ITAT remanded matter as assessee got no opportunity to make submission in respect of reasoning adopted by CIT(A)

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 CITINCOME 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 CITwww.taxmann.com Latest Case LawsRead More

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