Sahara India (Firm) vs Cit And Anr.

The Supreme Court held that the requirement for a pre-decisional hearing before issuing a direction under Section 142(2A) of the Income Tax Act, 1961, as suggested in Rajesh Kumar v. Dy. CIT, is not a blanket rule applicable to all cases. The Court clarified that while certain observations in Rajesh Kumar may imply a need for hearing, this does not hold universally, leading to the referral of the matter to a larger bench for clarification. The order for special audit remains operative pending the outcome of the petition.