Section 142(2A) of the Income Tax Act, 1961— Audit— Special Audit — In accordance with the principles of natural justice, the assesse must be given opportunity of a pre decisional hearing before action is taken under section 142(2A). The opinion required to be formed by the AO under section 142(2A) must be based in objective criteria and not merely subjective satisfaction. While exercising jurisdiction under article 226 of the constitution of India, the Court does not sit in appeal over the order passed by the AO—Religare Finvest Ltd. vs. Deputy Commissioner of income tax [2019] 419 ITR 5 (Delhi