SC ruling on determining management and control for residency of a company

Mansarovar Commercial Pvt. Ltd. Vs CIT (Supreme Court of India) Sub- What is the meaning of management and control for the purpose of determining residency of a company? Whether simply registered office of a company can be the criterion ? The Supreme Court in this case was considering interesting question as to taxability of alleged commission earned prior to the year 1990(whereafter the Income-tax Act,1961 was amended and income earned in Sikkim became taxable under the Act subject to certain exemptions) which was shown to have been earned in Sikkim and thus taxable as per Sikkim Mannual 1948...