Assessee received notice under Section 270A proposing penalty for alleged misreporting/underreporting of income, and submitted objections denying misreporting and disputing initiation of penalty. To comply with the one-month limitation in Section 270AA(2), the assessee also filed an application seeking immunity under Section 270AA.ACIT issued an order rejecting the application for immunity under Section 270AA, proceeding on the view that misreporting stood proved. On writ the court held that since objections filed by the assessee against the notice under Section 270A had not yet been adjudicated, the authority could not have proceeded to reject the application under Section 270AA before taking a final decision on imposition of penalty under Section 270A. Accordingly, the order was set aside with direction to the authority to consider objections and then take a final decision both on requisites under Section 270A and Section 270AA.