Right of 'limited finality' violated if reasoning adopted by CIT(A) for dismissing appeal not considered at assessment

INCOME TAX : Where AO disallowed payment made by assessee towards reimbursement of expenses to its US based subsidiary on ground that said subsidiary had already taken allowance of such expenses incurred by it and CIT (Appeals) also upheld same, however, on completely different reasoning that assessee failed to prove that such expenses were incurred by it wholly and exclusively for business purposes, since assessee got no opportunity to make submission before AO on such reasoning adopted by CIT

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