2026 (9) TMI 1643

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....tioner has challenged the order dated 30.07.2026 passed by the respondent no.1- the Assessing Officer under Section 270AA of the Income Tax Act, 1961 (hereinafter referred to as 'the Act of 1961') vide which petitioner's application under Section 270AA(2) of the act of 1961 seeking immunity from the penalty proceedings has been rejected. 2. The petitioner company is engaged in the business of letting out immovable property and has been filing its return of income. During the assessment year 2024-25, the petitioner declared a total income of Rs. 5,43,52,210/- under the head Profits and Gains of Business and Profession and filed its return. 3. Petitioner's assessment was done under Section 143(3) of the Act of 1961 read with Section 144....

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....tioner's application vide order dated 30.07.2026, inter alia, recording that the petitioner did not file any reply. 9. Learned counsel for the petitioner pointed out that it is clear from record that the petitioner had filed a reply to the notice dated 28.07.2026 issued by the AO on 29.07.2026 (Annexure P-12) and contended that the petitioner has placed the acknowledgement of such reply which showed that the same was filed on 29.07.2026 vide its Reference ID: 100117217516, yet the AO has arbitrarily rejected petitioner's application citing that the reply had not been filed by the petitioner. 10. Invitng Court's attention towards annexure P-16, learned counsel for the petitioner pointed out that on 30.07.2026, the respondent had seen t....