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13. The learned AO/TPO/DRP have erred by not making suitable adjustments to account for differences in the risk profile and working capital employed by the Appellant vis-a-vis the comparable companies.

Corporate Tax ground :

14. The learned AO/DRP have erred in disallowing payment made by the Appellant to Adobe USA on account of connectivity charges for delivery of computer software outside India, under the provisions of section 40(a)(i) of the Income Tax Act, 1961.

The Appellant craves leave to add, amend, vary, omit or substitute any of the aforesaid grounds of appeal at any time before or at the time of hearing of the appeal.

The Appellant prays for appropriate relief based on the said grounds of appeal and the facts and circumstances of the case."

2. Ground nos. 1 to 11 relate to the determination of Arm's Length Price (ALP) of the international transactions entered by the assessee. The facts culled out from the record in this regard are that the assessee company is engaged in development of software in various stages like engineering, research, development, debugging, coding, quality control checks, testing application, designing and programming and is exporting its services to M/s Adobe Systems Inc., USA and to M/s Adobe Systems Software, Ireland.