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        The ITAT set aside and restored multiple issues to the file of the AO. The DRP's LIBOR+350 bps rate is held prima facie appropriate, but the AO is directed to require the assessee to benchmark the outstanding receivable by reference to the currency of invoicing and to determine ALP of the international transaction under s.92CA, applying suitable mark-up or reduction for transaction-specific risk; the assessee may argue working-capital adjustments for software/ITeS segments. A double addition made at s.143(1) and again in the final order is to be deleted. The AO must use the disclosed book profit of Rs.118,10,19,785 for s.115JB computation. Donations qualify for deduction under s.80G; AO to allow.

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