Supreme Court held that to be a domicile in India, registration of company is not at all relevant and determinate test is where sole right to manage and control of company lies. Order of High Court is affirmed Review petition is dismissed. (AY. 1987-88 to 1989-90)
Mansarovar Commercial (P.) Ltd. v. CIT (2023) 294 Taxman 513 (SC) Editorial : Mansarovar Commercial (P.) Ltd. v. CIT (2023) 453 ITR 661/ 293 Taxman 312 (SC).
S. 37(1) : Business expenditure-Commission-Residence – Company – Control And Management -Assessee-Companies Registered In Sikkim-Burden not discharged-Round tripping of funds-Liable to tax in India. [S. 2(35), 5, 6(3)(ii), 131, 142(1), 143(2), 148, 234A, 282]