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June 2013 onwards even doubts about the correctness of the accounts, multiplicity of transactions, and specialized nature of business activities are some additional features that could invite a direction by the tax officer for a special audit over the tax audit. Interestingly we have no great judgments as of now to prevent the AO to invoke such action as most of the old judgment revolves around the old faction /ground of nature and complexity of accounts of the assessee.

In 426ITR132 there were reportedly multiple related party transactions and that counted with the AO as a reason good enough to inquire about the genuineness and reasonableness of the expenditure incurred. The AO found that the rational of professional charges paid were not explained as well as there were instances of higher than market rates being paid. Besides some warehouses for which rent is paid is found to be used by a third party. All of these are suggestive of doubts about the correctness of accounts with multiple sets of transactions like in case of recurring payment of rent or professional services entries.


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