Additional grounds raised in appeal needs adjudication by lower authority: ITAT Chennai

Regen Renewable Energy Generation Global Limited Vs ACIT (ITAT Chennai) ITAT Chennai restored the matter back to the file of AO for re-adjudication as additional ground raised by the assessee in appeal were not taken up before lower authorities. Facts- The assesse is a non-resident company incorporated, and fiscally domiciled, in Cyprus. AO noted that the assessee simply acted as an intermediary instead of RPPL who was ultimate beneficiary of such licensing agreement. Accordingly, the assessee was not the beneficial owner of royalties and therefore, the same was to be taxed in contracting stat...