Bal Krishan Sood v. ITO (2020) 84 ITR 307 (Chand)(Trib.)

S. 142(2A) : Inquiry before assessment-Special audit- Appeal maintainable before Appellate Tribunal-Complexity of Books of account established-Order for special audit sustainable. [S. 253]

Tribunal held  that considering the volume of transactions involved, the details of which were not reconcilable on account of different particulars mentioned therein, some being signed by truck owners, others by third parties, and payments being made in part in cash that too to different parties, the documents and accounts drawn therefrom were definitely not capable of presenting a clear picture of each transaction. On the contrary, the different details mentioned in the documents pertaining to each transaction made it very complex requiring deeper verification of each transaction. The Commissioner (Appeals) was correct in upholding the reference made for special audit. Consequently, the challenge by the assessee to the validity of the assessment order as being barred by limitation on account of the extended time taken by the Assessing Officer for passing the assessment order was also to be dismissed (AY. 2007-08)