AO Must Record Reasons to Reject Section 270AA Immunity: Calcutta HC

Amalgam Steel Private Limited & Anr. Vs ACIT & Ors. (Calcutta High Court) The Calcutta High Court examined the validity of an order passed under Section 270AA of the Income Tax Act, 1961 rejecting an assessee’s application for immunity from penalty under Section 270A. The petitioner had filed its return of income for Assessment Year 2023–24 declaring nil income, which was initially processed under Section 143(1). Subsequently, a scrutiny assessment under Section 143(3) raised a tax demand of ₹10.49 crore. The petitioner filed an application for rectification under Section 154, co...