Determination of nature of fees received by a foreign company from its Indian branch

RELEVANT PARAGRAPH 14.1 The undisputed fact which is confirmed by the learned counsel for the assessee, Shri Porus Kaka is that, no e-mail, correspondence, bill or any other documents or evidence pertaining to the impugned assessment year 2003-04 has been furnished or filed before the assessing officer during the assessment proceedings despite requests to do so. Shri Porus Kaka on this undisputed fact wants us to rely on the copy of the e-mail correspondence of 27-10-1997 of one Ms. Sonali Surajhita. For ready reference, the copy of the e-mail which is so heavily relied upon by Shri Porus Kaka...