2014 (12) TMI 61

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....Appeals assailing the following orders Tax Appeal No. Date of Tribunal's order ITA No. Assessment Year 31/2001 02.06.2000 5066/Ahd/1989 1983-84 306/2001 23.04.2001 5068/Ahd/1989 1985-86 59/2002 27.08.2001 1740/Ahd/1990 1986-87 81/2002 27.08.2001 1205/Ahd/1991 1987-88   These matters were admitted by this Court for consideration of the following substantial question of law:              Whether on the facts and in the circumstances of the case, the Income Tax Appellate Tribunal has substantially erred in law in deleting the addition made in respect of liability for purchasing gas from ONGC? 2. The assessee ....

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....dispute about the liability of the assessee. But the question was that of quantification of the liability. Differently put, the liability had accrued in the respective years which came to be quantified and crystallized by virtue of the Hon'ble Supreme Court deciding a price. The Tribunal was of the view that uncertainty and difficulty or the pendency of litigation relating to estimation or the pendency of litigation relating to estimation of the purchase price or fixing of purchase price would not convert the accrued liability into a contingent liability and since there remained no uncertainty or difficulty in estimation of the amount of such liability which had accrued in the respective assessment years of supply of Gas, the deducti....