BEFORE THE DELHI INTERNATIONAL ARBITRATION CENTRE

IN THE MATTER OF ARBITRATION

CASE NO. DAC/2491D/0719

IN THE MATTER OF:

SARR FREIGHT CORPORATION ….CLAIMANT

VS

BHARAT HEAVY ELECTRICALS LTD. (TRICHY) ....RESPONDENT

INDEX

S. No Particulars Page no.

1. Affidavit Of Admission / Denial Of Opposite Parties

Documents.

Filed Through:

Place: New Delhi

Suraj Kumar Singh

Dated: 11.02.2021 AMS & Partners
Advocates & Legal Consultant
17 LGF, Jangpura Extension
Market, New Delhi- 110014
Mob: 9810329829
Email: advocatesuraj13@gmail.com
 BEFORE THE DELHI INTERNATIONAL ARBITRATION CENTRE

IN THE MATTER OF ARBITRATION

CASE NO. DAC/2491D/0719

IN THE MATTER OF:

SARR FREIGHT CORPORATION ….CLAIMANT

VS

BHARAT HEAVY ELECTRICALS LTD. (TRICHY) ....RESPONDENT

AFFIDAVIT OF ADMISSION / DENIAL OF DOCUMENTS BY BHEL (CLAIM &

COUNTER CLAIM)

I, Mr. Venkatesh, authorized representative of the Respondent, who has been

authorized vide the letter of authorization by the head of the unit, BHEL Trichy

inter alia to contest the present case, do hereby solemnly admit/deny the

docments filed by the Claimant which are as follows:-

Sr. No. Documents Marking Pg. No. Admission/Denial

1. Copy of MSME Registration of the 1 Not submitted

claimant. while participating
in the tender.
2. Copy of the notice inviting tender 2-25 Admitted
dt. 26.07.2014.
3. Copy of the bid submitted by the 26-31 Admitted
claimant on 07.08.2014.

4. Copy of the Corrigendum. 32 Admitted

5. Copy of Email dt. 22.08.2014 33-35 Receipt admitted,
content denied

6. Copy of letter of intent. 36-39 Admitted

7. Copy of the Email dt. 11.09.2014 40 Admitted

by the respondent to the claimant.

8. Copy of the Email dt. 12.09.2014 41 Admitted

by the respondent to the claimant.

9. Copy of the Bank Guarantee dt. 42-45 Admitted

13.09.2014
10. Copy of the invoice no. 46-48 Denied as not
Sarr/Detention/2-14-15/0002 received.
dated 30.10.2014
11. Copy of the invoice number: 49-51 Denied as not
Sarr/Detention/2014-15/0002 received.
dated 30.10.2014
12. Copy of the Invoice No. 52 Received and paid
Sarr/TPT/2014-15/0016 dated an amount of Rs.
30.10.2014 18, 30,220/-.
13. Copy of the Email dated 10.10.2014 53 Admitted to the
by the claimant to Mr. Anuj Kumar extent that the
work was sub-
contracted to Mr.
Anuj Kumar
14. Copy of the Email dated 23.09.2014 53 Admitted to the
and 23.09.2014 by the claimant to extent that the
Mr. Anuj Kumar work was sub-
contracted to Mr.
Anuj Kumar
15. Copy of the letter dated 31.10.2014 54 Admitted -
by the claimant to the respondent. Security Deposit
16. Copy of the letter dated 08.11.2014 55 Admitted – RTGS
by the claimant to the respondent. form
17. Copy of the letter dated 10.11.2014 56-61 Receipt admitted
at site, content
denied
18. Copy of Email dated 10.11.2014 62 Receipt admitted
content denied.
19. Copy of the letter dated 11.11.2014 63-64 Denied as not
by the claimant to the respondent. received.
20. Copy of the Email dated 27.11.2014 65-66 Receipt admitted
by the claimant to the respondent. content denied
21. Copy of the letter dated 27.11.2014 67-68 Denied as not
to the respondent received.

