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32. Regarding the third ground the learned Counsel for the assessee submitted that Section 43B stipulates that irrespective of the method of accounting followed by the assessee, any sum payable by way of taxes, duties, cess, etc. shall be allowed as a deduction in the previous year in which it is actually paid by the assessee. The fact of the assessee here is that the excise duty liability was in dispute and the payment of the disputed liability has been disclosed in the accounts which was available with the AO at the time of framing the assessment. The lower authorities refused to entertain the claim for the reason that it was only claimed during the course of assessment before learned AO and not through valid revised return.