(Appeal by special leave against the judgment and order, dated March 3 1999, of the Delhi High Court in C.W.P. No. 1198 of 1999).

Income‑tax‑‑‑

‑‑‑‑Assessment proceedings‑‑‑Enquiry‑‑‑Special Audit‑‑‑Voluminous details to answer questions raised by assessing authority‑‑‑Assessing authority directing special audit of accounts to be carried out‑‑‑On basis of nature and complexity of accounts‑‑‑Valid‑‑‑Indian Income Tax Act, 1961, S.142(2A).

The High Court dismissed a writ petition filed by the assessee against an order under section 142 (2A) of the Income Tax Act, 1961, directing special audit of its accounts to be carried out, because, on its own showing, the assessee had filed voluminous details running into about 500 pages to explain the questions raised by the assessing authority and further details running into 1,000 pages, and this prima facie supported the formation of the opinion by the assessing authority for conducting special audit under section 142(2A). On appeal to the Supreme Court:

Held, affirming the decision of the High Court, that there was no reason to conclude that the order directing special audit was for any reason other than the complexity of the assessee's accounts.

M.L. Verma and Kailash Vasudev, Senior Advocates (Ms. V.D. Khanna, Advocate with them) for Appellant.

B.B. Ahjua, Senior Advocate (Pritesh Kapur, B.V. Balram Das and Ms. Sushma Suri, Advocates with him) for Respondents.

ORDER

We are not impressed, in the first place, by the submission that, in any event, the assessment in respect of the concerned assessment year has become time‑barred. Nor do we find any justification for interfering with the order of the High Court that has summarily dismissed the appellant's writ petition. We have seen the order by which the Joint Commissioner of income‑tax called for a special audit. We see no reason to conclude that the order was for any reason other than the complexity of the appellant's account, which are referred to in some detail in the Joint Commissioner's order.

The civil appeal is dismissed with costs

M.B.A./1109/FCAppeal dismissed