22. Copy of the Email dated 01.12.2014 69 Receipt admitted

between the parties. content denied.
23. Copy of the email dated 28.11.2014 69-70 Receipt admitted
from the claimant to the content denied.
Respondent
24. Copy of the Email dated 22.12.2014 71 Admitted
from the Respondent to the
Claimant
25. Copy of the Email dated 27.11.2014 72-73 Receipt admitted
from the Claimant to the content denied.
Respondent
26. Copy of the Email dated 20.12.2014 74 Receipt admitted
from the Claimant to the content denied
Respondent
27. Copy of the Email dated 26.03.2015 75 Receipt admitted
from the Claimant to the content denied
Respondent
28. Copy of the Email dated 23.03.2015 75 Receipt admitted
from the Claimant to the content denied
Respondent
29. Copy of the Email from the 76-78 Denied as no
respondent to the claimant dated document is found
21.03.2015 in the set
30. Copy of the Email dated 30.07.2015 79 Admitted
from the Respondent to the
Claimant
31. Copy of the Email dated 07.04.2015 80 Admitted
from the Respondent to the
Claimant
32. Copy of the Email dated 06.04.2015 80 Admitted
from the Respondent to the
Claimant
33. Copy of the Email dated 04.04.2015 81 Receipt admitted
from the Claimant to the content denied
Respondent
34. Copy of the Email dated 04.04.2015 81 Admitted
from the Respondent to the
Claimant
35. Copy of the Email dated 02.04.2015 82 Receipt admitted
from the Claimant to the content denied
Respondent
36. Copy of the Email dated 06.08.2015 83 Receipt admitted
from the Claimant to the content denied
Respondent
37. Copy of the Email dated 03.08.2015 83 Admitted
from the Respondent to the
Claimant
38. Copy of the Email dated 29.07.2015 84-85 Receipt admitted
from the Claimant to the content denied
Respondent
39. Copy of the Email dated 12.08.2015 86 Admitted
from the Respondent to the
Claimant
40. Copy of the Email dated 12.08.2015 87 Receipt admitted
from the Claimant to the content denied
Respondent
41. Copy of the Email dated 19.08.2015 88-89 Receipt admitted
from the Claimant to the content denied
Respondent
42. Copy of the Email dated 22.08.2015 90 Receipt admitted
from the Claimant to the content denied
Respondent
43. Copy of the Email dated 26.08.2015 91-92 Receipt admitted
from the Claimant to the content denied
Respondent
44. Copy of the Email dated 30.07.2015 93 Receipt admitted
from the Claimant to the content denied
Respondent
45. Copy of the Email dated 29.07.2015 94 Receipt admitted
from the Claimant to the content denied
Respondent
46. Copy of the Email dated 10.07.2015 95 Receipt admitted
from the Claimant to the content denied
Respondent
47. Copy of the Email dated 10.07.2015 96 Admitted
from the Respondent to the
Claimant
48. Copy of the Email dated 02.07.2015 97-99 Receipt admitted
from the Claimant to the content denied
Respondent
49. Copy of the Email dated 26.06.2015 100 Receipt admitted
from the Claimant to the content denied
Respondent
50. Copy of the Email dated 25.06.2015 100 Receipt admitted
from the Claimant to the content denied
Respondent
51. Copy of the Email dated 23.06.2015 101 Receipt admitted
from the Claimant to the content denied
Respondent
52. Copy of the Email dated 18.06.2015 102 Receipt admitted
from the Claimant to the content denied
Respondent
53. Copy of the Email dated 17.06.2015 103 Receipt admitted
from the Claimant to the content denied
Respondent
54. Copy of the Email dated 16.06.2015 103 Receipt admitted
from the Claimant to the content denied
Respondent
55. Copy of the Email dated 15.06.2015 104 Receipt admitted
from the Claimant to the content denied
Respondent
56. Copy of the Email dated 13.06.2015 105 Receipt admitted
from the Claimant to the content denied
Respondent
57. Copy of the Email dated 12.06.2015 105 Receipt admitted
from the Claimant to the content denied
Respondent
58. Copy of the Email dated 10.06.2015 106 Receipt admitted
from the Claimant to the content denied
Respondent
59. Copy of the Email dated 09.06.2015 107 Receipt admitted
from the Claimant to the content denied
Respondent
60. Copy of the Email dated 06.06.2015 107 Receipt admitted
from the Claimant to the content denied
Respondent
61. Copy of the Email dated 05.06.2015 108 Receipt admitted
from the Claimant to the content denied
Respondent
62. Copy of the Email dated 04.06.2015 109 Receipt admitted
from the Claimant to the content denied
Respondent
63. Copy of the Email dated 02.06.2015 109 Receipt admitted
from the Claimant to the content denied
Respondent
64. Copy of the Email dated 30.05.2015 110 Receipt admitted
from the Claimant to the content denied
Respondent
65. Copy of the Email dated 29.05.2015 111 Receipt admitted
from the Claimant to the content denied
Respondent
66. Copy of the Email dated 27.05.2015 111 Receipt admitted
from the Claimant to the content denied
Respondent
67. Copy of the Email dated 26.05.2015 112 Receipt admitted
