Petitioner had received certain amount towards IT support services to its customers.  Assessing Officer  held that said receipts of assessee were liable to be taxed as royalty in terms of section 9(1)(vi) and DTAA, had issued show cause notices under section 270A for initiating consequential penalty proceedings. Petitioner moved an application to avail of statutory remedy as codified under section 270AA.  Dy. Commissioner, however, rejected application for grant of immunity. Petitioner had duly complied with statutory pre-conditions set out in section 270AA(1). Notices in terms of which action under section 270A  was  initiated failed to specify whether petitioner was being tried on an allegation of under-reporting or misreporting. Court held that   application for immunity could not be rejected and, therefore, impugned orders in terms of which application under section 270AA came to be rejected were liable to be quashed.  (AY. 2018-19, 2019-20)