ITAT won't deal with issues not raised before it; ITAT denied to answer question of 'royalty' not ra

IT/ILT: Where Tribunal remanded matter back to Assessing Officer for deciding question of existence or otherwise of PE of assessee in India so as to determine taxability of payment under distribution assessment as 'business profits' since revenue did not raise a ground before Tribunal regarding treatment of payment in question as royalty or FTS, there could have been no point in rendering any decision on said issue and, thus, impugned remand order did not require any rectification