The Treasury Department's Bureau of Alcohol, Tobacco and Firearms, whose rescission of an ingredient labeling requirements for beer, wine and distilled spirits was invalidated earlier this year by a District Court judge, has proposed to take the same action again.

In its proposal, the agency said it is "not convinced that the conclusions" of the Carter administration, which was going to require liquor ingredients to be labeled starting in January, 1983, were justified.

Shortly after President Reagan took office, the department proposed rescinding the rules and made its proposal final in November, 1981.

The court ruled, according to the BATF's Federal Register notice, that "the department . . . failed to provide an adequate explanation for its decision to rescind."

The BATF is appealing that ruling, but, according to Imelda M. Kirk, "we are renewing rule-making process in light of deficiencies pointed out by the court." By "pointing the direction of our eventual decision," she said, "we would get better comments." She added that the proposal would not necessarily represent the department's final decision on the issue.

"They're just grasping at straws to stave off a very useful consumer protection measure," said Michael Jacobson of the Center for Science in the Public Interest, which has led the battle for labeling requirements. The center contends labels promote informed consumer choices and protect people who might have adverse reactions to certain additives.