Dismissing the petition the Court held that the assessee was afforded an opportunity of hearing before taking recourse to sub-section (2A) of section 142 directing the assessee for special audit. A questionnaire was also issued under section 142(1). These facts nullified the contention of the assessee that it had no effective opportunity of hearing. The reply was not found satisfactory because the assessee had not maintained its books of account accurately and had not followed the accounting principles correctly and the nature of accounts being complex and bulky had led the Department to take recourse to compulsory audit. The order directing special audit need not be interfered with. (AY.2017-18)