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14. That the order passed under Section 142(2A) is purely administrative in nature and that such order is not quasi judicial admits of no ambiguity. The law-makers while enacting Section 142(2A) empowered the AO to direct the assessee to get the accounts audited by special auditor. The legislature, to ensure that such power is not abused, provided safeguards. For forming an opinion as to whether it is necessary to have the accounts of the assessee audited by a special auditor, the AO has to have regard to the nature of complexity of the accounts of the assessee and the interest of the Revenue. After forming such opinion, he has to seek the approval of the Chief CIT or the CIT, as the case may be, before any direction is issued to the assessee to have his accounts audited by a special auditor. This by itself is a vital safeguard in preventing abuse of power. In the very scheme of things, we are unable to read that the assessee needs to be heard before the directions are issued to the assessee for audit of its accounts by a special auditor. Such order, in our opinion, does not entail any civil consequences. No decision is given. Merely because the assessee is required to pay the auditor's fee, that does not mean that any liability is created against the assessee and that such order entails any civil consequences. The issuance of direction for special audit facilitates the AO to have the complex accounts of the assessee examined by an independent auditor. That helps and assists him in assessing the income of the assessee. We find ourselves in agreement with the view of the Allahabad High Court in the case of Jhunjhunwala Vanaspati Ltd. (supra) and respectfully disagree with the view of the Calcutta High Court in the case of Peerless General Finance & Investment Co. Ltd. (supra) and West Bengal State Co-operative Bank Ltd. (supra) and the view of the Kerala High Court in the case of Muthoottu Mini Kuries (supra). In our opinion, the assessee is not required to be heard before passing an order under Section 142(2A)of the IT Act, 1961.