If Nature of account is complex, Special Audit u/s 142(2A) may be ordered in the Interest of revenue

RELEVANT PARAGRAPH Having heard learned counsel for the parties, we have perused the impugned order and the material available on record. The apex Court, in the case of Rajesh Kumar Vs Dy. Commissioner of Income Tax reported in (2006)287 ITR 91 while considering the scope of Section 142(2A)of the Act has held that before issuing the direction for the special audit it is necessary to give opportunity to the assessee. It appears that having regard to the said decision the proviso to Section 142(2A)of the Act has been added providing an opportunity to the assessee before issuing the direction for...