The assessee claimed deduction of  expenses which was disallowed by the Assessing Officer on the ground that  the assessee had not deducted tax at source as per section 40(a) of the Act. On appeal the CIT(A) dismissed the appeal and confirmed the addition by adopting a reasoning which is different from the Assessing Officer  on the basis that the assessee was unable to produce evidence to show that the expenditure has been incurred wholly and exclusively for the purpose of business and no evidence was produced. On appeal the Tribunal held that by adopting different reasoning than that of Assessing Officer  there is violation of right of limited finality.  Order  was set aside to the Assessing Officer for fresh order as per law after providing reasonable opportunity of hearing. (AY.  2010-11, 2011-12, 2012-13)