There are some common scenarios where calling pre-flop with AA instead of 3-betting can be preferable.
If you're in the blinds facing a single raise, and your stacks are extremely deep, then you're just building a big pot out of position where you aren't able to get the SPR low enough to avoid giving your opponent huge implied odds
with a lot of hands. In this situation, the deep stacks make your positional disadvantage more important of a consideration than your cards.
Another common spot is when you're in early position facing an early position raise. Suppose in a 9-handed game UTG open raises, and you're in UTG+1 or UTG+2 with AA. Unless your ranges are balanced well, 3-betting here will often get even KK to fold against a lot of decent opponents in small stakes games. Calling is often a superior option.