( 1 ) THE petitioner is a company incorporated under the U. K. Companies Act and has its principal place of business of India at Digboi in the State of Assam. It carries on business, inter alia, in oils and lubricants. In its assessment under the Indian Income-tax Act the petitioner claimed deduction of certain expenses as administrative charges incurred by the Burma Oil Company Ltd. of London as the London management fee payable by the petitioner and debited in its account. It appears that from the assessment year 1951-52, the question of allowance of this claim was being discussed between the petitioner and the taxing authority. For instance, in its letter dated the 20th February, 1953, to the Income-tax Officer, Dibrugarh, who was then making the petitioner's assessments to income-tax, it was explained that the London charges represented the charge made by the Burma Oil Company for management and secretarial work carried out on behalf of the petitioner in London and the charge was for certain services rendered by the London company. The said Income-tax Officer by his letter dated the 19th December, 1952, required the petitioner to furnish a schedule in respect of