Sec. 142(2A) of Income Tax Act, 1961— Audit—The proviso to s. 142(2A) does not envisage any personal hearing before an order under sub-s. (2A) can be passed and the said proviso only requires giving reasonable opportunity of being heard to the assessee and such reasonable opportunity ordinarily would not include right of personal hearing. It may, in a given case, at the discretion of the AO that the same may be granted and the same may even be either desirable or necessary in given set of circumstances where complex and technical questions of law and facts are involved and such requirement, however, cannot be read into or fastened under the proviso to s. 142(2A)—NBCC (INDIA) LTD. Vs. ADDI. CIT - [2020] 313 CTR 254 (DEL)