Dismissing the petition the Court held that the Assessing Officer had considered the nature of accounts and the complexities involved in the accounts and a few such complexities involved in the accounts and had given reasons for the rejection of the objections filed by the assessee. The assessee had once again submitted objections on December 23, 2011 which were also disposed of on December 26, 2011. Thus, the opportunity to defend the case by way of pre-decisional hearing was provided as no final order was passed based on the proceedings dated December 9, 2011 directly. Further, the assessee had not challenged the order dated December 9, 2011, as a final order. This being the admitted facts between the parties, there was no reason to disbelieve the proceedings dated December 9, 2011, though it was not aptly worded, as rightly stated by the Department. The order for special audit under section 142(2A) was sustainable. (AY. 2009-10) (SJ)