i think there is also a subtler form of "topping from the bottom" in manipulation. some subs may say and do the seemingly right submissive things. but they try to manipulate and control their Master or Mistress through bad behavior.
they desire attention and/or punishment. and by pretending to be disobedient, they manipulate their Master into giving them what they want.
i see this as undermining the control of a Master and disrupting the flow of the relationship and connection. if my Master is constantly having to correct my behavior then he is not the one controlling the relationship and i am not truly submitting.
every sub makes mistakes and sometimes struggles with disobedience. but a sub that is constantly disobeying is trying to fill their own needs for their own pleasure. that is not fulfilling to both partners in this relationship.
when i truly surrender, Master is free to lead and take more control... honest control.
when i manipulate, it is like stealing that control away from him. and it is not an honest submission at all.