Company's Residential Status Based on De Facto Control

Recently, Hon’ble Supreme Court of India (‘the Hon’ble SC’) has pronounced the ruling in the case of Mansarovar Commercial Pvt Ltd vs Commissioner of Income-tax, Delhi, wherein it has been held that a company’s residential status is based on the company’s de-facto control and management. Control and management mean not merely theoretical control and power, i.e., not de jure control and power, but de facto control and power actually exercised