(1.) HELD on the question of admission.
(2.) BY this petition, the petitioner seeks to lay a challenge to the initiation of special audit contemplated by sub-s. (2A) of S. 142 of the IT Act, 1961 ('the Act').
(3.) IT is submitted by the learned counsel for the petitioner that in order to attract the applicability of the provision the AO must be satisfied with the availability of the following two facts :