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Case lawConcepts › Special audit: when the officer sends your books to an outside auditor

Special audit: when the officer sends your books to an outside auditor

The Assessing Officer wants my accounts audited by a nominated chartered accountant. Can he do that, and what does it cost me in time?

The Assessing Officer wants my accounts audited by a nominated chartered accountant. Can he do that, and what does it cost me in time?

Yes, under s.142(2A), but only on specified grounds, only with the prior approval of a Principal Chief Commissioner, Chief Commissioner, Principal Commissioner or Commissioner, and only after giving you a hearing. The report is due within a period fixed by the officer, extendable to an outer limit of 180 days, the cost is borne by the Central Government, and the whole period is excluded from the limitation for completing the assessment.

This is an explainer, not a judgment. It states the law in our own words, which is exactly why it needs checking. Everything below was written from the sources listed at the foot of this page, and no chartered accountant has yet signed it off. Read the source before you rely on it in a reply or an appeal.

Section 142(2A) lets the Assessing Officer direct that the assessee get his accounts audited by an accountant nominated by the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner, and furnish a report in the prescribed form. The grounds were widened by the Finance Act, 2013 and now cover the nature and complexity of the accounts, the volume of the accounts, doubts about the correctness of the accounts, multiplicity of transactions in the accounts, and the specialised nature of business activity of the assessee — in each case having regard also to the interests of the revenue.

The grounds are not a formality. The Supreme Court's approach is that the officer must make a genuine and honest attempt to understand the accounts himself before invoking the section; s.142(2A) is not a device for shifting the officer's own responsibility onto an outside auditor. That has been the position since Rajesh Kumar v. DCIT, 287 ITR 91 (SC), affirmed by the larger bench in Sahara India (Firm) v. CIT.

There are two safeguards. The first is approval: the Assessing Officer cannot issue the direction on his own, and the approving authority's satisfaction has to be a real application of mind. Sahara India described an approval that is 'an empty ritual' as not satisfying the section. Appellate authorities cannot direct a special audit themselves — the power belongs to the Assessing Officer, or to a Joint Commissioner exercising the functions of an Assessing Officer.

The second is the hearing. The proviso requires that the assessee be given a reasonable opportunity of being heard before the direction is issued. Sahara India held that even though the section did not originally say so in terms, principles of natural justice have to be read into it, because a special audit direction carries serious civil consequences — the assessee has to open his books to an outsider and live with an extended assessment window. A direction issued without a pre-decisional hearing is open to challenge by writ.

On timing, s.142(2C) lets the Assessing Officer fix the period for furnishing the report, and allows extension both on the assessee's application and on the officer's own motion, but the aggregate period cannot exceed 180 days from the date the direction is received. On cost, s.142(2D) puts the auditor's remuneration and the incidental expenses on the Central Government, determined by the Principal Chief Commissioner or Chief Commissioner — the assessee does not pay the nominated auditor's fee.

The sting is in limitation. The Explanation to s.153 excludes, in computing the period for completing the assessment, the time from the date the direction is issued to the last date on which the assessee is required to furnish the report — or, where the direction is challenged, up to the date of the court's order. If, after that exclusion, less than sixty days of limitation remain, the period is extended to sixty days. So a special audit direction can add the better part of six months, plus the duration of any writ, to the department's time to assess. That is often the real reason a direction is issued late in the limitation period, and it is a point worth taking if the timing looks tactical rather than substantive.

Why it matters

A special audit direction is expensive in disruption even though it is free in fees, and it hands the department extra months of limitation. Because it is issued mid-assessment and is not an appealable order, the only practical remedy is a writ, and the writ has to be filed quickly. The grounds — approval, hearing, and whether the officer really tried to understand the books — have to be identified at the direction stage.

What to do

Where people go wrong

Unsettled, or not pinned down. I could not fetch the bare text of s.142(2A) to (2D) or of the Explanation to s.153, so the 180-day outer limit, the sixty-day minimum extension and the exact wording of the approval requirement rest on commentary rather than statute. There is authority — noted in a TaxGuru headline I did not fetch — holding that a direction issued without a hearing is an irregularity rather than an illegality, which would affect the remedy; that line should be checked before assuming a direction is void for want of a hearing. The prescribed form of the special audit report and the position on whether a special auditor may express legal opinions were both flagged in search results but not verified.

Authorities on these sections

Judgments in this library that turn on the same provisions.

Where this came from

Every page in this library links to what it was written from, so you can check it rather than take our word for it.