https://www.taxtmi.com/caselaws?id=179727 A body corporate incorporated outside India qualifies as a company under the Income-tax Act only if it is incorporated under foreign law; a UAE sole proprietorship with no corporate status was not a company and could not invoke the advance ruling mechanism on that basis. Residence under section 6(1)(a) depends on physical presence in India during the previous year, with both entry and exit days counted. On that test, the applicant exceeded 182 days in India and was resident, not non-resident, during the relevant year, so it was ineligible to maintain an application under section 245Q(1). en-us Thu, 08 Feb 1996 00:00:00 +0530 Tue, 08 Mar 2016 18:20:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=179727 A body corporate incorporated outside India qualifies as a company under the Income-tax Act only if it is incorporated under foreign law; a UAE sole proprietorship with no corporate status was not a company and could not invoke the advance ruling mechanism on that basis. Residence under section 6(1)(a) depends on physical presence in India during the previous year, with both entry and exit days counted. On that test, the applicant exceeded 182 days in India and was resident, not non-resident, during the relevant year, so it was ineligible to maintain an application under section 245Q(1). Case-Laws Income Tax Thu, 08 Feb 1996 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=179727