The assessment of the appellant was completed  u/s 143(3)of the Act . Show cause notice was issued seeking to levy penalty u/s 270A  read with section 274 of the Act  for under reporting of income . The assessee submitted application before the AO in Form No. 68 in terms of section  270AA(2)  seeking immunity from imposition of penalty under section 270A of the Act . Department passed the order denying the immunity from penalty and prosecution on the ground that since no order under section 270AA had been passed by the jurisdictional Assessing Officer within the statutory time line . On writ the Court held that  the  object of the section to encourage / incentivize a tax payer  to fast -track settlement of issue and to recover tax demand and reduce protracted litigation . Consequently the order passed under section 270A  of the Act was set aside  the Department was directed to grant immunity under section 270AA of the Act . Relied on  Schneider Electric South East Asia (HQ) v .ACIT (IT)  (WP ( C) 5111 / 2022    ( WP( C) 5839/2022 & CM Appl. 17517-17518 , dt. 8 -4 -2022 )( AY. 2018 -19)