Place of Effective Management residency: transitional rules set opening WDV, brought forward losses and carry forward treatment for newly resident foreign companies. When a foreign company becomes resident in India because its Place of Effective Management is in India and was not earlier resident, specified transitional rules apply: opening WDV and year-wise brought forward losses and unabsorbed depreciation are adopted from foreign tax records if assessed abroad or from books of account if not; such losses and depreciation are deemed brought forward and may be set off or carried forward only against income chargeable in India due to residency, with revisions allowed if foreign authorities change those figures.