Penalty u/s. 270A unjustified as application for immunity filed u/s. 270AA not decided within time limit

G R Infraprojects Limited Vs ACIT (Rajasthan High Court) Rajasthan High Court held that imposition of penalty u/s. 270A of the Income Tax Act unjustified as application filed u/s. 270AA for immunity of penalty not decided by AO within prescribed time limit. Facts- The petitioner is a public limited company and is engaged in the execution of turnkey infrastructure projects. The petitioner company filed the return of income for F.Y. 2019-2020 on 13.02.2021. A show cause notice u/s. 143(2) was issued to the petitioner-company. Subsequently, notices u/s. 142(1) of the Act were issued to the petiti...