from the Claimant to the content denied
Respondent
68. Copy of the Email dated 25.05.2015 113 Receipt admitted
from the Claimant to the content denied
Respondent
69. Copy of the Email dated 23.05.2015 113 Receipt admitted
from the Claimant to the content denied
Respondent
70. Copy of the Email dated 20.05.2015 114 Receipt admitted
from the Claimant to the content denied
Respondent
71. Copy of the Email dated 19.05.2015 115 Receipt admitted
from the Claimant to the content denied
Respondent
72. Copy of the Email dated 18.05.2015 115 Receipt admitted
from the Claimant to the content denied
Respondent
73. Copy of the Email dated 15.05.2015 116 Receipt admitted
from the Claimant to the content denied
Respondent
74. Copy of the Email dated 14.05.2015 117 Receipt admitted
from the Claimant to the content denied
Respondent
75. Copy of the Email dated 12.05.2015 118 Receipt admitted
from the Claimant to the content denied
Respondent
76. Copy of the Email dated 11.05.2015 118 Receipt admitted
from the Claimant to the content denied
Respondent
77. Copy of the Email dated 09.05.2015 119 Receipt admitted
from the Claimant to the content denied
Respondent
78. Copy of the Email dated 02.05.2015 120 Receipt admitted
from the Claimant to the content denied
Respondent
79. Copy of the Email dated 01.05.2015 120 Receipt admitted
from the Claimant to the content denied
Respondent
80. Copy of the Email dated 30.04.2015 121 Receipt admitted
from the Claimant to the content denied
Respondent
81. Copy of the Email dated 29.04.2015 122 Receipt admitted
from the Claimant to the content denied
Respondent
82. Copy of the Email dated 17.04.2015 122-123 Admitted (The
from the Claimant to the email sent by the
Respondent Respondent to the
Claimant)
83. Copy of the Email dated 16.04.2015 124 Receipt admitted
from the Claimant to the content denied
Respondent
84. Copy of the Email dated 15.04.2015 124 Receipt admitted
from the Claimant to the content denied
Respondent
85. Copy of the Email dated 13.04.2015 125 Receipt admitted
from the Claimant to the content denied
Respondent
86. Copy of the Email dated 11.04.2015 126 Receipt admitted
from the Claimant to the content denied
Respondent
87. Copy of the Email dated 10.04.2015 126 Receipt admitted
from the Claimant to the content denied
Respondent
88. Copy of the Email dated 08.04.2015 127 Receipt admitted
from the Claimant to the content denied
Respondent
89. Copy of the Email dated 07.04.2015 128 Receipt admitted
from the Claimant to the content denied
Respondent
90. Copy of the Email dated 06.04.2015 128 Receipt admitted
from the Claimant to the content denied
Respondent
91. Copy of the Email dated 04.04.2015 129 Receipt admitted
from the Claimant to the content denied
Respondent
92. Copy of the Email dated 02.04.2015 130 Receipt admitted
from the Claimant to the content denied
Respondent
93. Copy of the Email dated 26.03.2015 130 Receipt admitted
from the Claimant to the content denied
Respondent
94. Copy of the Email dated 23.03.2015 131 Receipt admitted
from the Claimant to the content denied
Respondent
95. Copy of the Email dated 21.03.2015 132 Admitted
from the Claimant to the
Respondent
96. Copy of the Email dated 21.03.2015 132 Denied as no
from the Respondent to the document is found
Claimant in the set
97. Copy of the Email dated 20.03.2015 133 Admitted to the
from the Respondent to the extent that Mr.
Claimant Anuj had nexus
with the Claimant
 rest of the content
denied
98. Copy of the Email dated 20.03.2015 134 Admitted
from the Respondent to the
Claimant
99. Copy of the Email dated 14.03.2015 135 Receipt admitted
from the Claimant to the content denied
Respondent
100. Copy of the Email dated 07.03.2015 135 Receipt admitted
from the Claimant to the content denied
Respondent
101. Copy of the Email dated 04.03.2015 136 Receipt admitted
from the Claimant to the content denied
Respondent
102. Copy of the Email dated 03.03.2015 137 Receipt admitted
from the Claimant to the content denied
Respondent
103. Copy of the Email dated 02.03.2015 138 Receipt admitted
from the Claimant to the content denied
Respondent
104. Copy of the Email dated 28.02.2015 138 Receipt admitted
from the Claimant to the content denied
Respondent
105. Copy of the Email dated 27.02.2015 139 Receipt admitted
from the Claimant to the content denied
Respondent
106. Copy of the Email dated 26.02.2015 140 Receipt admitted
from the Claimant to the content denied
Respondent
107. Copy of the Email dated 25.02.2015 141 Receipt admitted
from the Claimant to the content denied
Respondent
108. Copy of the Email dated 18.02.2015 142 Receipt admitted
from the Claimant to the content denied
Respondent
109. Copy of the Email dated 17.02.2015 143 Receipt admitted
from the Claimant to the content denied
Respondent
110. Copy of the Email dated 14.02.2015 144 Receipt admitted
from the Claimant to the content denied
 Respondent

