President Carter's proposed "windfall profits" tax is fast becoming the center of a high-stakes battle in Congress over how to spend about $146 billion in revenues the measure is expected to bring in.

The skirmishing has pitted the White House in a four-way fight with the oil industry, liberals and Republicans, with each side pressing its own views of how the tax and its accompanying spending programs should be shaped.

The wrangling threatens to become more bitter.

The situation has its share of irony, because what created the struggle was not Carter's original decision to propose a tax, but the recent round of price hikes by the oil exporters' cartel.

When Carter unveiled his windfall proposal, the tax take seemed so slight that the plan was dismissed as a mere political gesture, designed to blunt any voter resentment to his move to decontrol crude oil prices.

Between now and 1990, the tax was to raise only around $20 billion.

But that was when the administration was figuring oil prices at $16 a barrel - the price in effect in April, when Carter announced his decision to lift oil price controls.

Since then, crude oil prices have soared to more than $20 a barrel, and the potential tax take from the windfall measure has leaped to $146 billion - with even higher totals likely if the oil cartel raises prices more rapidly.

Suddenly, the windfall tax has become Carter's magic money machine - easily capable of financing his massive new $88 billion synthetic fuels program, mass transit grants and anything else you ever dreamed of.

And, like any new money source, it's become the object of a congressional free-for-all on how to divide the take.

The White House wants to use the money solely for Carter's new energy trust fund. Liberals want to increase aid to the poor. Republicans want to finance an across-the-board cut in income taxes.

Others want to roll back Social Security taxes or use the money for mandatory conservation programs. And those are just the serious proposals.The question hasn't yet been thrown open to the floor.

The revenue seekers may be somewhat disappointed when the windfall monies come flowing into the Treasury's coffers.

For one thing, the $146 billion to which Carter keeps referring represents the gross revenues the new tax would produce, not the net money the tax would add to the Treasury.

The disparity arises because the windfall tax actually is an excise tax, which would be deductible in figuring corporate income taxes. It therefore would reduce any income tax the industry would pay on added earnings.

With this factor taken into account, the net gain in revenues resulting from the windfall tax would be only about $106 billion during the 1980-1990 period, rather than $146 billion.

The rest of the $142 billion Carter says he needs for his synfuels and other energy programs would come by earmarking part of the regular corporate income tax to finance the energy trust fund.

For another thing, the windfall tax passed by the House may be trimmed back sharply by the Senate Finance Committee, leaving Carter with substantially less in new revenues than even the net figures would show.

Both liberals and conservatives on the panel fear the House-approved proposal would discourage the industry from investing heavily in new production, and they're planning to exempt more categories of oil to provide extra incentives.

The problem is that while the changes may spur more production, they also could strip the bill of most of its revenue-raising capability, leaving Carter far short of what is needed to finance his energy program.

The president has served notice he'll cut back his synfuels effort if he can't get enough money from the windfall tax Congress passes.

But some estimates show that if the Senate panel goes ahead with all it is planning, it could slash the $146 billion gross revenues figure by between $45 billion and $118 billion - possibly leaving as little as $28 billion or new spending.

Observers say that at a minimum the panel is likely to exempt from the tax newly discovered oil and hard-to-get-at "tertiary" oil. But there is pressure for further exemptions. Carter may face a major fight.

The oil industry also has shifted its position. Earlier, with the tax bite apparently so small, the oil companies were almost passive on the issue, presenting little more than lip service opposition.

Now, however, with unexpectedly strong sympathy in the Finance Committee, the industry has stepped up its attack. How much influence it ultimately will have on the floor remains to be seen.

Carter has one sleeper in this whole affair - the revenues he may reap as a result of the quotas imposed on foreign oil imports earlier this month as part of his July 15 energy announcements.

When the import restrictions finally begin biting, the administration will have to parcel out individual import limitations for each of the domestic oil refiners - a must for maintaining order in the face of overall quotas.

This would be done by auction, a procedure that could net the government billions of dollars in added revenues. But that won't come until 1984 or later. And there may be a further battle over how that money should be used.

The battle over how to spend the windfall money is expected to be fought first in the House Ways and Means Committee, which starts work this week on proposals for new energy tax credits.

The administration also had planned to submit a proposal for using some of the windfall revenues for aid to the poor, but strategists so far have been unable to agree on the mechanics. The White House may move this week.

But the real skirmish will come in the Senate, first over how stiff to make the windfall tax and then over what to do with the new money. It is there that Carter faces his most serious challenge.

As the president conceded last week, without the new windfall tax, he can't have the massive synfuels program he wants, and the scrambling over other parts of Carter's energy program will have been in vain.

The fear by some onlookers is that the coming weeks' fight may blow up in the administration's face, and the public's as well.

If the various factions are unable to agree on the individual issues, the whole tax, and its accompanying energy programs, could be lost.

That's the scope of the stakes now on the congressional table.