Assessee airline made provision for certain expenditures such as airport handling expenses, crew accommodation expense, IT communication charges and provision for certain other expenses .  Assessee had not deducted tax on source on above sum stating that it was an year end provision and payees were not identified and assessee was following accrual system of accounting . AO  held that as the assessee had made ascertained provision of expenditure and provision for expenditure was made under specified head thereby ascertaining amount , it could not be said that payee was not identified . Accordingly the Appellate Tribunal held that the assessee was required to be deducted at said year-end provisions towards expenditure made by assessee.  (AY. 2010 -11, 2011-12)