The Indian Income Tax Appellate Tribunal (ITAT) delivered a ruling dated 31 May 2007 (reported in September 2007) in the case of Radha Rani Holdings (P) Ltd v. Assistant Director of Income Tax, International Taxation (16 SOT 495) on whether the residential status of a foreign company could change to that of a "resident" of India, if a resident of India holds a 99% stake in the foreign company. (a) Facts. The Taxpayer (i.e. Radha Rani Holdings (P) Ltd) was a Singaporean company and filed its tax return in India as a "non-resident" company. The tax authorities noticed that 99%...