Penalty immunity hearings require meaningful opportunity before rejection, requiring fresh consideration where next-day notice prevents substantiation of claims.

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....The proviso to Section 270AA(4) bars rejection of a penalty-immunity application without a meaningful opportunity of hearing. Notice requiring appearance on the following day, followed by immediate rejection, was insufficient to allow applicants to present and substantiate their claims. The rejection orders were set aside, and the applications were remitted for fresh consideration after hearing the applicants and considering their material. Assessing Authorities were entitled to await expiry of the prescribed appeal period before deciding the applications; that delay did not invalidate the process.....