2006 (11) TMI 135 - SUPREME COURT

Seizure - hearing given is only in terms of s. 142(3) which is limited only to the findings of the special auditor - order of assessment would be based upon the findings of special auditor subject of course to their acceptance by the AO. Even at that stage the assessee cannot put forward a case that power under section 142(2A) had wrongly been exercised - An appeal against the order of assessment, would not serve any real purpose as the appellate authority would not go into such a question