https://www.taxtmi.com/caselaws?id=464023 HC held the foreign-incorporated assessee to be taxable as an Indian resident since the AO's findings under Section 6(3)(ii) established control and management directed from India, though the CIT(A) noted the board members were non-resident. The court also found the assessee to be an "eligible assessee" under Section 144C(15)(b) (incorporated in BVI), and therefore the AO was required to follow the statutory dispute-resolution procedure prescribed under Section 144C of the Act. en-us Mon, 02 Dec 2024 00:00:00 +0530 Fri, 26 Sep 2025 20:09:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464023 HC held the foreign-incorporated assessee to be taxable as an Indian resident since the AO's findings under Section 6(3)(ii) established control and management directed from India, though the CIT(A) noted the board members were non-resident. The court also found the assessee to be an "eligible assessee" under Section 144C(15)(b) (incorporated in BVI), and therefore the AO was required to follow the statutory dispute-resolution procedure prescribed under Section 144C of the Act. Case-Laws Income Tax Mon, 02 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464023