Assessee had in an earlier year paid up an amount of Rs. 88,44,425 as sales tax liability which was refunded to it in the assessment year 2002-03 by virtue of a decision of the jurisdictional High Court. The assessee claimed that the sum had to be kept as a contingent liability since an appeal was pending before the Supreme Court. The Tribunal held that as and when and if the Supreme Court decided against the assessee, the assessee would be able to claim the amount again as expenditure. Dismissing the appeal of the assessee the Court held that sufficient safeguards had been made by the Tribunal and there was no reason to interfere with the directions of the Tribunal. (AY. 2002-03, 2003-04)