Dismissing the petition the Court held that the PCIT had duly given an opportunity of hearing to the assessee and after applying his mind to the material on record and satisfying himself as regards the necessity of directing the assessee to get his accounts audited by an accountant as envisaged under S.  142(2A) of the Act had granted approval for the proposal for special audit. Merely because the terms of reference contained some irrelevant directions, it would not vitiate the entire process. Except for bald allegations of mala fides, nothing substantial had been brought out so as to establish actual mala fides on the part of the Assessing Officer. Moreover, though the period for completion of special audit was 120 days, after approximately two thirds of the period had elapsed, the assessee belatedly approached the court challenging it. This conduct of the assessee also disentitled him to the grant of discretionary relief under article 226 of the Constitution of India. The order directing special audit was valid. (AY. 2011-12, 2016-17)