111. Copy of the Email dated 13.02.2015 144 Receipt admitted

from the Claimant to the content denied
Respondent
112. Copy of the Email dated 11.02.2015 145 Receipt admitted
from the Claimant to the content denied
Respondent
113. Copy of the Email dated 09.02.2015 146 Receipt admitted
from the Claimant to the content denied
Respondent
114. Copy of the Email dated 06.02.2015 147 Receipt admitted
from the Claimant to the content denied
Respondent
115. Copy of the Email dated 05.02.2015 148 Receipt admitted
from the Claimant to the content denied
Respondent
116. Copy of the Email dated 04.02.2015 149 Receipt admitted
from the Claimant to the content denied
Respondent
117. Copy of the Email dated 03.02.2015 150 Receipt admitted
from the Claimant to the content denied
Respondent
118. Copy of the Email dated 02.02.2015 150 Receipt admitted
from the Claimant to the content denied
Respondent
119. Copy of the Email dated 31.01.2015 151 Receipt admitted
from the Claimant to the content denied
Respondent
120. Copy of the Email dated 30.01.2015 152 Receipt admitted
from the Claimant to the content denied
Respondent
121. Copy of the Email dated 29.01.2015 153 Receipt admitted
from the Claimant to the content denied
Respondent
122. Copy of the Email dated 27.01.2015 154 Receipt admitted
from the Claimant to the content denied
Respondent
123. Copy of the Email dated 23.01.2015 155 Receipt admitted
from the Claimant to the content denied
 Respondent

124. Copy of the Email dated 21.01.2015 155 Receipt admitted

from the Claimant to the content denied
Respondent
125. Copy of the Email dated 10.01.2015 156 Receipt admitted
from the Claimant to the content denied
Respondent
126. Copy of the Email dated 08.01.2015 157 Receipt admitted
from the Claimant to the content denied
Respondent
127. Copy of the Email dated 04.03.2017 158 Receipt admitted
from the Claimant to the content denied
Respondent
128. Copy of the Legal Notice from 159-165 Receipt admitted
December 2015 content denied

DEPONENT

VERIFICATION

Verified at New Delhi on ____ day of February, 2021 that the contents of the

above affidavit are true and correct to the best of my knowledge and belief and

that no part of it is incorrect and nothing material has been concealed

therefrom.

DEPONENT