Dismissing the petition the Court held that, since there was continued non-compliance, a show-cause notice in respect of specific queries raised therein was issued on May 30, 2019. Another notice dated June 3, 2019 in the form of a corrigendum to the show-cause notice was issued, calling upon the assessee to produce the books of account. The questionnaire raised by the AO was not specifically answered. Despite the honest attempt made by the Assessing Officer in understanding the accounts of the assessee, it had not yielded the desired results, thereby warranting the appointment of the special auditor. At this stage, it could not be held that there was no correlation between the aspects which required scrutiny and the terms of reference for the special auditor under the law. The direction for special audit was justified. Followed Sahara India (Firm) v.CIT (2008) 300 ITR 403 (SC)  (AY.2016-17)