Make-to-Order customer Return Order triggers unwanted ATP check

When executing a return delivery on a Make-to-Order (Strategy 20, no APO) material, we notice that the ATP check (checking rule BE) gets triggered.  On a return this makes no sense  and of course fails, stopping us from creating the delivery. How can we prevent that?
Strat. 20 has Req.type KE & Req.Class 040 with the Availability Check flagged, but returns should not trigger an ATP check and therefore the  SLCat is unflagged as such ("Define Procedure for  each schedule line category"), but that seems to be ignored - only for this MTO strategy.
When, for testing, we change the Strategy on the same material to 40,  the ATP check -everything else being equal- no longer happens, which indicates that the Order type, Del Type, ItCat, SLCat are all ok. What link am I missing ?
Somehow, selecting a different material strategy impacts the running of ATP.  It would already be useful to know, if in your system, when using Make-To-Order strategy, you see the same or not.
Help would be very appreciated.
Hans.

Thank you for the suggestion.   OVZI already has these settings (MRP type and RqType blank). 
I don't see how a setting in OVZI would explain that just changing the strategy on the material removes the problem : the key fields here (ItCat, MRPType) would have the same values and they would both come up with a requirement type, linked to a requirement class which has the AvC active (ovzg).  How come that gets overruled (I presume by the schedule line category DN) for one strategy and not the other ?
I could make an entry in ovzi to force it to go to the same requirement type all the time, but that will impact all materials using this ItCat and MRP type.  That seems like a too generic fix for a specific issue.  If you know of any other link between strategy (specifically MTO) and ATP behaviour, I'd be very interested.

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