Recently, Hon’ble Supreme Court of India (‘the Hon’ble SC’) has pronounced the ruling in the case of Mansarovar Commercial Pvt Ltd vs Commissioner of Income-tax, Delhi, wherein it has been held that a company’s residential status is based on the company’s de-facto control and management. Control and management mean not merely theoretical control and power, i.e., not de jure control and power, but de facto control and power actually exercised