The Hon’ble ITAT consider it expedient to remit the matter back to the file of the Assessing Officer for taking into account the submissions made on behalf of the assessee. Where it is found as a matter of fact that the contingent liability in question do not form part of the P&L account and has not been taken into account while determining the income chargeable to tax, it will be incumbent upon Assessing Officer to reverse the disallowance carried out in the intimation under Section 143(1) in question. It shall be open to the assessee to adduce documents and explanations before the Assessing Officer in support of its contentions. Issue towards disallowance of contingent liabilities is restored back to the file of the Assessing Officer for fresh determination in accordance with law. (ITA  N0. 635/Del/2023 dt: 01/08/2023)