Amalgam Steel (P.) Ltd. v. Asst. CIT (2026) 309 Taxman 174 (Cal)(HC)

S.270AA: Immunity from imposition of penalty-Application for immunity from penalty was rejected without considering the assessee’s contentions, or the reasons could not withstand judicial scrutiny and therefore is liable to be set aside. [S. 143(1), 270A(9), Art . 226].

Hon’ble Calcutta High Court held that it is now well settled that reasons are live links between the narrative and the directive and that an order without reasons can also be treated as a nullity. As the order impugned does not evince any application of mind on the part of AO and also does not cite any reason on the basis of which the ultimate conclusion has been arrived at, the same cannot withstand judicial scrutiny, and therefore, the same is liable to be quashed and set aside.(AY. 2023-24) 

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