MADAN B. LOKUR, J. ( 1 ) THE Assessee entered into an agreement on 24th July, 1991 with the rajasthan State Road Transport Corporation for supply of cold process retreading plant and retreading material for retreading the old tyres of the buses of the corporation. ( 2 ) SOME disputes arose between the Assessee and the Corporation with the result that they were referred to the Chairman of the Corporation for arbitration. ( 3 ) ON 4th April, 1997, the Chairman gave his Award but since that was not acceptable to the Assessee, objections were filed under Sections 30 and 33 of the Arbitration Act, 1940 before the District Judge, Jaipur. ( 4 ) BY an order dated 22nd November, 1999, the District Judge dismissed the objections and the Award was made a rule of the Court. ( 5 ) ACCORDING to the Assessee, a contingent liability had arisen on 4th april, 1997 (the date of the Award) and on this basis, a claim of deduction was made by the Assessee. This was not accepted by the Assessing Officer who held that the liability arose on the date when the Award was made a rule of the court, that is, 22nd November, 1999. ( 6 ) THE view taken by the Assessing Officer was reversed by the commissioner of Income Tax (Appeals) who held that the liability had accrued on 4th April, 1997. ( 7 ) IN further appeal, the Income Tax Appellate Tribunal accepted the view of the Assessing Officer. ( 8 ) ON these broad facts, we are of the view that a substantial question of law arises for consideration. Accordingly, we admit this appeal and frame the following substantial question of law: "whether on the facts and in the circumstances of the case, the Income Tax appellate Tribunal was correct in law in holding that it is the date on which the Award was made a rule of the Court (22nd November, 1999) and not the date of the Award (4th April, 1997) that should be taken into consideration for the accrual of the liability of the Assessee to the Rajasthan State Road Transport corporation for the purpose of Section 37 (1) of the Income Tax Act, 1961. " Filing of the paper books is dispensed with.