the actual nature of services ITA No. 3968/Mum 2017- M/s SAVVIS Communications, LLC rendered by assessee and its clients. From the order of ld. CIT(A), it is clear that while passing the order for earlier years the relevant parts of the agreement were not brought to the notice of Tribunal, which clearly demonstrate that it is not for the assessee which is providing services using its own equipment but equipment itself are being provided in the premises of customer, which, in term, remain at beck and call of the user. The assessee not only uses its highly sophisticated equipment to render services but such right to use is given to the client, who directly uses the equipments capabilities. Once, the web hosting rights are given to the clients, the clients have direct access to these facilities. The ld. DR further submits that the bench has based its observation on wrong set of facts contained in the order of ld. CIT(A). The ld. DR for the revenue further refers various clauses of service agreement recorded by ld. CIT(A) in para-6.2 of its order and would submit that the assessee is offering comprehensive package of software and hardware system which remain at the beck and call of the client. The assessee is in possession of various equipment and associated technology, software and high speed access, which together, result in replacement of client's infrastructure with the infrastructure provided by the assessee. The ld. DR explained that when these facilities grouped together, for which the assessee also undertake security and management responsibility, which is known as hosting services. This includes server, cloud space, internet access, ITA No. 3968/Mum 2017- M/s SAVVIS Communications, LLC security procedure etc. and desired software for use of client. The maintenance of these equipments is carried out by assessee so as to ensure data security as well as for operational purpose. The entire set up at the contracted level of bandwidth or cloud space is in possession of the client with the assessee having obligation to facilitate the clients use. While providing infrastructure as a service there cannot be any suppression between the software and hardware. Both are integrated together and offered as a whole. The client needs the cloud space at all the times as well as data availability of the software at beck and call. The clients is not bothered about the location of data center or rack space, therefore, the claim of assessee that it render certain hosting services for use of equipment is incidental is not acceptable.