On appeal by the assessee , the Tribunal held that show cause notice was required to be given to the assessee by the Assessing Officer before making the order proposing conduct of special audit under S. 142(2A) of the Act and even if the administrative Commissioner approves the said proposal after giving opportunity to the assessee, nonetheless such a course of action would be vitiated because of non- compliance to the principles of natural justice at the stage of making the proposal. Accordingly, Tribunal interfered with the same. It may also be mentioned that following setting aside of the approval given by the administrative Commissioner, the assessment order in the present case (following search) was found to be beyond the period of limitation. Therefore, the same was declared invalid and bad in law.  Dismissing the appeal of revenue High Court affirmed the order of the Tribunal.  (ITA Nos ,448/PN/2013 / 309/PN/2013 dt 21-12-2016    (AY .2005-06, 2006 -07) )  (ITA NO. 1329 of  2017, /ITA NO. 1188 of  2017/ ITA  NO. 1321 of  2017  dt 27 -01 -2020  )