The Assessing Officer rejected the assessee’s application under section 270AA(2) for immunity from penalty under section 270A on the ground that it was barred by limitation. On writ the Court held that  the order rejecting the assessee’s application under section 270AA(2) was set aside for non-compliance with section 270AA(4) which provides for opportunity of hearing to the assessee before rejecting the application. The matter was remanded to the Assessing Officer for reconsideration after hearing the assessee. Matter remanded. (AY. 2020-21)