The  assessee’s application for immunity under section 270AA was rejected on ground that same was filed beyond stipulated period available for filing said application, however, no opportunity of being heard was granted to assessee, On writ allowing the petition the Court held that the proviso to sub-section (4) of section 270AA makes it amply clear that before an application is rejected, applicant must be given an opportunity of being heard  .  Accordingly the matter was remanded back to consider the application of the assessee.   ( AY. 2020 -21 )