Treatment of Wholly owned Subsidiary at foreign Land !!! Urgent

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  1. Hi Experts,
    I have some queries on Treatment prescribed under income Tax Act for WOS at Foreign Land.
    i will Elaborate via Example ,pls Refer below :-
    Co. XYZ Ltd. is resident company In India, now XYZ Company opens a wholly owned Subsidiary in Thailand Name XYZ (Thailand) Co. Ltd. Now this Thailand co. has its all control and management situated in India ,so it will considered as Resident Company for Income Tax purposes...Right ?(SEC 6(3))
    and if so than will all the provisions of Income Tax Act will be applicable to this Thailand company too ?? e.g. Section 44AA, 145A etc etc or is there anything else i missed ? it would be great if someone can share the book name wherein i can refer all the details i am looking for this case.

    Really Need your Inputs.

    Thanks !
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