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    <description>Place of effective management in India was not established where the factual bases relied on for residential status were not supported by the documentary record. The appellate authority noted that the earlier view of a three-member collegium had been followed, but the underlying factual foundation remained unsound and unrebutted. On that basis, the finding that the company was resident in India for the relevant year could not be sustained, and the addition of its global income was liable to be deleted.</description>
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